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A Limited directly owns 90% of the ordinary share capital of B Limited, and 60% of the ordinary share capital of C Limited. B Limited directly owns 40% of the ordinary share capital of C Limited. For the purposes of S151(4) assume all entitlements follow share capital. Without the inclusion of indirect ownership A and B are in the same group (because B is a 75%+ subsidiary of A), but C would not be part of the group (because it does not form the relationship of a 75% subsidiary nor the common 75% subsidiary of a third company). To remedy this the legislation looks at indirect ownership and combining multiple chains of ownership. Ss1155 and 1156 treat A as indirectly owning the ordinary share capital owned (directly or indirectly) by B, including its shares in C. Here, the formula would be; Fraction of share capital owned by A in B x Fraction of share capital owned by B in C, or 90% x 40% = 36% So A directly owns 60% of C, and indirectly owns 36% of C (through B). S1157 then require that these fractions be added together to give A's total holding of C: 96%. 96% is sufficient to create a group relationship, so A, B, and C are all in a group for group relief purposes. Registered industrial and provident societies can be subsidiaries for the purpose of group relief, as well as owners of subsidiaries. In deciding whether a company is a '75% subsidiary', shareholdings owned directly or
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DCMS Ministerial hospitality, overseas travel and meetings with outside interest groups, newspapers and other media proprietors, editors and senior executives 1 Jan 012 - 31 Mar 012 ## Department For Culture, Media And Sport Quarterly Information GIFTS GIVEN OVER £140 Secretary of State, Rt Hon Jeremy Hunt MP Date gift given To Gift Value Nil Minister for Sport & the Olympics, Hugh Robertson MP Date gift given To Gift Value Nil Minister for Culture, Communications & Creative Industries, Ed Vaizey MP (DCMS) Date gift given To Gift Value Nil Minister for Tourism and Heritage, John Penrose MP Date gift given To Gift Value Nil From Gift Value Outcome GIFTS RECEIVED OVER £140 Secretary of State, Rt Hon Jeremy Hunt MP Date gift received Nil From Gift Value Outcome Minister for Sport & the Olympics, Hugh Robertson MP Date gift received Nil From Gift Value Outcome Minister for Culture, Communications & Creative Industries, Ed Vaizey MP (DCMS) Date gift received Nil From Gift Value Outcome Minister for Tourism and Heritage, John Penrose MP Date gift received Nil HOSPITALITY1 Rt Hon Jeremy Hunt MP, Secretary of State Date Name of Organisation Type of Hospitality Received (include an asterisk against the entry if accompanied by spouse/partner or other family member or friend) * 23 Jan 012 Richard Desmond - Channel 5 30 Jan 012 Carphone Warehouse Drinks 12 Feb 012 BAFTA Dinner and Ticket 21 Feb 012 British Film Institute Ticket 29 Feb 012 The Sun Lunch 04 Mar 012 The FA Group Tickets 16 Mar 012 Docklands Sinfonia Tickets* HUGH ROBERTSON MP, Minister for Sport and the Olympics Date Name of Organisation Type of Hospitality Received 9 Jan 012 BT Reception and entertainment* 12 Jan 012 Glasgow 2014 & London 2012 25 Jan 012 British Ski & Snowboard Dinner 31 Jan 012 Channel 4 Reception 6 Feb 012 Laureus Sports Awards 20 Feb 012 Association of National Olympic Committees 22 Feb 012 British Telecom Dinner 29 Feb 012 Football Association Ticket 6 Mar 012 LGA Overnight accommodation 7-8 Mar 012 Olympic Park Legacy Co. Overnight accommodation 27 Mar 012 LOCOG Dinner 28 Mar 012 International Olympic Committee John Penrose MP, Minister for Tourism & Heritage Date Name of Organisation Type of Hospitality Received 23 Jan 012 Bomber Command Reception 29 Feb 012 People 1st Drinks reception 1 Mar 012 Bank of America/Merrill Lynch 7 Mar 012 Sunday Times Lunch 15 Mar 012 Ladbrokes Lunch 1 Does not normally include attendance at functions hosted by HM Government; 'diplomatic' functions in the UK or abroad, hosted by overseas governments; minor refreshments at meetings, receptions, conferences, and seminars; and offers of hospitality which were declined. *indicates if accompanied by spouse/partner or other family member or friend. Lunch Reception Dinner Dinner Lunch Ed Vaizey MP, Minister for Culture, Communications and Creative Industries (DCMS) Date Name of Organisation Type of Hospitality Received (include an asterisk against the entry if accompanied by spouse/partner or other family member or friend) 6 Jan 012 Donmar Warehouse Theatre tickets* 9 Jan 012 Netflix Cocktail evening President's reception 12 Jan 012 Institute of Practitioners in Advertising 13 Jan 012 National Theatre Tickets 17 Jan 012 Advertising Stakeholders Lunch 18 Jan 012 Deloitte Media & Telecoms 2012 Dinner 27 Jan 012 CTF Partners Lunch 27 Jan 012 Winfield House Exhibition 27 Jan 012 Duchess Theatre Tickets* 31 Jan 012 Kandahar Group British Museum Exhibition ticket and reception 6 Feb 012 Barclays Capital Lunch 7 Feb 012 Blackstone Group Lunch 7 Feb 012 Soho Theatre Theatre ticket & dinner Lunch 9 Feb 012 Author's Licensing & Collecting Society 11 Feb 012 BAFTA/Chanel Dinner 12 Feb 012 British Film Institute Film awards/Reception/Dinner * 15 Feb 012 Donmar Warehouse Theatre tickets/Dinner* 17 Feb 012 British Fashion Council London Fashion Week launch event 17 Feb 012 Bush Theatre Theatre Tickets * 18 Feb 012 David Hockney Preview invitation * 20 Feb 012 Burberry Prorsum Ticket 21 Feb 012 Universal Brit Awards & Dinner * 25 Feb 012 English National Opera Tickets * 28 Feb 012 Film Policy Review Drinks/Dinner 29 Feb 012 Contemporary Art Society Auction/Dinner 1 Mar 012 Daily Telegraph Lunch 7 Mar 012 IKON Lunch 14 Mar 012 Digital Radio UK Lunch 19 Mar 012 Digital Radio UK Lunch Lunch 20 Mar 012 Professional Publishers Association 22 Mar 012 NSPCC Dinner 28 Mar 012 London Music Masters Tickets* 29 Mar 012 Channel 4 & ITV Lunch 29 Mar 012 Soho Theatre Tickets* ## Overseas Travel Secretary Of State, Rt Hon Jeremy Hunt Mp Date(S) Of Trip | Destination | Purpose of | |----------------------------------------------------------------------------------|-------------------| | trip | | | 'No 32 | | | (The | | | Royal) | | | Squadron' | | | or 'other | | | RAF' or | | | 'Charter' | | | or | | | 'Eurostar' | | | | | | Feb 012 | | | Vatican City | Cultural | | Delegation | | | | | | Feb 012 | | | Los Angeles/ USA | GREAT | | Campaign | | | | | | Mar 012 | | | Rio de Janeiro/ | | | Brazil | | | GREAT | | | Campaign | | | Minister for Sport and the Olympics - Hugh Robertson | | | 1-2 Feb | | | 012 | | | | | | | | | Lausanne | IIOC - illegal | | betting in | | | Sport | | | | | | | | | 7-8 Mar | Marseilles/France | | Legacy for | | | London | | | Melbourne/Australia GREAT | | | Mar 012 | Campaign | | | | | Minister for Culture, Communications & Creative Industries - Ed Vaizey MP (DCMS) | | | | | | 27 Feb | | | 012 | | | Copenhagen | Digital Single | | Market | | | | | | 012 | | | Israel | New Media | | Delegation | | | Minister for Tourism and Heritage - John Penrose MP | | | Nil | | | | | | | | Number of officials accompanying Minister, where nonscheduled travel is used Total cost including travel, and accommodation of Minister only *indicates if accompanied by spouse/partner or other family member or friend £437 ## Meetings With External Organisations2 (Including Meetings With Newspaper And Other Media Proprietors, Editors And Senior Executives) Secretary of State - Rt Hon Jeremy Hunt MP Date of Meeting Name of Organisation Purpose of Meeting Jan 012 Premier League To discuss football governance Jan 012 FA Group To discuss football governance Jan 012 LOCOG To discuss Cultural Olympiad Jan 012 LOCOG General discussion Jan 012 Creative Industries Roundtable General discussion - Museums Jan 012 National Museums Directors Conference Jan 012 BT To discuss broadband Jan 012 Channel 4 General discussion and reception Feb 012 Whitbread Plc 20.12% sign up campaign Feb 012 LOCOG To discuss Cultural Olympiad To discuss DAB Feb 012 BBC - Mark Thompson, John Tate, Tim Davie Feb 012 Intercontinental Group 20.12% sign up campaign Feb 012 Tony Gallagher - Telegraph General discussion/catch up Feb 012 Olympic Delivery Authority General discussion Feb 012 LOCOG To discuss Games operations Feb 012 LOCOG General discussion General discussion Feb 012 Three and Hutchinson Whampoa Feb 012 FA Group To discuss football governance Feb 012 Committee of Advertising Practice To discuss Press, Media Regulation Feb 012 British Olympic Authority General discussion Feb 012 LOCOG To discuss Cultural Olympiad Feb 012 BBC Trust To discuss local TV Mar 012 Google To discuss Comms Green Paper Mar 012 LOCOG To discuss Cultural Olympiad Mar 012 Amazon To discuss Comms Green Paper Mar 012 Virgin To discuss Comms Green Paper To discuss Comms Green Paper Mar 012 British Phonographic Industry (BPI) Mar 012 Wikipedia To discuss Comms Green Paper Mar 012 Press Complaints Commission To discuss Comms Green Paper Mar 012 LOCOG To discuss Cultural Olympiad Mar 012 News International To discuss Comms Green Paper 2 Does not normally include meetings with Government bodies such as other Government Departments and Agencies, NDPB's, Non-Ministerial Departments, Agencies, Government reviews and representatives of Parliament, devolved or foreign governments. | Mar 012 | BSkyB | To discuss Comms Green Paper | |---------------------------------------------------|---------------------------------|---------------------------------| | Mar 012 | Google | To discuss Comms Green Paper | | Mar 012 | Arqiva | To discuss Comms Green Paper | | Mar 012 | Transport for London | To discuss London 2012 | | transport | | | | Mar 012 | Lord Fellowes | General discussion | | Mar 012 | Union of Shop, distributive and | | | Allied Workers (USDAW) | | | | To discuss proposed restrictions | | | | on Sunday trading during 2012 | | | | Games | | | | | | | | Minister for Tourism & Heritage - John Penrose MP | | | | Date of Meeting | Name of Organisation | Purpose of Meeting | | To discuss betting levy | Jan 012 | Association of British | | Bookmakers; British | | | | Horseracing Authority | | | | Jan 012 | Postcode Lottery | To discuss Postcode lottery | | Metal Theft Working Group | Jan 012 | Lincs Police; British Transport | | Police; Kent Police | | | | Jan 012 | UK Music | Introductory meeting | | Jan 012 | Tourism Alliance | Breakfast meeting | | To discuss problem gambling | Jan 012 | Gambling Commission; Gala | | Coral | | | | Jan 012 | Classic British Hotels | To discuss 20.12% campaign | | To discuss 20.12% campaign | Jan 012 | Millennium and Copthorne | | Hotels | | | | Jan 012 | Music | Education | | Group | | | | To discuss National Plan for | | | | Music Education | | | | Jan 012 | Travel Lodge | To discuss 20.12% campaign | | Jan 012 | Trainline | To discuss domestic tourism | | Jan 012 | British Hospitality Association | To discuss 2012 Tourism Summit | | Feb 012 | Jurys Inns | To discuss 20.12% campaign | | Feb 012 | Camelot | To discuss wireless hubs | | Feb 012 | Radisson Edwardian Hotels | To discuss 20.12% campaign | | Feb 012 | British Horseracing Association | To discuss the levy | | To discuss the levy | Feb 012 | Association of British | | Bookmakers | | | | To discuss problem Gambling | Feb 012 | QAAD | | Evangelical Alliance | | | | Salvation Army | | | | Methodist Church | | | | Church of England | | | | CARE | | | | Catch up | Feb 012 | Association of British Travel | | Agents (ABTA) | | | | Feb 012 | Matheson & Co | To discuss tourism links with | | East Asia | | | | Feb 012 | Greenwich Foundation | Introductory meeting | | Feb 012 | Intercontinental Hotel Group | To discuss 20.12% campaign | |---------------------------------------------------------|---------------------------------|--------------------------------| | Feb 012 | Bet Fair, Remote Gambling | | | Association | | | | Mar 012 | British Horseracing | | | Authority/Association of British | | | | Bookmakers | | | | Mar 012 | The British Holiday & Home | | | Parks Association | | | | Minister for Sport and the Olympics - Hugh Robertson MP | | | | | | | | Date of Meeting | Name of Organisation | Purpose of Meeting | | Jan 012 | NBC News | To discuss 2012 Olympics | | Jan 012 | Daily Mail | 2012 Olympic Press Catch-up | | Jan 012 | UK Anti-Doping Agency | General discussion | | Jan 012 | Football League | To discuss football governance | | Jan 012 | | | | Women's Sport & Fitness | | | | Foundation (WSFF) | | | | Jan 012 | Premier League | To discuss football governance | | Jan 012 | Telegraph | | | Mirror | | | | Jan 012 | Chartered Institute for the | | | Management of Sport & | | | | Physical Activity | | | | Jan 012 | FA Group | To discuss football governance | | Jan 012 | Nations and Regions for | | | LOCOG | | | | Jan 012 | Football Foundation | General discussion | | Jan 012 | FIFA | General discussion | | Jan 012 | Independent On Sunday | Catch up | | Jan 012 | Premiership Rugby | General discussion | | Jan 012 | Mail; Independent | 2012 Olympics press catch up | | Jan 012 | British Olympic Association | Regular catch up | | Jan 012 | Chelsea FC | General discussion | | Jan 012 | John Paul II Foundation for | | | Sport | | | | Feb 012 | International Basketball | | | Federation | | | | Feb 012 | Daily Telegraph | 2012 Olympic press catch up | | Feb 012 | BBC | Catch up | | Feb 012 | Football Foundation | Catch up | | Feb 012 | The FA Group | To discuss football governance | | Feb 012 | Mail on Sunday | 2012 Olympic press catch up | | Feb 012 | Telegraph | 2012 Olympic press catch up | | Mar 012 | BBC | Catch up | | Mar 012 | Performance directors for: | | | Canoeing, Sailing, Equestrian, | | | | Hockey, Rowing | | | | Mar 012 | Rugby Football Union | To discuss RFU governance | | | | | | Transparency | | | | | | | To discuss New Levy proposals To discuss the Levy To discuss VAT on Caravans To discuss Future of Women's Sport 2012 Olympic Press Catch-up Introductory meeting with new Chair To discuss 2012 Olympic Games Catch up To discuss basketball Performance Directors Forum | Mar 012 | Football Association | Introductory meeting | |-----------------------------------------------------------------------------|-----------------------------|----------------------------------| | Mar 012 | British Olympic Association | General discussion | | Mar 012 | Rugby Football Union | To discuss governance issues | | Mar 012 | British Olympic Association | Catch up | | Mar 012 | Football Foundation | General discussion | | Mar 012 | Dow Chemical | To discuss London 2012) | | Minister for Culture, Communications and Creative Industries - Ed Vaizey MP | | | | (DCMS) | | | | | | | | Date of Meeting | Name of organisation | Purpose of meeting | | Library/Literacy Charities | | | | meeting | | | | Jan 012 | The Reading Agency | | | Bird, Booktrust | | | | National Literacy Trust | | | | Canongate Publishers and | | | | World Book Night | | | | Cause4 | | | | Jan 012 | Galaxy National Book Award | Introductory meeting | | Jan 012 | Community Media Association | Catch up | | Digital and Creative Funders | | | | roundtable | | | | Jan 012 | Arts Council England | | | TSB | | | | National Endowment for | | | | Science, Technology & the Arts | | | | (NEST) | | | | Arts & Humanities Research | | | | Council (AHRC) | | | | Creative England | | | | British Film Institute | | | | Tech City | | | | UKTI | | | | Skillset | | | | | | | | Jan 012 | Animation UK/Blue Zoo | To discuss Animation UK report | | Jan 012 | Sony Music | Introductory meeting with New | | Chair | | | | Jan 012 | Sue Charteris | Introductory meeting | | Jan 012 | Janice Blackburn | General discussion | | Jan 012 | BFI | Catch up | | Jan 012 | Everything Everywhere | To discuss mobile infrastructure | | project | | | | Jan 012 | Three | To discuss mobile infrastructure | | project | | | | Jan 012 | 02 | To discuss mobile infrastructure | | project | | | | Jan 012 | Deezer UK | General discussion | | Jan 012 | Mobile Network Operators; | | | Internet Service Providers | | | | To discuss self- regulatory | | | | agreement on traffic | | | | management | | | | Jan 012 | Content Providers | To discuss self-regulatory | agreement on traffic management Jan 012 Vodafone To discuss Mobile Infrastructure, Spectrum and Femto Cells Jan 012 Phil Redmond General catch up Jan 012 London Music Masters To discuss the Bridge Project Jan 012 Stuart Purviss, (former ITN CEO & Ofcom partner) To discuss DAB Memorandum of Understanding General discussion Jan 012 Music Education Monitoring Group: Jan 012 BT To discuss Digital Region Jan 012 Talktalk Catch up Jan 012 BFI To discuss responses to the FPR Jan 012 ICO Catch up Jan 012 BT Catch up Jan 012 BT To discuss the digital region Jan 012 Wedgewood Museum Trust To discuss the future of Wedgewood Museum To discuss the National Library Challenge Jan 012 World Book Night Cause4 TRA Booktrust National Literacy Trust (NLT) Introductory meeting Jan 012 Internet Watch Foundation (IWF) Feb 012 Booktrust General discussion Feb 012 Medicinema General discussion Feb 012 National Apprenticeships Service To discuss creative & digital apprenticeships Feb 012 Hutchinson Whampoa: 3UK To discuss Ofcom's spectrum auction consultation To discuss DAB Feb 012 BBC - Mark Thompson, John Tate, Tim Davie Feb 012 Artsandbusiness Catch up Feb 012 Animation UK Introductory meeting Online Copyright Infringement Roundtable Feb 012 Intellectual Property Office; Ofcom; BPI; Publishers Association; MPAA; Premier League; BT; Virgin Media; TalkTalk; Sky; Google; Internet Advertising Bureau; FACT Feb 012 Daily Telegraph General discussion Feb 012 Nikkei Handover of formal invitation To discuss search engines, rights holders Feb 012 LCA, Microsoft, yahoo, google, bpi, premier league, mpaa, Ofcom, IPO, & Publishers Association Feb 012 Heritage Foundation General discussion | Feb 012 | Rights Holders Groups | Roundtable on creative industries | |---------------------------------|------------------------------|--------------------------------------| | Mar 012 | National Youth Theatre | General discussion | | Mar 012 | CIPFA | To discuss library stats | | General discussion | Mar 012 | Attitude is Everything; GAMA; | | Shape; Action on Hearing Loss | | | | To discuss ePrivacy | Mar 012 | Google; Apple; Microsoft; | | Miozilla | | | | Mar 012 | Sky | General discussion | | Mar 012 | Hooper Communications | To discuss Digital Copyright | | Exchange | | | | Mar 012 | Live Nation | Introductory meeting | | Mar 012 | Creative England | Catch up | | Mar 012 | Creative and Cultural Skills | To discuss forward strategy | | Mar 012 | Shine Group | To discuss MacTaggart speech | | Mar 012 | Allen & Co | Introductory meeting | | Mar 012 | Alison Wedgwood | To discuss the future of | | Wedgewood Museum | | | | Mar 012 | Painting & Patronage | | | To discuss "promoting UK and | | | | Middle East Cultural relations" | | | | Mar 012 | Sony Pictures | General discussion | | Mar 012 | BFI | General discussion | | Introductory meeting | Mar 012 | UK Interactive Entertainment | | (UKIE) | | | | | | |
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The Victims' Code: Young victims of crime: Understanding the support you should get If you're a victim of crime, support and information is available to help you get through it. You can have an adult stay with you while the police ask you questions about what happened. This could be your parent or family friend but they need to be over 18 years old. You may be asked to make something called a witness statement. This is when you say what happened when the crime took place like what time it was and where you were. The police will ask you if you also want to make a Victim Personal Statement (VPS). This is when you say how the crime has made you feel and how it has changed things for you. The VPS lets you tell the judge and others in the court room how you feel about what happened to you. The Victims' Code is a Government document that tells you what support and information victims of crime in England and Wales should get from criminal justice agencies. These are organisations like the police and the courts. The Victims' Code has a special section for people who are under 18 because they should get extra support. Telling the police about the crime You can tell the police about a crime by phone, online or by going to the police station. The police should give you information so you know what happens after you've told them about the crime and what support you should get next. You don't have to make a VPS if you don't want to, but if you do choose to make one, it can be made at any time before the case goes to court. Once you have made a VPS and signed it, you can't take it back or change it but you can write another one to give more information to the police and courts. Unless you say you don't want this, the police will give your contact details to a charity that gives help to victims. Someone from the charity will get in touch with you to offer their help or support. You will be asked if you would like to read your VPS out in court if the suspect is found guilty. You do not have to do this if you don't want to and can ask for somebody else to read it out for you instead. If you don't want your VPS to be read out in court at all, the court will still look at it before they decide what punishment to give to the suspect. ## Knowing What'S Happening The police should get in touch with you or your parents to let you know how they are looking into the crime and whether anyone has been arrested or charged for the crime. You can tell the police how often you want to hear from them about the investigation and how you would like to be contacted. You can watch a video about being a witness at www.gov.uk/going-to-courtvictim-witness ZAHRA Zahra, 15, who was sexually abused, told the police about what had happened. "I had a great police officer, who explained what was happening and why, which meant that the whole time I knew what was going on." ## Going To Court If your case does not go to court, you should be told why not. If there is a trial, you may be asked to be a witness in court, this means you will have to speak in court to tell them what happened. If you are a witness at court, you should be told about what this means for you and should be kept up to date with what's happening. This includes: - information about where and when the court hearings will take place - whether the suspect has been allowed to go home until the court date or is being held in prison Also: - you may able to visit the court before the day of the trial if you want - someone from the Witness Care Unit should contact you before you go to court to answer all your questions about going to court and to help you until the case is finished "I went to the court a week before the trial and it was so helpful. I met the court usher who would actually be with me on the day which took away some of the stress of meeting some random person on the actual day." ## Being A Witness If you go to court as a young witness in a trial you may be able to use "special measures" to help make it easier for you to tell the court about the crime. Special measures are things like: - having a screen around the witness box so that you don't have to see the suspect or their family when you are answering questions - being able to give evidence by live video-link so you don't have to be in the same room as where the trial is taking place - the judge and lawyers remove their wigs and gowns to make you more comfortable - having someone, called an intermediary, be with you in court to help you understand the questions you are being asked You can also ask people who work at the court if you can wait in an area away from the suspect and their friends and family. ## Zahra "The usher showed me the court room and video link room which made me less worried and less nervous. The barrister was really nice, they asked if I wanted them all to wear wigs or not and they let me choose, which was really important as it made me feel like I had some control over what was happening. The barrister even showed me how he looked without his wig and talked to me about what he was going to say and do." ## The Judgment If the suspect is found guilty, you will be told what the sentence (their punishment) means. Sometimes the suspect is allowed to appeal the sentence. This is when they ask for the judge's decision to be changed or for the sentence to be reduced. If this happens, you should be told where and when the court will listen to the appeal. ## Zahra "The offender was found guilty and went to prison, but it took one month before he was sentenced. The sentence was confusing to me but my witness care officer was great at explaining what it meant." ## After The Trial If you've been a victim of a sexual or violent crime, and the suspect is sent to prison for more than 12 months, you will be able to join the Victim Contact Scheme. Victims on this scheme can get updates on what happens to the suspect after they go to prison and can give their thoughts on any rules the suspect must follow when they come out of prison. If you are under 18, your parent or guardian can decide to use this service to get updates and to pass on your views. ## Zahra "Before the offender came out of prison my probation Victim Liaison Officer came to see me to talk to me about the rules for the prisoner's release and explained that he would need to report to the probation service regularly. We also drew a map showing places where I would not want him to go, based on where I live and where I often go. My Victim Liaison Officer explained that if these were agreed to, he would not be able to go into those areas. It was good as the Victim Liaison Officer didn't just tell me what they were doing, they let me be a part of it and helped me make decisions which were really helpful." ## Restorative Justice As a victim you may be able to take part in Restorative Justice. This is when you have contact with the offender so that both of you can find a way forward and build a more positive future. It gives you a chance to tell them how the crime has affected you so they can understand the impact of their crime. The offender is also able to say why they did the crime and say sorry if they want to. Both you and the offender need to agree to this before it happens. You do not have to take part in Restorative Justice but you will be given lots of support if you decide to write to or meet the offender. GARY Gary, 15, attended a Restorative Justice meeting with the offender who had mugged him: "At first it felt strange to be so close to the offender. The officer who was there was a big help. Each person had a chance to speak. My family and I talked about how we were affected and so did the guy who mugged me. As he explained what happened and why- basically it was down to drugs, drugs, drugs - our anger went away. We all signed an agreement at the end, which included suggestions and changes that would improve the life of the offender and (hopefully) stop him committing more crimes in future. I am glad we attended the conference. The great thing about it was that the offender got to hear what it was like for me and was very sorry. We too got to see into his life and understood better what had driven him to crime." ## Not Happy With The Support? If you feel you are not getting the support the Victims' Code says you should, you can complain to the organisation which you don't think has supported you properly (for example the police or the Crown Prosecution Service). Every organisation has a complaints process to help you do this. Your complaint should be handled quickly and you should get a reply from them within ten working days. If you are still unhappy with their reply, you can complain via your Member of Parliament to someone called the Parliamentary and Health Service Ombudsman (www.ombudsman.org.uk) whose job is to make sure that organisations give the help they should to victims. If you are a victim of a violent crime, you might be able to get some money, called financial compensation. The Criminal Injuries Compensation Authority arranges these payments. Your parent or guardian can apply for compensation on your behalf - visit **www.gov.uk/claim-compensation-criminal** injury for more information. If you need this leaflet in an alternative format, for example in large print, please call +44 (0)203 334 3555 or email **general.queries@justice.gsi.gov.uk**. Watch Lucy's story on **YouTube http://www.youtube.com/user/MinistryofJusticeUK** or read the full Victims' Code on: www.gov.uk
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| SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | |-----------------------------------|--------------------------------|--------------------------------|-------------------------------|--------------|-----------| | | IRRECOVERABLE VAT | | | | | | PROCLASS | | | | | | | REF. | | | | | | | 3PB BARRISTERS | Corporate Serv & Neighbourhood | External Legal Fees | Legal Fees | 19/11/2018 | 350.00 | | A J WRIGHT BUILDER | Community Services | Llt - Melton | Melton - Dfg Agency Account | 01/11/2018 | 5,359.92 | | A J WRIGHT BUILDER | Community Services | Llt - Harborough | Harborough - Dfg Agency Acc. | 20/11/2018 | 12,199.01 | | ACTIVE ARTS GROUP | H Improv, Leisure & Regulatory | Leisure Dev. - Arts & Heritage | Project/Initiatives Fees | 01/11/2018 | 750.00 | | ADEXA DIRECT LIMITED | H Improv, Leisure & Regulatory | The Pavilion | Other Equipment | 12/11/2018 | 589.00 | | ADMIRAL CLEANING SUPPLIES LTD | Finance, Efficiency & Assets | Council Offices & Land | Cleaning | 07/11/2018 | 225.34 | | ANCHOR PRINT GROUP LIMITED | H Improv, Leisure & Regulatory | Control Of Dogs | Signs And Directions | 08/11/2018 | 269.71 | | ANCHOR PRINT GROUP LIMITED | Corporate Serv & Neighbourhood | Communications | District Magazine Publication | 13/11/2018 | 540.00 | | ANCHOR PRINT GROUP LIMITED | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 07/11/2018 | 225.00 | | ANCHOR PRINT GROUP LIMITED | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 15/11/2018 | 360.00 | | ANCHOR PRINT GROUP LIMITED | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 21/11/2018 | 270.00 | | ANCHOR PRINT GROUP LIMITED | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 21/11/2018 | 246.85 | | ANCHOR PRINT GROUP LIMITED | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 21/11/2018 | 410.70 | | ASSOCIATION OF BUILDING ENGINEERS | H Improv, Leisure & Regulatory | Building Control Division | E'Es Subscriptions | 29/11/2018 | 255.00 | | AYLESTONE PARK HOTEL | Community Services | Homelessness | Hire Of Rooms | 15/11/2018 | 240.00 | | AYLESTONE PARK HOTEL | Community Services | Homelessness | Hire Of Rooms | 15/11/2018 | 210.00 | | BACK CARE SOLUTIONS LTD | Leader | Human Res. Train & Development | Occupational Health | 29/11/2018 | 644.00 | | BEEJAY SUPPLIES | Corporate Serv & Neighbourhood | Vehicle Maintenance | Normal Repairs | 12/11/2018 | 305.17 | | BELL & SONS | Finance, Efficiency & Assets | Council Offices & Land | Rea: Building | 07/11/2018 | 220.00 | | BLABY AND DISTRICT SOCIAL CENTRE | H Improv, Leisure & Regulatory | Spa - Sports Dev. & Commercial | Hire Of Rooms | 01/11/2018 | 468.00 | | BLABY AUDIO VISUAL LIMITED | Finance, Efficiency & Assets | Council Offices & Land | Communications | 08/11/2018 | 232.00 | | BREAK GLASS SOLUTIONS | H Improv, Leisure & Regulatory | The Pavilion | Goods For Resale | 01/11/2018 | 300.00 | | BRENNTAG UK LIMITED | Other | General Fund Balance Sheet | Fuel | 07/11/2018 | 370.60 | | BRITISH RED CROSS | H Improv, Leisure & Regulatory | The Pavilion | Seminars & Short Training | 20/11/2018 | 279.00 | | BRITISH TELECOM PLC | Corporate Serv & Neighbourhood | Ict Services | Telecoms - Calls | 29/11/2018 | 2,333.59 | | BRITISH TELECOM PLC | Corporate Serv & Neighbourhood | Ict Services | Telecoms - Internal | 06/12/2018 | 925.02 | | BRITISH TELECOM PLC | H Improv, Leisure & Regulatory | Car Parks | Off Street Enforcement | 29/11/2018 | 1,759.02 | | BROOK STREET UK LIMITED | Corporate Serv & Neighbourhood | Refuse & Recycling Options | Project/Initiatives Fees | 08/11/2018 | 392.95 | | BROOK STREET UK LIMITED | Corporate Serv & Neighbourhood | Refuse & Recycling Options | Project/Initiatives Fees | 08/11/2018 | 433.35 | | BURDENS GROUP | Corporate Serv & Neighbourhood | Parks And Open Spaces | Equipment R & M | 21/11/2018 | 945.00 | | CAPITA BUSINESS SERVICESLTD | Finance, Efficiency & Assets | Banking Charges | Transaction Costs - Cards | 19/11/2018 | 3,122.42 | | CCS MEDIA LTD | Corporate Serv & Neighbourhood | Refuse & Recycling Options | Project/Initiatives Fees | 29/11/2018 | 1,212.30 | | CCS MEDIA LTD | H Improv, Leisure & Regulatory | Environmental Protection | Computer Equipment | 15/11/2018 | 259.68 | | CCS MEDIA LTD | Corporate Serv & Neighbourhood | Ict Services | Infrastructure - Cre | 07/11/2018 | 297.20 | | CDW LIMITED | Corporate Serv & Neighbourhood | Ict Services | Desktop - Workstations | 21/11/2018 | 8,498.25 | | CHARNWOOD BOROUGH COUNCIL | Community Services | Llt - Charnwood | Other Local Authorities | 22/11/2018 | 23,770.00 | | CHARTERED INSTITUTE OF HOUSING | Community Services | Community Serv. Group Manager | E'Es Subscriptions | 29/11/2018 | 298.00 | | CHARTERED INSTITUTE OF HOUSING | Community Services | Housing Services | E'Es Subscriptions | 29/11/2018 | 298.00 | | CHEMPAC SOLUTION LIMITED | Corporate Serv & Neighbourhood | Parks And Open Spaces | Protective Clothing/Uniforms | 21/11/2018 | 232.40 | | CHEMPAC SOLUTION LIMITED | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Protective Clothing/Uniforms | 21/11/2018 | 396.00 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | |-----------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|-----------| | | IRRECOVERABLE VAT | | | | | | PROCLASS | | | | | | | REF. | | | | | | | CIPFA | Finance, Efficiency & Assets | Financial Services | Books, Newspapers And Pubs | 07/11/2018 | 330.00 | | CLOCKWISE | Other | General Fund Balance Sheet | Deductions - Clockwise | 29/11/2018 | 605.00 | | COLLEGE GARTH LTD | H Improv, Leisure & Regulatory | Control Of Dogs | Small Misc Contracts | 08/11/2018 | 2,062.83 | | COMPASS MINERALS | Corporate Serv & Neighbourhood | Parks And Open Spaces | Materials - Purchase | 21/11/2018 | 1,185.22 | | COMPUTER CONTROLLED SOLUTIONS | H Improv, Leisure & Regulatory | The Pavillion-Landfill Gas Mon | Equipment R & M | 22/11/2018 | 4,000.00 | | COSBY PARISH COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 19/11/2018 | 2,245.00 | | COUNTESTHORPE PARISH COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 29/11/2018 | 586.00 | | COUNTY DRAINS LEICESTER LTD | Finance, Efficiency & Assets | Whetstone Depot | Rea: Drainage | 29/11/2018 | 1,005.50 | | CRAEMER UK LTD | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Bins - Domestic | 07/11/2018 | 750.00 | | CRAEMER UK LTD | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Bins - Domestic | 07/11/2018 | 750.00 | | CRAEMER UK LTD | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Bins - Domestic | 21/11/2018 | 4,750.00 | | CROFT HOTEL | Community Services | Homelessness | Hire Of Rooms | 15/11/2018 | 637.50 | | CYBERMEDIA SOLUTIONS LTD | Other | General Fund Balance Sheet | In Year Capital Additions | 29/11/2018 | 6,528.00 | | DAISY COMMUNICATIONS LIMITED | Corporate Serv & Neighbourhood | Ict Services | Telecoms - Calls | 13/11/2018 | 1,594.96 | | DENNIS EAGLE LTD | Corporate Serv & Neighbourhood | Vehicle Maintenance | Normal Repairs | 07/11/2018 | 381.46 | | DENNIS EAGLE LTD | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Accidental Damage Repair Costs | 22/11/2018 | 250.00 | | DESIGN 2 PRINT | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 01/11/2018 | 240.00 | | DESIGN 2 PRINT | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 01/11/2018 | 240.00 | | DESIGN 2 PRINT | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 12/11/2018 | 321.00 | | DINERS CLUB INTERNATIONAL | Community Services | Benefits Section | Public Transport Costs | 01/11/2018 | 311.65 | | DINERS CLUB INTERNATIONAL | Corporate Serv & Neighbourhood | Democratic Serv & Governance | Public Transport Costs | 01/11/2018 | 266.60 | | DISABILITY ADAPTATION SERVICES | Other | General Fund Balance Sheet | In Year Capital Additions | 01/11/2018 | 4,930.00 | | DISCLOSURE & BARRING SERVICE | Other | General Fund Balance Sheet | Misc - Criminal Records Bureau | 08/11/2018 | 484.00 | | DTM GARDENS & LANDSCAPES LIMITED | Corporate Serv & Neighbourhood | Parks And Open Spaces | Open Space Development | 20/11/2018 | 750.00 | | DTM GARDENS & LANDSCAPES LIMITED | Corporate Serv & Neighbourhood | Parks And Open Spaces | Open Space Development | 20/11/2018 | 1,541.00 | | DTM GARDENS & LANDSCAPES LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 20/11/2018 | 1,231.00 | | DTM GARDENS & LANDSCAPES LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 20/11/2018 | 6,985.00 | | DURA SPORT (LEISURE CARE) LIMITED | Finance, Efficiency & Assets | The Pavillion - Land And Build | Pla: All Weather Pitch Works | 07/11/2018 | 325.00 | | EAST LEICESTERSHIRE & RUTLAND CCG | Other | General Fund Balance Sheet | S106 Monies Payable To 3rd Par | 08/11/2018 | 50,469.85 | | EAST LEICESTERSHIRE & RUTLAND CCG | Other | General Fund Balance Sheet | S106 Monies Payable To 3rd Par | 08/11/2018 | 20,849.93 | | EDEN SPRINGS (UK) LTD | Finance, Efficiency & Assets | Council Offices & Land | Refreshments | 19/11/2018 | 327.22 | | ESPO | Finance, Efficiency & Assets | Council Offices & Land | Gas | 12/11/2018 | 2,002.79 | | ESPO | Finance, Efficiency & Assets | Council Offices & Land | Gas | 19/11/2018 | -295.43 | | ESPO | Finance, Efficiency & Assets | Council Offices & Land | Gas | 19/11/2018 | 1,479.35 | | ESPO | Finance, Efficiency & Assets | Council Offices & Land | Gas | 19/11/2018 | 453.27 | | ESPO | Finance, Efficiency & Assets | Council Offices & Land | Gas | 19/11/2018 | 778.90 | | ESPO | Finance, Efficiency & Assets | The Pavillion - Land And Build | Gas | 20/11/2018 | 325.39 | | ESPO | Finance, Efficiency & Assets | The Pavillion - Land And Build | Gas | 20/11/2018 | 339.78 | | ESPO | Finance, Efficiency & Assets | Council Offices & Land | Hygiene Equip & Supps | 13/11/2018 | 225.00 | | EXTRAVAGANZA | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 09/11/2018 | 645.00 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | |-----------------------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|-----------| | | IRRECOVERABLE VAT | | | | | | PROCLASS | | | | | | | REF. | | | | | | | F G MOSS & SON | Other | General Fund Balance Sheet | In Year Capital Additions | 21/11/2018 | 3,330.00 | | F G MOSS & SON | Community Services | Llt - Harborough | Harborough - Dfg Agency Acc. | 29/11/2018 | 390.00 | | F G MOSS & SON | Community Services | Llt - Harborough | Harborough - Dfg Agency Acc. | 29/11/2018 | 4,415.00 | | FAIRACRE SERVICES | Finance, Efficiency & Assets | Council Offices & Land | Pla: Plumbing | 07/11/2018 | 660.50 | | FAIRACRE SERVICES | Finance, Efficiency & Assets | Council Offices & Land | Pla: Plumbing | 07/11/2018 | 587.72 | | FAIRACRE SERVICES | Finance, Efficiency & Assets | Whetstone Depot | Rea: Plumbing | 07/11/2018 | 210.50 | | FAROL LIMITED | Corporate Serv & Neighbourhood | Parks And Open Spaces | Accidental Damage Repair Costs | 21/11/2018 | 212.23 | | FIRMSTEP LTD | Corporate Serv & Neighbourhood | Communications | Software Maintenance | 09/11/2018 | 7,537.00 | | FIRSTCALL T/A NESTOR PRIMCARE SERVICES LIMITE | Leader | Emergency Planning & Bus. Cont | Out Of Hours Service | 09/11/2018 | 283.38 | | FIRSTCALL T/A NESTOR PRIMCARE SERVICES LIMITE | Leader | Emergency Planning & Bus. Cont | Out Of Hours Service | 08/11/2018 | 216.05 | | FORD & SLATER | Corporate Serv & Neighbourhood | Vehicle Maintenance | Normal Repairs | 07/11/2018 | 441.46 | | FORD & SLATER | Corporate Serv & Neighbourhood | Vehicle Maintenance | Normal Repairs | 07/11/2018 | 965.92 | | FREETH CARTWRIGHT LLP | Corporate Serv & Neighbourhood | External Legal Fees | Legal Fees | 07/11/2018 | 2,500.00 | | GAMBLING COMMISSION | Planning, Housing, Econ & Comm | Grant Aid & Access Activities | Other Local Authorities | 13/11/2018 | 348.00 | | GAP PROPERTY SERVICES LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 14/11/2018 | 4,038.00 | | GILVAR LINING LTD | Finance, Efficiency & Assets | Council Offices & Land | Rea: Building | 21/11/2018 | 410.00 | | GIVE US A BREAK WINDOWS LIMITED | Finance, Efficiency & Assets | Whetstone Depot | Rea: Building | 07/11/2018 | 1,844.70 | | GYM SERVICE SOLUTIONS LTD | H Improv, Leisure & Regulatory | The Pavilion | Equipment R & M | 01/11/2018 | 262.50 | | HANDS CLEANERS LIMITED | H Improv, Leisure & Regulatory | The Pavilion | Cleaning | 20/11/2018 | 351.12 | | HARBOROUGH DISTRICT COUNCIL | H Improv, Leisure & Regulatory | Car Parks | Other Partnership Support | 19/11/2018 | 12,800.50 | | HAYLEY SHAW | H Improv, Leisure & Regulatory | The Pavilion | Hired Services | 21/11/2018 | 300.00 | | HEADLAND MULTIMEDIA LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 29/11/2018 | 936.00 | | HEADLAND MULTIMEDIA LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 15/11/2018 | 13,750.00 | | HEALTH MANAGEMENT LIMITED | Leader | Human Res. Train & Development | Occupational Health | 08/11/2018 | 1,722.70 | | HERITAGE HOTEL | Community Services | Homelessness | Hire Of Rooms | 15/11/2018 | 870.83 | | HERITAGE HOTEL | Community Services | Homelessness | Hire Of Rooms | 15/11/2018 | 325.00 | | HERITAGE HOTEL | Community Services | Homelessness | Hire Of Rooms | 15/11/2018 | 1,469.17 | | HINCKLEY & BOSWORTH COUNCIL | Corporate Serv & Neighbourhood | Communications | Hbbc: Ict Services Provision | 21/11/2018 | 4,969.75 | | HINCKLEY & BOSWORTH COUNCIL | Corporate Serv & Neighbourhood | Ict Services | Hbbc: Ict Services Provision | 21/11/2018 | 25,703.92 | | HINCKLEY & BOSWORTH COUNCIL | Corporate Serv & Neighbourhood | Ict Services | Hbbc: Ict Services Provision | 21/11/2018 | 30,673.67 | | HM COURTS & TRIBUNALS SERVICE | Finance, Efficiency & Assets | Recovery Team | Court Fees | 08/11/2018 | 512.50 | | HOWKINS AND HARRISON | Finance, Efficiency & Assets | Assets Management | Valuation Fees | 29/11/2018 | 300.00 | | IBM UNITED KINGDOM LIMITED | H Improv, Leisure & Regulatory | Health And Recreation | Equipment R & M | 15/11/2018 | 271.00 | | IDOX SOFTWARE LIMITED | Leader | Performance Management | Consultant'S Fees | 07/11/2018 | 1,900.00 | | IDOX SOFTWARE LIMITED | Leader | Performance Management | Computer Infrastructure | 13/11/2018 | 3,800.00 | | INPHASE LIMITED | Leader | Performance Management | Seminars & Short Training | 12/11/2018 | 395.00 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Environmental Maintenance | Temporary/Casual Staff | 07/11/2018 | 780.70 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Environmental Maintenance | Temporary/Casual Staff | 08/11/2018 | 780.70 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Environmental Maintenance | Temporary/Casual Staff | 07/11/2018 | 780.70 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Environmental Maintenance | Temporary/Casual Staff | 21/11/2018 | 856.01 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | |----------------------------------------------------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|-----------| | | IRRECOVERABLE VAT | | | | | | PROCLASS | | | | | | | REF. | | | | | | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Environmental Maintenance | Temporary/Casual Staff | 21/11/2018 | 859.83 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Parks And Open Spaces | Temporary/Casual Staff | 07/11/2018 | 976.65 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Parks And Open Spaces | Temporary/Casual Staff | 08/11/2018 | 976.65 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Parks And Open Spaces | Temporary/Casual Staff | 07/11/2018 | 878.99 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Parks And Open Spaces | Temporary/Casual Staff | 21/11/2018 | 976.65 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Parks And Open Spaces | Temporary/Casual Staff | 21/11/2018 | 976.65 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Temporary/Casual Staff | 07/11/2018 | 1,097.20 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Temporary/Casual Staff | 08/11/2018 | 854.55 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Temporary/Casual Staff | 21/11/2018 | 1,171.05 | | JAM PERSONNEL | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Temporary/Casual Staff | 21/11/2018 | 1,091.93 | | JOHN MERISON BUILDING & MAINTENANCE | Other | General Fund Balance Sheet | In Year Capital Additions | 07/11/2018 | 3,849.15 | | JOHNSTON SWEEPERS LTD | Corporate Serv & Neighbourhood | Environmental Maintenance | Other Equipment | 21/11/2018 | 1,594.00 | | JOHNSTON SWEEPERS LTD | Corporate Serv & Neighbourhood | Environmental Maintenance | Accidental Damage Repair Costs | 20/11/2018 | 271.92 | | KINGS ARMOURED SECURITY SERVICES LIMITED | H Improv, Leisure & Regulatory | Car Parks | Security Services | 01/11/2018 | 370.97 | | KLS GROUNDCARE MACHINERY LIMITED | Corporate Serv & Neighbourhood | Parks And Open Spaces | Equipment R & M | 29/11/2018 | 425.95 | | LCC COUNTESTHORPE LEYSLAND COMMUNITY COLLEGEH Improv, Leisure & Regulatory | Spa - Local Sports Alliance | Hire Of Rooms | 14/11/2018 | 360.53 | 0.00 | | LCC COUNTESTHORPE LEYSLAND COMMUNITY COLLEGEH Improv, Leisure & Regulatory | Spa - Local Sports Alliance | Hospitality | 21/11/2018 | 455.00 | 0.00 | | LEAWOOD BUILDERS | Finance, Efficiency & Assets | Public Conveniences | Rea: Building | 08/11/2018 | 538.00 | | LEAWOOD BUILDERS | Other | General Fund Balance Sheet | In Year Capital Additions | 14/11/2018 | 4,484.00 | | LEAWOOD BUILDERS | Other | General Fund Balance Sheet | In Year Capital Additions | 21/11/2018 | 7,882.00 | | LEICESTER CITY COUNCIL | Other | General Fund Balance Sheet | Deductions - Attach Of Earn. | 08/11/2018 | 270.74 | | LEICESTER DIGITAL PRINT | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 08/11/2018 | 225.00 | | LEICESTER DIGITAL PRINT | Corporate Serv & Neighbourhood | Publicity, Promotion & Market. | Publicity & Promotion | 08/11/2018 | 255.00 | | LEICESTERSHIRE COUNTY COUNCIL | Central Items & Appropriations | I&E Account - General Fund | Pensions | 01/11/2018 | 18,250.00 | | LEICESTERSHIRE COUNTY COUNCIL | Central Items & Appropriations | I&E Account - General Fund | Pensions | 29/11/2018 | 18,250.00 | | LEICESTERSHIRE COUNTY COUNCIL | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Commercial Waste Fees | 21/11/2018 | 9,496.99 | | LEICESTERSHIRE COUNTY COUNCIL | Planning, Housing, Econ & Comm | Planning Delivery | Consultant'S Fees | 08/11/2018 | 4,750.20 | | LEICESTERSHIRE COUNTY COUNCIL | Planning, Housing, Econ & Comm | Planning Delivery | Consultant'S Fees | 22/11/2018 | 9,641.00 | | LEICESTERSHIRE COUNTY COUNCIL | H Improv, Leisure & Regulatory | Spa - Exercise Ref & Heart Sm | Seminars & Short Training | 29/11/2018 | 300.00 | | LEICESTERSHIRE COUNTY COUNCIL | Corporate Serv & Neighbourhood | Local Land Charges | Lcc Fees | 20/11/2018 | 1,451.00 | | LEICESTERSHIRE COUNTY COUNCIL | Corporate Serv & Neighbourhood | Local Land Charges | Lcc Fees | 20/11/2018 | 1,461.00 | | LEICESTERSHIRE COUNTY COUNCIL | Corporate Serv & Neighbourhood | Local Land Charges | Lcc Fees | 20/11/2018 | 877.00 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 07/11/2018 | 4,665.00 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 14/11/2018 | 3,420.00 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 15/11/2018 | 3,115.00 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 22/11/2018 | 3,563.00 | | LEICESTERSHIRE COUNTY COUNCIL | Community Services | Llt - Melton | Melton - Dfg Agency Account | 20/11/2018 | 3,675.00 | | LEICESTERSHIRE COUNTY COUNCIL | Community Services | Llt - Melton | Melton - Dfg Agency Account | 20/11/2018 | 1,702.75 | | LEICESTERSHIRE COUNTY COUNCIL | Community Services | Llt - Harborough | Harborough - Dfg Agency Acc. | 20/11/2018 | 2,840.00 | | LEICESTERSHIRE COUNTY COUNCIL | Community Services | Llt - Harborough | Harborough - Dfg Agency Acc. | 20/11/2018 | 3,698.00 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | |-----------------------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|------------| | | IRRECOVERABLE VAT | | | | | | PROCLASS | | | | | | | REF. | | | | | | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | Creditors -County-Superann Ees | 01/11/2018 | 170,182.23 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | Creditors -County-Superann Ees | 29/11/2018 | 169,655.86 | | LEICESTERSHIRE COUNTY COUNCIL PENSION FUND | Leader | Comp./Early Ret. Regs & Lsa | Full Year Cap Cost | 01/11/2018 | 7,597.47 | | LEICESTERSHIRE COUNTY COUNCIL PENSION FUND | Leader | Comp./Early Ret. Regs & Lsa | Full Year Cap Cost | 08/11/2018 | 10,759.72 | | LEICESTERSHIRE COUNTY COUNCIL PENSION FUND | Leader | Comp./Early Ret. Regs & Lsa | Full Year Cap Cost | 13/11/2018 | 10,734.87 | | LEICESTERSHIRE COUNTY COUNCIL PENSION FUND | Leader | Comp./Early Ret. Regs & Lsa | Full Year Cap Cost | 13/11/2018 | 9,131.62 | | LION CONTAINERS LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 19/11/2018 | 2,190.00 | | LLOYDS BUSINESS NETWORKS LTD | Corporate Serv & Neighbourhood | Ict Services | Telecoms - Calls | 19/11/2018 | 238.48 | | LOCAL GOVERNMENT ASSOCIATION | Corporate Serv & Neighbourhood | Members Expenses/Allowances | Seminars & Short Training | 13/11/2018 | 329.00 | | LOCAL GOVERNMENT ASSOCIATION | Leader | Corporate Management | Seminars & Short Training | 13/11/2018 | 329.00 | | LODGE TYRES CO LTD | Corporate Serv & Neighbourhood | Vehicle Maintenance | Tyres | 29/11/2018 | 793.62 | | MALLARD CONSULTANCY LTD | Community Services | Comm Safety - Domestic Abuse | Subscriptions | 08/11/2018 | 330.00 | | MALLARD CONSULTANCY LTD | H Improv, Leisure & Regulatory | Environmental Protection | Subscriptions | 08/11/2018 | 330.00 | | MALLARD CONSULTANCY LTD | Planning, Housing, Econ & Comm | Planning Enforcement | Subscriptions | 08/11/2018 | 330.00 | | MAX CLEANERS & MAINTENANCE LIMITED | Finance, Efficiency & Assets | Whetstone Depot | Contract Cleaning | 12/11/2018 | 1,982.50 | | MAX CLEANERS & MAINTENANCE LIMITED | Finance, Efficiency & Assets | Whetstone Depot | Contract Cleaning | 12/11/2018 | 1,982.50 | | MAX CLEANERS & MAINTENANCE LIMITED | Finance, Efficiency & Assets | Whetstone Depot | Contract Cleaning | 12/11/2018 | 1,982.50 | | MAX CLEANERS & MAINTENANCE LIMITED | Finance, Efficiency & Assets | Whetstone Depot | Cleaning | 08/11/2018 | 1,982.50 | | MIDLAND HR ****DIRECT DEBIT ACCOUNT ONLY**** | Finance, Efficiency & Assets | Financial Services | Software Maintenance | 06/12/2018 | 303.88 | | MIDLAND HR ****DIRECT DEBIT ACCOUNT ONLY**** | Finance, Efficiency & Assets | Financial Services | Software Maintenance | 06/12/2018 | 319.08 | | MIDLAND HR ****DIRECT DEBIT ACCOUNT ONLY**** | Finance, Efficiency & Assets | Financial Services | Software Maintenance | 29/11/2018 | 520.94 | | MIDLAND HR ****DIRECT DEBIT ACCOUNT ONLY**** | Leader | Human Res. Train & Development | Software Maintenance | 06/12/2018 | 3,034.25 | | MIDLAND HR ****DIRECT DEBIT ACCOUNT ONLY**** | Leader | Human Res. Train & Development | Software Maintenance | 29/11/2018 | 3,329.70 | | MORGAN HUNT PUBLIC SECTOR LIMITED | Community Services | Benefits Section | Temporary/Casual Staff | 07/11/2018 | 2,125.00 | | MORGAN HUNT PUBLIC SECTOR LIMITED | Community Services | Benefits Section | Temporary/Casual Staff | 09/11/2018 | 2,125.00 | | MORGAN HUNT PUBLIC SECTOR LIMITED | Community Services | Benefits Section | Temporary/Casual Staff | 20/11/2018 | 2,125.00 | | MORGAN HUNT PUBLIC SECTOR LIMITED | Community Services | Benefits Section | Temporary/Casual Staff | 22/11/2018 | 2,125.00 | | MORGANS LOCKSMITHS | Corporate Serv & Neighbourhood | Parks And Open Spaces | Materials - Purchase | 07/12/2018 | 265.00 | | MORGANS LOCKSMITHS | Corporate Serv & Neighbourhood | Parks And Open Spaces | Materials - Purchase | 07/12/2018 | 381.20 | | ** NAME REDACTED ** | Other | General Fund Balance Sheet | Capital Grants Unapplied -Othe | 01/11/2018 | 1,461.33 | | ** NAME REDACTED ** | Other | General Fund Balance Sheet | Debtors - Insurance Claims | 01/11/2018 | 650.44 | | NORFOLK COUNTY COUNCIL | Corporate Serv & Neighbourhood | External Legal Fees | Legal Fees | 15/11/2018 | 2,610.88 | | NORTH WARWICKSHIRE & HINCKLEY COLLEGE | Leader | Staff Training And Development | Training Costs | 20/11/2018 | 1,495.00 | | NORTHGATE PUBLIC SERVICES | Community Services | Benefits Section | Seminars & Short Training | 29/11/2018 | 550.00 | | PARK AVENUE RECRUITMENT | Planning, Housing, Econ & Comm | Planning Delivery | Temporary/Casual Staff | 07/11/2018 | 1,054.50 | | PARK AVENUE RECRUITMENT | Planning, Housing, Econ & Comm | Planning Delivery | Temporary/Casual Staff | 13/11/2018 | 1,045.00 | | PICK EVERARD | Finance, Efficiency & Assets | Council Offices & Land | Pla: Building Works | 12/11/2018 | 2,565.00 | | PITNEY BOWES LTD | Corporate Serv & Neighbourhood | Customer Services | Post Room Equipment | 13/11/2018 | 612.68 | | POLYCOPY | Corporate Serv & Neighbourhood | Reprographics | Print Mats (Int. Print Room) | 15/11/2018 | 454.00 | | ** NAME REDACTED ** | H Improv, Leisure & Regulatory | Licencing - Hack Carr/Pvt Hire | Fees And Charges | 13/11/2018 | 238.40 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | |------------------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|----------| | | IRRECOVERABLE VAT | | | | | | PROCLASS | | | | | | | REF. | | | | | | | PREMIER WASTE & RECYCLING | H Improv, Leisure & Regulatory | Con Of Other Pub. Health Risks | Works In Default | 15/11/2018 | 1,253.52 | | REACH PUBLISHING SERVICES LIMITED | Finance, Efficiency & Assets | Assets Management | Valuation Fees | 29/11/2018 | 302.54 | | REACH PUBLISHING SERVICES LIMITED | Planning, Housing, Econ & Comm | Planning Delivery | Advertising - Notices | 01/11/2018 | 428.59 | | REACH PUBLISHING SERVICES LIMITED | Planning, Housing, Econ & Comm | Planning Delivery | Advertising - Notices | 08/11/2018 | 428.59 | | REACH PUBLISHING SERVICES LIMITED | Planning, Housing, Econ & Comm | Planning Delivery | Advertising - Notices | 15/11/2018 | 352.96 | | REACH PUBLISHING SERVICES LIMITED | Planning, Housing, Econ & Comm | Planning Delivery | Advertising - Notices | 21/11/2018 | 428.59 | | RED MONKEY PLAY LIMITED | Corporate Serv & Neighbourhood | Parks And Open Spaces | Equipment R & M | 07/11/2018 | 854.00 | | RED MONKEY PLAY LIMITED | Corporate Serv & Neighbourhood | Parks And Open Spaces | Equipment R & M | 07/11/2018 | 3,900.00 | | REDROX LEGAL CONSULTANTS LIMITED | Corporate Serv & Neighbourhood | External Legal Fees | Legal Fees | 07/11/2018 | 400.00 | | REGENT OFFICE CARE LIMITED | Corporate Serv & Neighbourhood | Parks And Open Spaces | Security Services | 15/11/2018 | 1,011.15 | | REGENT OFFICE CARE LIMITED | Corporate Serv & Neighbourhood | Parks And Open Spaces | Security Services | 15/11/2018 | 1,011.15 | | REGENT OFFICE CARE LIMITED | Finance, Efficiency & Assets | Council Offices & Land | Security Services | 07/11/2018 | 619.70 | | REGENT OFFICE CARE LIMITED | Finance, Efficiency & Assets | Council Offices & Land | Security Services | 08/11/2018 | 233.75 | | REGENT OFFICE CARE LIMITED | Finance, Efficiency & Assets | The Pavillion - Land And Build | Security Services | 15/11/2018 | 619.70 | | REGENT OFFICE CARE LIMITED | Finance, Efficiency & Assets | The Pavillion - Land And Build | Security Services | 15/11/2018 | 619.70 | | REGENT OFFICE CARE LIMITED | Finance, Efficiency & Assets | Whetstone Depot | Security Services | 08/11/2018 | 380.87 | | RICOH UK LIMITED | Corporate Serv & Neighbourhood | Reprographics | Mfd Copy Charge | 15/11/2018 | 323.14 | | RIJO 42 MACHINES LTD | H Improv, Leisure & Regulatory | The Pavilion | Goods For Resale | 04/12/2018 | 652.82 | | ROSIE CYHANCHUK | H Improv, Leisure & Regulatory | Spa - Exercise Ref & Heart Sm | Hired Services | 29/11/2018 | 277.50 | | ROYAL MAIL | Leader | Register Of Electors | Postages | 29/11/2018 | 1,167.60 | | ROYAL MAIL | Leader | Register Of Electors | Postages | 29/11/2018 | 238.70 | | SHAKESPEARE MARTINEAU | Corporate Serv & Neighbourhood | External Legal Fees | Legal Fees | 14/11/2018 | 488.00 | | SHARNFORD TRACTORS LTD | Corporate Serv & Neighbourhood | Vehicle Maintenance | Normal Repairs | 13/11/2018 | 531.73 | | SHORTLAND PARSLEY | Finance, Efficiency & Assets | Trad Services - Whet Ind Est | Management Fees | 29/11/2018 | 1,140.00 | | SHORTLAND PARSLEY | Finance, Efficiency & Assets | Trad Services - Whet Ind Est | Management Fees | 29/11/2018 | 425.00 | | SKY BUSINESS | H Improv, Leisure & Regulatory | The Pavilion | Licences | 21/11/2018 | 491.00 | | SODEXO MOTIVATION - DIRECT DEBIT ONLY | Other | General Fund Balance Sheet | Deductions - Childcare Voucher | 19/11/2018 | 3,434.00 | | SODEXO MOTIVATION SOLUTIONS UK LIMITED | Other | General Fund Balance Sheet | Debtors - Cycle To Work | 08/11/2018 | 640.00 | | SOLOPROTECT LIMITED | Other | General Fund Balance Sheet | Control A/C - Solo Protect | 29/11/2018 | 583.00 | | STEANS ASSOCIATES | Community Services | Llt - Harborough | Harborough - Dfg Agency Acc. | 20/11/2018 | 750.00 | | STORM ENVIRONMENTAL LIMITED | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Bins - Trade | 29/11/2018 | 2,259.20 | | STORM ENVIRONMENTAL LIMITED | Corporate Serv & Neighbourhood | Refuse Coll & Domestic Recyc | Bins - Trade | 29/11/2018 | 3,531.90 | | STRATA HOMES YORKSHIRE LIMITED | Planning, Housing, Econ & Comm | Planning Delivery | Fees And Charges | 21/11/2018 | 385.00 | | STREETVIBE YOUNG PEOPLES SERVICE | Community Services | Community Dev. - Youth Issues | Project/Initiatives Fees | 07/11/2018 | 1,155.00 | | TERBERG MATEC UK | Other | General Fund Balance Sheet | Debtors - Insurance Claims | 29/11/2018 | 390.00 | | THE PRUDENTIAL ASSURANCE COMPANY LIMITED | Other | General Fund Balance Sheet | Deductions - Avc | 29/11/2018 | 1,405.12 | | TOTAL GAS & POWER LIMITED | Finance, Efficiency & Assets | Council Offices & Land | Electricity | 22/11/2018 | 2,843.44 | | TOTAL GAS & POWER LIMITED | Finance, Efficiency & Assets | The Pavillion - Land And Build | Electricity | 04/12/2018 | 1,294.29 | | TOTAL GAS & POWER LIMITED | Finance, Efficiency & Assets | Whetstone Depot | Electricity | 14/11/2018 | 1,026.52 | | TOTAL GAS & POWER LIMITED | Finance, Efficiency & Assets | Whetstone Depot | Electricity | 14/11/2018 | 959.03 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | |--------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|-----------| | | IRRECOVERABLE VAT | | | | | | PROCLASS | | | | | | | REF. | | | | | | | UNISON | Other | General Fund Balance Sheet | Deductions - Unison | 08/11/2018 | 312.85 | | VANGUARD CONTRACTS LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 07/11/2018 | 4,233.30 | | VODAFONE LIMITED (CORPORATE) | Community Services | Light Bulb Project | Telephones (Mobile/Pagers) | 08/11/2018 | 211.03 | | VODAFONE LIMITED (CORPORATE) | Corporate Serv & Neighbourhood | Vehicle Maintenance | Telephones (Mobile/Pagers) | 08/11/2018 | 467.90 | | VODAFONE LIMITED (CORPORATE) | H Improv, Leisure & Regulatory | Environmental Protection | Telephones (Mobile/Pagers) | 08/11/2018 | 306.17 | | VODAFONE LIMITED (CORPORATE) | Corporate Serv & Neighbourhood | Ict Services | Telecoms - Internal | 08/11/2018 | 3,802.26 | | WATER PLUS GROUP LIMITED | Finance, Efficiency & Assets | Council Offices & Land | Water Charges | 19/11/2018 | 1,033.82 | | WATER PLUS GROUP LIMITED | Finance, Efficiency & Assets | Littlethorpe Depot | Water Charges | 09/11/2018 | 504.60 | | WATER PLUS GROUP LIMITED | Finance, Efficiency & Assets | The Pavillion - Land And Build | Water Charges | 20/11/2018 | 476.00 | | WATER PLUS GROUP LIMITED | H Improv, Leisure & Regulatory | Car Parks | Water Charges | 19/11/2018 | 943.74 | | WATERLOO HOUSING GROUP | Community Services | Hospital Discharge Project | Rent And Rent Deposits | 08/11/2018 | 427.84 | | WE CARE 4 AIR LTD | Other | General Fund Balance Sheet | In Year Capital Additions | 08/11/2018 | 2,092.50 | | WESTFIELD HOUSE HOTEL | Community Services | Homelessness | Project/Initiatives Fees | 15/11/2018 | 476.00 | | WHETSTONE PARISH COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 21/11/2018 | 15,400.00 | | WHETSTONE PARISH COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 29/11/2018 | 1,033.00 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 01/11/2018 | 424.74 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 08/11/2018 | 482.77 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 08/11/2018 | 498.92 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 14/11/2018 | 816.19 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 14/11/2018 | 682.61 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 20/11/2018 | 296.32 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 20/11/2018 | 486.37 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 29/11/2018 | 525.15 | | WOODWARD TURF CARE | Corporate Serv & Neighbourhood | Parks And Open Spaces | Open Space Development | 06/12/2018 | 220.00 | | WOODWARD TURF CARE | Corporate Serv & Neighbourhood | Parks And Open Spaces | Open Space Development | 06/12/2018 | 280.00 | | WOODWARD TURF CARE | Corporate Serv & Neighbourhood | Parks And Open Spaces | Open Space Development | 06/12/2018 | 360.00 | | WOODWARD TURF CARE | Corporate Serv & Neighbourhood | Parks And Open Spaces | Open Space Development | 06/12/2018 | 225.00 | | WOODWARD TURF CARE | Corporate Serv & Neighbourhood | Parks And Open Spaces | Open Space Development | 06/12/2018 | 300.00 | | ZEBRA TRAINING SERVICES | Community Services | Benefits Section | Seminars & Short Training | 14/11/2018 | 1,980.00 | | ZURICH INSURANCE GROUP LIMITED | Other | General Fund Balance Sheet | Creditors - Insurance -Ind Est | 08/11/2018 | 958.64 |
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24 February 2017 Jean-Alexis Souvras Director of Public Affairs Eurotunnel UK Terminal Ashford Road Folkestone KENT CT18 8XX Dear Jean-Alexis ## Eurotunnel Network Statement 2018 Further to your consultation of 4 November 2016 on Eurotunnel's Network Statement for the 2018 working timetable, I am pleased to provide the opinion of the Office of Rail and Road (ORR). Our comments have been developed in line with the principles set out in the co-operation agreement between ORR and ARAFER and with regard to the requirements of the Recast Directive (2012/34 EU), as implemented in Great Britain by the Railways (Access, Management and Licensing of Railway Undertakings) Regulations 2016. The comments of ORR (along with those of ARAFER) are attached as an annex to this letter. This letter and its annex will be published on our website, and has also been copied to Anne Yvrande-Billon, Vice-Presidente de l'Arafer. Yours sincerely Daniel Brown ## Annex: Opinion On Eurotunnel'S 2018 Network Statement Annexe À L'Avis N°2017-017 Du 22 Février 2017 Executive Summary Synthèse 1. Now that the binational regulation has been ratified in France and Great Britain, Autorité de Régulation des Activités Ferroviaires et Routières ("Arafer") and the Office of Rail and Road ("ORR") have become responsible for railway-related economic regulation, for the French and British sections of the Channel Fixed Link, respectively. 1. A la suite de la ratification du règlement binational en France et en Grande-Bretagne, l'Autorité de Régulation des Activités Ferroviaires et Routières (ci-après « Arafer ») et l'Office of Rail and Road (ci-après « ORR ») sont devenus compétents pour la régulation économique ferroviaire respectivement pour la partie française et la partie britannique de la Liaison Fixe Transmanche. 2. In that respect, Arafer and ORR agreed to try to adopt opinions and decisions promptly for both halves of the Channel Fixed Link that are consistent in both content and timing. This cooperation is aimed at promoting fair competition between railway undertakings and optimal use of rail capacity and efficiency in the operation of the Channel Fixed Link as well as full transparency and non-discriminatory access to the Channel Fixed Link. This is intended to increase the confidence of existing users as well as facilitating use of the infrastructure by new entrants. 2. L'Arafer et l'ORR sont convenus à cet effet de s'efforcer d'adopter des avis et décisions concernant les deux parties de la Liaison Fixe Transmanche d'une manière cohérente et coordonnée tant en ce qui concerne le calendrier que le contenu. Cette coopération vise, d'une part, à promouvoir une concurrence équitable entre les entreprises ferroviaires ainsi qu'une utilisation optimale des capacités et l'exploitation efficace des infrastructures de la Liaison Fixe Transmanche et, d'autre part, à assurer un accès transparent et non discriminatoire à la Liaison Fixe Transmanche. L'objectif est d'accroître la confiance des utilisateurs existants et de faciliter l'arrivée de nouveaux entrants. 3. In this opinion, Arafer and ORR present their views on whether Eurotunnel's 2018 Network Statement transparently presents all the information required for an applicant to gain access to the infrastructure; whether it contains provisions which would allow Eurotunnel to discriminate against applicants; and whether the charges for usage of the Channel Fixed Link are transparent and fair. 3. Dans cet avis, l'Arafer et l'ORR exposent leur analyse du document de référence du réseau d'Eurotunnel 2018 (ci-après « DRE »). Ils ont examiné si le DRE présentait de façon transparente les informations nécessaires pour qu'un candidat puisse accéder à l'infrastructure ; s'il contenait des clauses potentiellement discriminatoires ; et si les redevances d'utilisation de la Liaison Fixe Transmanche étaient transparentes et équitables. 4. Si, de façon générale, l'Arafer et l'ORR considèrent que le DRE a marqué un progrès sur certaines de ses composantes ces dernières années, les points suivants doivent être améliorés : 4. Overall, Arafer and ORR think that some aspects of the Network Statement have been improved in recent years but the following issues need improvement: a. the Network Statement should be more transparent. In particular it should be clearer about: a. le DRE devrait être plus transparent. Il devrait, en particulier, clarifier les points suivants : i. the terms on which a new entrant would access the Channel Fixed Link and the effects of that on existing users; i. les conditions d'accès qui s'appliqueraient à un nouvel entrant pour accéder à la Liaison Fixe Transmanche et leurs effets sur les utilisateurs existants; ii. les modalités d'allocation des capacités de la ii. how capacity is allocated in the Channel Fixed Link. Arafer and ORR recognise that at the moment there is an overall surplus of capacity in the Channel Fixed Link but the possibility cannot be excluded of problems at peak times. This should be resolved ex ante instead of waiting for a capacity problem to arise; Liaison Fixe Transmanche. L'Arafer et l'ORR sont conscients que la Liaison Fixe Transmanche dispose aujourd'hui de capacités globalement excédentaires mais il ne peut être exclu que des problèmes capacitaires surviennent aux heures de pointe. Des solutions à ces problèmes devraient être définies ex ante plutôt que d'attendre qu'ils surviennent ; iii. the relationship between Eurotunnel's proposed iii. la relation entre le cadre tarifaire proposé par charging structure and its actual and forecast costs is not clear. In particular Eurotunnel does not identify the costs directly incurred. Eurotunnel et ses coûts réels et prévisionnels manque de transparence. Eurotunnel n'identifie pas, en particulier, les coûts directement imputables. b. Arafer and ORR understand that Eurotunnel's actual charges to Eurostar (the only passenger train operator) are based on the railway usage contract (« RUC ») not the Network Statement and it is not clear enough how the charges in the RUC are consistent with those in the Network Statement. Annex 4 is a useful step with regard to reconciliation between the RUC and the Network Statement but it needs to be more clearly explained. b. L'Arafer et l'ORR comprennent que les redevances dont s'acquitte effectivement Eurostar (seul opérateur de transport ferroviaire de passagers) sont assises sur le contrat d'utilisation (ci-après « le RUC ») et non sur le document de référence d'Eurotunnel. De surcroît, la cohérence entre la tarification prévue par le RUC et les redevances qui sont définies dans le document de référence du réseau n'est pas suffisamment claire. Si l'annexe 4 constitue une avancée notable sur la question de l'articulation entre le RUC et le DRE, les explications proposées doivent être plus claires ; c. la présentation et la transparence des principes de c. the presentation and transparency of the applicable charging principles, as well as that of the resulting charges for the use of the infrastructure should be improved. In particular Eurotunnel should justify how the structure and level of charges, and the adjustment of charges applied to freight and passenger activities, are consistent with the charging principles laid down in the Directive; tarification applicables et leur déclinaison en redevances d'utilisation de l'infrastructure devraient être améliorées. En particulier, Eurotunnel devrait justifier de la conformité de la structure et du niveau des modulations appliquées aux trains de passagers et de fret avec les principes tarifaires posés par la directive ; d. The section on the performance regime does not fully d. la section relative au système d'amélioration des demonstrate compliance with the requirements of Directive 2012/34/EU and does not explain in enough detail how the performance regime works. performances ne démontre pas pleinement sa conformité avec les dispositions de la directive 2012/34/UE et ne décrit pas de manière assez détaillée le fonctionnement de ce dispositif. ## 1. Context 1. Contexte 1.1 Introduction 1.1 Introduction 5. Arafer and ORR's opinion is organised around the following themes : 5. L'avis de l'Arafer et de l'ORR est organisé autour des thématiques suivantes : a) the new features of the 2018 Network Statement; a) les nouveautés inscrites au DRE 2018 ; b) background on the concession, the railway usage contract (RUC) and the traffic that uses the Channel Fixed Link; c) where additional information is required for new entrants; and b) les éléments de contexte relatifs au contrat de concession, à la convention d'utilisation (RUC) et au trafic qui emprunte la Liaison Fixe Transmanche ; d) where the transparency of the 2018 Network Statement and, in particular, the charges it describes can be improved. c) les informations supplémentaires dont les nouveaux entrants ont besoin ; d) les sujets pour lesquels la transparence du DRE 2018 et, en particulier, des redevances d'accès, peut être améliorée. ## 1.2 Background Of The Opinion 1.2 Contexte De L'Avis 6. Aux termes d'un contrat de concession (ci-après « la Concession ») signé le 14 mars 1986 entre les gouvernements de la République française et du Royaume-Uni et les sociétés privées France Manche SA et The Channel Tunnel Group Limited (ci-après « les Concessionnaires »), les 6. Under a Concession Agreement (the "Concession Agreement") signed on 14 March 1986 between the Governments of French Republic and the United Kingdom and the private companies France Manche SA and The Channel Tunnel Group Limited (the "Concessionaires"), the Concessionaires have the right and the obligation to carry out the development, financing, construction and operation of the Channel Fixed Link for a total term of 99 years. The Concessionaires trade jointly under the name of Eurotunnel and fulfil the role of infrastructure manager of the Channel Fixed Link under Article 3.2 of Directive 2012/34/EU of the European Parliament and of the Council of 21 November 2012 establishing a single European railway area (recast) ("the Directive"). References in this opinion to Eurotunnel should be taken as a reference to the Concessionaires. Concessionnaires ont le droit et l'obligation d'assurer la conception, le financement, la construction et l'exploitation de la Liaison Fixe Transmanche pour une durée totale de 99 ans. Les Concessionnaires opèrent conjointement sous le nom d'Eurotunnel et remplissent le rôle de gestionnaire d'infrastructure de la Liaison Fixe Transmanche au sens du paragraphe 2 de l'article 3 de la directive 2012/34/UE du Parlement Européen et du Conseil du 21 novembre 2012 établissant un espace ferroviaire unique européen (refonte) (ci-après « la directive »). Ci-après, les références à Eurotunnel dans cet avis sont entendues comme s'adressant aux Concessionnaires. 7. Article 1 of the Binational regulation transferring economic rail regulation competence from the Intergovernmental Commission (the "IGC") to the national regulatory bodies, setting out principles for cooperation between them and establishing a charging framework for the Channel Fixed Link (the "Binational Regulation"), approved by French law n° 2016-702 of 30th May 2016 and by the Channel Tunnel (International Arrangements) (Charging Framework and Transfer of Economic Regulation Functions) Order 2015 states that: "1. The function of the IGC as a regulatory body is transferred to the regulatory bodies established by the United Kingdom and France by virtue of European law (…). 2. These regulatory bodies shall respectively have jurisdiction over the part of the Fixed Link situated on the territory of their State, as determined in accordance with article 3 of the Treaty of Canterbury". 7. L'article 1er du règlement binational transférant la compétence de régulation économique ferroviaire de la Commission intergouvernementale (ci-après « la CIG ») aux organismes de contrôle nationaux, établissant les principes de la coopération entre ceux-ci et portant établissement d'un cadre de tarification pour la Liaison Fixe Transmanche (ci-après, le « règlement binational »), régulièrement approuvé par la loi n° 2016-702 du 30 mai 2016 et par le *Channel Tunnel (International Arrangements)* (*Charging Framework and Transfer of Economic Regulation Functions*) Order 2015 dispose que: « 1. La fonction d'organisme de contrôle de la CIG est transférée aux organismes de contrôle établis en vertu de la législation européenne par la France et le Royaume-Uni […]. 2. Ces organismes de contrôle sont respectivement compétents sur la partie de la Liaison Fixe située sur le territoire de l'Etat dont ils relèvent, déterminée conformément à l'article 3 du Traité de Cantorbéry». 8. Therefore, Arafer and ORR have become responsible for the economic rail regulation of the French part and the British part respectively of the Channel Fixed Link. 8. Par conséquent, l'Arafer et l'ORR sont devenus compétents pour la régulation économique ferroviaire, respectivement pour la partie française et la partie britannique de la Liaison Fixe Transmanche. 9. L'article 3 du règlement binational prévoit que l'Arafer et l'ORR, dans l'exercice de leurs fonctions relatives à la Liaison Fixe Transmanche, prennent en compte la nécessité de se coordonner et d'adopter des décisions ou avis dont les effets juridiques et pratiques sont concordants sur l'ensemble de la Liaison Fixe Transmanche. A cette fin et afin d'assurer la sécurité juridique de la régulation de la Liaison Fixe Transmanche par l'adoption de décisions ou d'avis concordants, ils coopèrent étroitement et coordonnent leurs processus de décision, y compris par la mise en place de procédures communes de travail efficaces. 9. Article 3 of the Binational Regulation provides that Arafer and ORR, in the performance of their functions relating to the Channel Fixed Link, have regard to the need to coordinate and to adopt decisions or opinions that have an aligned legal and practical effect across the entirety of the Channel Fixed Link. To that end and for the purpose of ensuring legal certainty of the regulation of the Channel Fixed Link by the adoption of aligned decisions or opinions, Arafer and ORR should cooperate closely and coordinate their decision making process, including by putting in place effective common working arrangements. 10. This opinion reflects information provided to Arafer and ORR by Eurotunnel during 2016. It has also been informed by responses to questions which Arafer and ORR have put to all stakeholders (the infrastructure manager as well as existing and potential users of the Channel Fixed Link). Eurotunnel did not respond within the deadline to the questionnaire which Arafer and ORR sent them on 10 November 2016 (the deadline for response was 30 November 2016), despite the legal obligation to do so. Arafer and ORR received a response from Eurotunnel on 16 February 2017, at which point it was too late to take account of the information provided for the purposes of this opinion. Nevertheless, Arafer and ORR will review Eurotunnel's response and continue to work with Eurotunnel during 2017 to effect improvements to the Network Statement. 10. Cet avis tient compte des informations transmises par Eurotunnel en 2016 et des réponses aux questionnaires que l'Arafer et l'ORR ont transmis à l'ensemble des parties prenantes (le gestionnaire de l'infrastructure ainsi que les utilisateurs actuels et potentiels de la Liaison Fixe Transmanche). Eurotunnel n'a pas répondu dans les délais au questionnaire que l'Arafer et l'ORR lui ont adressé le 10 novembre 2016 (le délai de réponse expirait le 30 novembre 2016), en dépit de ses obligations légales. L'Arafer et l'ORR ont reçu la réponse d'Eurotunnel le 16 février 2017, trop tardivement pour leur permettre de prendre en compte les informations transmises dans le cadre de cet avis. Pour autant, l'Arafer et l'ORR examineront la réponse d'Eurotunnel et poursuivront le travail engagé avec Eurotunnel en 2017 pour améliorer le document de référence du réseau. ## 1.3 Scope Of The Opinion 1.3 Portée De L'Avis 11. Article 27 of the Directive provides that : 11. L'article 27 de la directive dispose que : « 1. Le gestionnaire de l'infrastructure établit et publie, après consultation des parties intéressées, un document de référence du réseau pouvant être obtenu contre paiement d'un droit qui ne peut être supérieur au coût de publication de ce document. Le document de référence du réseau est publié dans au moins deux langues officielles de l'Union. Son contenu est mis gratuitement à disposition sous forme électronique sur le portail internet du gestionnaire de l'infrastructure et accessible par un portail internet commun. Ce portail internet est mis en place par les gestionnaires de l'infrastructure dans le cadre de leur coopération conformément aux articles 37 et 40. "1. The infrastructure manager shall, after consultation with the interested parties, develop and publish a Network Statement which shall be obtainable against payment of a fee which shall not exceed the cost of publication of that statement. The Network Statement shall be published in at least two official languages of the Union. The content of the Network Statement shall be made available free of charge in electronic format on the web portal of the infrastructure manager and accessible through a common web portal. That web portal shall be set up by the infrastructure managers in the framework of their cooperation in accordance with Articles 37 and 40. 2. The Network Statement shall set out the nature of the infrastructure which is available to railway undertakings, and contain information setting out the conditions for access to the relevant railway infrastructure. The Network Statement shall also contain information setting out the conditions for access to service facilities connected to the network of the infrastructure manager and for supply of services in these facilities or indicate a website where such information is made available free of charge in electronic format. The content of the Network Statement is laid down in Annex IV." 2. Le document de référence du réseau expose les caractéristiques de l'infrastructure mise à la disposition des entreprises ferroviaires et contient des informations précisant les conditions d'accès à l'infrastructure ferroviaire concernée. Le document de référence du réseau contient également des informations précisant les conditions d'accès aux installations de service reliées au réseau du gestionnaire de l'infrastructure et la fourniture de services dans ces installations, ou indique un site internet où ces informations sont mises gratuitement à disposition sous forme électronique. Le contenu du document de référence du réseau est défini à l'annexe IV. » 12. A cet égard, le paragraphe 2 de l'article 56 de la directive dispose que l'organisme de contrôle « [v]érifie notamment si le document de référence du réseau contient des clauses discriminatoires ou octroie au gestionnaire de l'infrastructure des pouvoirs discrétionnaires pouvant être utilisés à des fins de discrimination à l'égard des candidats ». 12. In that respect, paragraph 2 of Article 56 of the Directive states that the regulatory body "shall, in particular, check whether the Network Statement contains discriminatory clauses or creates discretionary powers for the infrastructure manager that may be used to discriminate against applicants". 13. Paragraph 6 of Article 56 of the Directive also states that "The regulatory body shall ensure that charges set by the infrastructure manager comply with Section 2 of Chapter IV and are non-discriminatory". 13. En outre, le paragraphe 6 de l'article 56 de la directive précise que l'organisme de contrôle « [v]eille à ce que les redevances fixées par le gestionnaire de l'infrastructure soient conformes aux dispositions du chapitre IV, section 2, et non discriminatoires ». 14. Recital 34 of the Directive specifies that "[t]o ensure transparency and non-discriminatory access to rail infrastructure, and to services in service facilities, for all railway undertakings, all the information required to use access rights should be published in a Network Statement". 14. Le considérant 34 de la directive précise qu' « [a]fin d'assurer la transparence et un accès non discriminatoire aux infrastructures ferroviaires et aux services dans les installations de service pour toutes les entreprises ferroviaires, toutes les informations requises pour exercer les droits d'accès devraient être publiées dans un document de référence du réseau ». 15. These provisions are reflected in Article 3 of the Annex to the Binational Regulation setting out the Charging Framework for the Channel Fixed Link, which states that "When performing its functions, the infrastructure manager shall, at all times, ensure that the charges are transparent, nondiscriminatory and fair" as well as in French law, in particular in Articles L. 2122-4-3, L. 2122-5, L. 2122-9, L. 2131-4 of the Transport Code, and in British law in Articles 34(2)(b) and 31(2) of the Railways (Access, Management and Licensing of Railway Undertakings) Regulations 2016 (the GB Railways Regulations). 15. Ces dispositions sont reprises en substance à la fois dans l'annexe tarifaire du règlement binational qui prévoit dans son article 3 que : « [d]ans l'exercice de ses fonctions, le gestionnaire de l'infrastructure doit constamment s'assurer de la transparence et du caractère équitable et non discriminatoire des redevances » ainsi qu'en droit français, notamment aux articles L. 2122-4-3, L. 2122-5, L. 2122-9, L. 2131-4 du code des transports, et en droit britannique aux articles 34(2)(b) et 31(2) du Railways (Access, Management and Licensing of Railway Undertakings) Regulations 2016 (ci-après « GB Railways Regulations »). 16. Ainsi, l'Arafer et l'ORR se sont attachés à vérifier que le document de référence du réseau expose de façon claire et transparente l'ensemble des informations requises pour que tout candidat puisse accéder à l'infrastructure, afin d'éviter, en particulier, de placer le gestionnaire d'infrastructure dans une position lui octroyant des pouvoirs 16. Thus, Arafer and ORR have tried to check that the Network Statement clearly and transparently supplies all the information necessary for any applicant to gain access to the infrastructure, in particular for the purpose of avoiding putting the infrastructure manager in a position where it has discretionary powers which might be used to discriminate against applicants. Likewise, Arafer and ORR have aimed to make sure that charges set out in the Network Statement by the infrastructure manager are transparent, fair and non-discriminatory. discrétionnaires pouvant être utilisés de façon discriminatoire à l'égard des candidats. L'Arafer et l'ORR se sont ont également attachés à vérifier que les redevances établies par le gestionnaire de l'infrastructure sont transparentes, équitables et non discriminatoires. 17. Arafer and ORR deal with Network Statements in different ways, as is explained in the following two paragraphs. 17. Comme les deux paragraphes suivants le précisent, les modalités d'examen des documents de référence du réseau diffèrent entre l'Arafer et l'ORR. 18. In France, according to paragraph II of Article L. 2133-6 of the French Transport Code, Arafer "issues a non-binding opinion on the Network Statement within two months of its publication. The modifications which are necessary to make the provisions compatible with the law according to this opinion are made without new consultation of the parties concerned"1. 18. En France, aux termes du II de l'article L. 2133-6 du code des transports, « [l]'Autorité de régulation des activités ferroviaires et routières émet un avis motivé sur le document de référence du réseau dans un délai de deux mois suivant sa publication. Les modifications qui, au vu de cet avis, sont nécessaires pour rendre les dispositions conformes à la réglementation sont apportées sans nouvelle consultation des parties intéressées. » 19. En Grande-Bretagne, l'ORR n'est pas tenu de rendre un avis motivé sur les documents de référence du réseau comme dans le cas français. Bien que l'article 34(2) du *GB Railways Regulations* oblige l'ORR à contrôler les documents de référence du réseau, cela ne prend pas la forme d'un avis motivé. Par conséquent, l'absence d'un tel avis n'empêcherait pas la mise en œuvre du document de référence du réseau. 19. In the UK, ORR does not have to give the reasoned opinion on Network Statements which is required in France. Although regulation 34(2) of the GB Railways Regulations obliges ORR to control and check Network Statements, it does not go as far as to require a reasoned opinion. As a result, a lack of a reasoned opinion in the UK is not an obstacle to the implementation of that Network Statement. 20. ORR notes, however, regulation 13(1) of the GB Railways Regulations obliges Eurotunnel to consult all stakeholders on its Network Statement. As the economic regulator of the Channel Fixed Link, ORR is a stakeholder and thus has authority to respond to the consultation on Eurotunnel's Network Statement. ORR considers that commenting on the Network Statement in the form of a reasoned opinion prescribed by French law falls within the scope of the power granted to ORR to respond to consultations. 20. L'ORR note cependant que l'article 13(1) du *GB Railways Regulations* oblige Eurotunnel à consulter l'ensemble des parties prenantes sur son document de référence du réseau. En tant que régulateur économique de la Liaison Fixe Transmanche, l'ORR est une partie prenante et est ainsi habilité à répondre à la consultation sur le document de référence d'Eurotunnel. L'ORR considère que les commentaires sur le DRE, qui prennent la forme d'un avis motivé prévu en droit français, s'inscrivent dans le cadre du pouvoir conféré à l'ORR de répondre aux consultations. ## 1.4 Economic Context Of The Channel Fixed Link 1.4 Contexte Économique De La Liaison Fixe Transmanche 21. Clause 2.2 of the Concession Agreement defines the railway shuttle rolling stock as part of the Channel Fixed Link. Annex A.1.22 of the Concession Agreement also states that the Channel Fixed Link will enable the passage of trains from "*other railway companies*" and describes the contents of the contracts that should be concluded with these users. 21. L'article 2.2 du contrat de concession définit le matériel roulant des navettes ferroviaires comme une composante de la Liaison Fixe Transmanche. L'annexe A.1.22 du contrat de concession précise également que la Liaison Fixe transmanche permettra le passage des trains des « autres compagnies de chemin de fer » et décrit le contenu des contrats qui devraient être conclus avec ces utilisateurs. 22. In 1987, a Railway Usage Contract ("RUC") was concluded between the Concessionaires and Société Nationale des Chemins de Fer Français - SNCF and British Railway Board- BRB (the "Railways") for a period equal to the duration of the Concession (clause 24.9 of the RUC). In accordance with the provisions of the Concession Agreement, the RUC replaces the heads of terms which set out "the principles and conditions upon which the Concessionaires would permit Trains of the Railways to pass through the Fixed Link (…) and the conditions upon which the Railways would provide certain railway infrastructure" (Recital B of the RUC). The RUC refers to both freight and passenger activities of the Railways. Clause 6.2 of the RUC notably states that "the Railways shall at all times during the term of this Agreement be entitled to fifty per cent (50%) of the capacity, per Hour and in each direction, of the Fixed Link (…)". Through back to back agreements, certain rights and obligations of the "*Railways*" under the RUC were later delegated to Eurostar on the passenger side and to DB Cargo and SNCF for British and French rail freight activities, respectively. 22. En 1987, une convention d'utilisation (ci-après « RUC ») a été conclue entre les concessionnaires et la Société Nationale de Chemins de Fer Français (« SNCF ») et *British Railway Board* (« BRB ») (les « Réseaux ») pour une période égale à la durée de la concession (article 24.9 du RUC). Conformément aux stipulations du contrat de concession, le RUC rappelle « [l]es principes et conditions selon lesquels les Concessionnaires permettront aux Trains des Réseaux de circuler dans le Lien Fixe (…) et les conditions selon lesquelles les Réseaux assureront la réalisation de certaines infrastructures ferroviaires » (considérant B du RUC). Le RUC fait référence à la fois aux activités de fret et de transport de voyageurs des « *Réseaux* ». L'article 6.2 du RUC stipule notamment que « les Réseaux auront droit à tout moment pendant la durée de la présente Convention à cinquante pour cent (50 %) de la capacité du Lien Fixe, pour chaque Heure et dans chaque sens (…) ». A travers des contrats adossés au RUC, une partie des droits et obligations des Réseaux en vertu du RUC ont été délégués à Eurostar pour les services de voyageurs et à DB Cargo et SNCF pour les activités ferroviaires de fret, respectivement au Royaume-Uni et en France. 23. In summary, there are two types of activities using the Channel Fixed Link: shuttle activities, run exclusively by the Concessionaires, and railway activities in the form of passenger and freight trains. According to the RUC, 50% of the hourly capacity in each direction is reserved to the "*Railways*", initially BRB and SNCF pursuant to the RUC, and now Eurostar for passenger trains and DB Cargo and SNCF for freight activities pursuant to the back to back arrangements mentioned above. The remaining 50% of capacity remains at the disposal of the Concessionaires. 23. En résumé, deux types d'activités utilisent la Liaison Fixe Transmanche : les activités de transport par navettes, exploitées exclusivement par les concessionnaires, et les activités de transport par trains de voyageurs et de fret. Le RUC prévoit que 50 % de la capacité horaire dans chaque sens est réservée aux « *Réseaux* », initialement BRB et SNCF en vertu du RUC, et désormais Eurostar pour les trains de voyageurs et DB Cargo et SNCF pour les activités ferroviaires de fret en vertu des contrats adossés au RUC mentionnés plus haut. Les 50 % restants des capacités restent à la disposition des concessionnaires. 24. Les données relatives aux activités et aux opérateurs utilisant la Liaison Fixe Transmanche en 2015 sont présentées dans l'annexe 1 du présent avis. Faute de réponse dans les temps d'Eurotunnel aux questions qui lui ont été adressées lors de l'instruction, les données relatives à l'année 2016 n'ont pu être renseignées. Ces données illustrent les faits suivants : 24. Data on the services and operators using the Channel Fixed Link in 2015 are contained in Schedule 1 to this opinion. Without any answer from Eurotunnel in due time to questions addressed through the examination of the Network Statement, data regarding 2016 could not be included. This shows: a) There has been no new entry in the passenger or rail freight markets in recent years. For rail freight transport, the only firms that have been using the Channel Fixed Link are DB Cargo, SNCF/Captrain, and GB Railfreight as well as subsidiaries of Group Eurotunnel SE. On the passenger transport side, Eurostar remains the sole railway undertaking; a) aucun nouvel opérateur n'est entré récemment sur les marchés du transport ferroviaire de voyageurs ou de marchandises. Pour le transport ferroviaire de marchandises, les seules entreprises qui ont utilisé la Liaison Fixe Transmanche sont DB Cargo, SNCF/Captrain, GB Railfreight ainsi que des filiales du groupe Eurotunnel SE. S'agissant du transport de voyageurs, Eurostar demeure la seule entreprise ferroviaire ; b) Depuis l'année 2011, les activités de navettes et les activités b) Since 2011, the shuttle activities and the railway activities have seen contrasting annual changes. For example, when the rail freight activity showed a strong reduction in 2015 (-16.5% fewer trains than in 2014), the shuttle activities remained virtually stable (+3% more trucks transported and -0.63% fewer cars transported than in 2014). The possibility that recent events such as the terrorist attacks have had asymmetric economic impacts on the different activities cannot be excluded. ferroviaires connaissent des évolutions annuelles contrastées. A titre d'exemple, alors que l'activité de fret ferroviaire a connu une forte diminution en 2015 (-16,5% de trains par rapport à l'année 2014), l'activité de navettes a été quasiment stable (+ 3% de camions transportés et -0,63% de voitures transportées par rapport à l'année 2014). Il ne peut être exclu que des évènements récents tels que les attentats terroristes aient eu des effets économiques asymétriques sur les différentes activités. 25. Operational performance in the Channel Fixed Link is important to the business needs of stakeholders, and delays can give rise to additional costs. Stakeholders have said that they have experienced a recent increase in the number of incidents in the Channel Fixed Link. 25. La performance opérationnelle au sein de la Liaison Fixe Transmanche est importante pour les besoins commerciaux des parties prenantes et les retards peuvent générer des coûts supplémentaires. Les parties prenantes ont déclaré avoir récemment fait face à une augmentation du nombre d'incidents dans la Liaison Fixe Transmanche. ## 1.5 The New Features Of The 2018 Network Statement 1.5 Les Nouveautés Du Document De Référence De Réseau 2018 26. Eurotunnel consulted the stakeholders on a first version of the 2018 Network Statement, on 4 November 20162. The version of the 2018 Network Statement reviewed by ARAFER and ORR for the purpose of preparing and issuing this opinion was published by Eurotunnel after that consultation on 19 December 2016. 26. Le 4 novembre 2016, Eurotunnel a soumis à la consultation des parties prenantes une première version du DRE 20183. La version que l'Arafer et l'ORR ont examinée afin de préparer et d'émettre le présent avis est celle qui a été publiée par Eurotunnel le 19 décembre 2016 à l'issue de cette procédure de consultation. 27. Le DRE 2018 diffère de la version finale du Document de Référence du Réseau 2017 (ci-après « le DRE 2017 »), publiée le 24 décembre 2015, notamment sur les sujets présentés ci-après : 27. The 2018 Network Statement differs from the final version of the Fixed Link Usage Annual Statement - 2017 Working Timetable, published on 24 December 2015 (the "2017 Network Statement"), particularly in the following areas: - le glossaire inclut de nouvelles définitions des termes utilisés dans le document de référence du réseau ; - The glossary includes further definitions of terms used in the Network Statement; - il présente les différentes dispositions adoptées en France et au Royaume-Uni pour transposer la directive 2012/34/UE ; - It indicates the different measures adopted to transpose Directive 2012/34/EU in France and in the UK; - il fait référence au transfert formel des compétences de régulation économique à l'Arafer et l'ORR ; - It refers to the formal transfer of the regulatory body functions to Arafer and ORR; - il fait état de l'installation d'un nouveau système de communication GSM-R. Les trains de passagers et de marchandises doivent ainsi être équipés de la technologie GSM-R pour être autorisés à emprunter la Liaison Fixe Transmanche ; - It points out the installation of new GSM-R signaling communication system. As such, passenger and freight trains need to be equipped with the GSM-R technology in order to be authorized to run in the Channel Fixed Link; - il inclut une précision relative à la participation d'Eurotunnel au Corridor de Fret Ferroviaire Mer du Nord - Méditerranée à compter de l'horaire de service 2017 ; - It includes an explanation of Eurotunnel's participation, since the 2017 timetable, in the North Sea-Mediterranean Rail Freight Corridor; - il modifie les sections relatives aux « *prestations supplémentaires* » et aux « prestations essentielles « Open Access » du fret transmanche », en précisant que ces services ne sont pas fournis par Eurotunnel dans le périmètre de la concession ; - It modifies the sections regarding the "*ancillary services*" and the "*essential services for Open Access Cross-Channel* Freight", to make it clear that these services are not provided by Eurotunnel inside the concession area; - la valeur des redevances pour les trains de voyageurs pour 2015 présentées en annexe 4 a été mise à jour ; - The value of access charges for passenger trains for 2015 included in Annex 4 have been updated; - The table in Annex 4 titled "Inflation forecasts for the indexation of Access Fees from 2015 prices (Offers 1, 2 & 3)" has been updated to revise forecasts for 2016 and 2017. In addition the table now includes the forecasts for 2018 and actual values for January 2016; - le tableau de l'annexe 4 intitulé « Prévisions d'inflation pour l'indexation des Droits de circulation à partir des valeurs 2015 (Offres 1, 2 et 3) » a été mis à jour s'agissant des prévisions pour les années 2016 et 2017. En outre, le tableau renseigne désormais les prévisions relatives à l'année 2018 et les valeurs constatées pour le mois de janvier 2016 ; - la section relative au système d'amélioration des performances comprend désormais quelques références aux principes - The performance regime section now includes some references to the basic principles of the performance scheme laid down in Directive 2012/34/EU; fondamentaux du système d'amélioration de performance prévus par la directive 2012/34/UE ; - Annex 3, presenting freight train charges, now specifies the reference year of the billing units; - l'annexe 3, dédiée à la présentation des redevances des trains de marchandises, précise dorénavant l'année de référence des unités de facturation ; - "Offer 1" for freight trains now includes a sentence explaining the reason why this offer does not include a specific charge for administration costs. For the other "Offers" 2, 3 and 4 the Network Statement explains the specific situations for which the administration charge would be applied; and - l' « *Offre* 1 » pour les trains de marchandises apporte désormais une précision sur la raison pour laquelle cette offre n'inclut pas de frais de dossier. Pour les « *Offres* » 2, 3 et 4, le DRE précise les situations spécifiques pour lesquelles ces frais de dossiers seront appliqués ; - The table in Annex 4 titled "Visibility over five years on reservation fees per train in 2015 prices (Offer 1)" has been supplemented with an explanatory note indicating that indexation can be derived by simply pro-rating the change from "Offer 1" to all the other Offers. Furthermore, another note was included concerning the link between RUC charges and Network Statement charges, as well as the indexation applied to each charge. - le tableau de l'annexe 4 intitulé « Visibilité sur 5 ans des Droits de Réservation par Train en valeur 2015 (Offre 1) » inclut désormais une précision qui indique que l'évolution des droits de réservation appliquée aux autres offres peut être déduite par « *simple pro-rata* » à partir de l' « *Offre* 1 ». En outre, d'autres précisions ont été ajoutées concernant le lien entre la tarification prévue par le RUC et les redevances du DRE ainsi que l'indexation appliquée à chacune des redevances. ## 2. Analysis 2. Analyse 28. Having regard to the economic context presented in section 1.4, and to the provisions of Articles 56(2) and 56(6) of the Directive, Arafer and ORR conclude that it is their duty to ensure that the charges and access conditions set out in the infrastructure manager's Network Statement are sufficiently clear, non-discriminatory and offer the required predictability for new operators to enter the market and design a business plan. 28. Compte tenu du contexte économique présenté en section 1.4, et en application des dispositions des articles 56(2) et 56(6) de la Directive, l'Arafer et l'ORR estiment qu'ils sont tenus de veiller à ce que les redevances et les conditions d'accès présentés dans le document de référence de réseau du gestionnaire d'infrastructure soient suffisamment claires, nondiscriminatoires et offrent la prévisibilité dont les acteurs ont besoin pour entrer sur le marché et élaborer leur plan d'affaires. 29. The following subsection (2.1) is therefore dedicated to observations on the charges and access conditions for the Channel Tunnel. Moreover, given the issues of performance raised by the stakeholders, Arafer and ORR will also ensure that the infrastructure manager has an appropriate performance scheme in place. A second subsection (2.2.) is thus dedicated to observations on operational performance and the performance scheme. 29. La sous-section (2.1) suivante est donc dédiée aux observations sur les redevances et les conditions d'accès à la Liaison Fixe Transmanche. En outre, du fait des problèmes de performance auxquels les parties prenantes disent avoir été confrontées, l'Arafer et l'ORR considèrent qu'elles doivent veiller à ce que le gestionnaire d'infrastructure mette en place un régime de performance adéquat. Une deuxième sous-section (2.2) est ainsi dédiée aux observations relatives à la performance opérationnelle et au système d'amélioration de performance. ## 2.1 Charges And Access Conditions 2.1 Redevances Et Conditions D'Accès 2.1.1 Observations On Access Conditions 2.1.1 Observations Relatives Aux Conditions D'Accès 30. Several network access conditions should be more clearly presented in the 2018 Network Statement in order to provide a higher level of transparency for new entrants. In particular, three topics should be presented with more clarity: 30. Certaines conditions de l'accès au réseau devraient être présentées plus clairement dans le DRE 2018 afin d'accroître le niveau de transparence pour les nouveaux entrants. Trois d'entre elles devraient, en particulier, faire l'objet de clarifications : a) les conditions contractuelles qui seront proposées aux nouveaux a) the contractual conditions that will be offered to new entrants and their repercussions on existing users of the Channel Fixed Link; entrants et leurs répercussions sur les utilisateurs existants de la Liaison Fixe Transmanche ; b) the mechanisms for allocation of capacity; b) les mécanismes d'allocation des capacités ; c) the scheduling and coordination process. c) la procédure de programmation et de coordination. ## The Contractual Conditions Offered To New Entrants Les Conditions Contractuelles Offertes Aux Nouveaux Entrants 31. First, Eurotunnel should provide additional information in the 2018 Network Statement on the contractual conditions that will be offered to new entrants and their impact on actual users of the infrastructure. Indeed, considering the existing contracts and the fact that the Concession Agreement provides that users of the Channel Fixed Link should be offered a contract, it is of the utmost importance that current and prospective users of the Channel Fixed Link are able to understand the contractual terms and conditions that will prevail following the entry of new operators in the market. Therefore, the 2018 Network Statement should indicate: 31. En premier lieu, Eurotunnel devrait apporter plus d'informations dans le DRE 2018 sur les conditions contractuelles qui seront proposées aux nouveaux entrants et leurs implications pour les utilisateurs actuels de l'infrastructure. En effet, eu égard aux contrats existants et au fait que le contrat de concession prévoie que les utilisateurs de la Liaison Fixe Transmanche devraient se voir offrir un contrat, il est primordial que les utilisateurs actuels et potentiels de la Liaison Fixe Transmanche soient en mesure de comprendre les conditions et les termes contractuels qui prévaudront suite à l'arrivée de nouveaux opérateurs sur le marché. Aussi le DRE 2018 devrait-il indiquer : a) The conditions that would most likely be proposed by Eurotunnel; a) les conditions qui seraient susceptibles d'être offertes par b) If, in the event of a new entry into the passenger rail transport Eurotunnel ; market, the existing contracts would be amended and by what process. b) si, en cas de nouvelle entrée sur le marché du transport ferroviaire de voyageurs, les contrats existants seraient modifiés et suivant quelles modalités. ## The Allocation Of Capacity L'Allocation Des Capacités 32. Second, the 2018 Network Statement should be supplemented with additional information on the allocation of capacity of the Channel Fixed Link. Indeed, in order to design their business plan, actual and prospective future users require knowledge of the availability of capacity in the Channel Fixed Link, with particular regard to the capacity that will be offered to new entrants. To fulfil this requirement, the 2018 Network Statement should at least indicate : 32. En deuxième lieu, le DRE 2018 devrait être complété d'informations supplémentaires relatives à l'allocation des capacités de la Liaison Fixe Transmanche. En effet, pour l'élaboration de leur plan d'affaires, les utilisateurs existants et les nouveaux entrants potentiels ont besoin de connaître la disponibilité des capacités de la Liaison Fixe Transmanche s'agissant, en particulier, des capacités offertes aux nouveaux entrants. Pour satisfaire cette exigence, le document de référence du réseau 2018 devrait a minima indiquer : a) sur quelle part des capacités de la Liaison Fixe Transmanche a) From which part of the Channel Fixed Link capacity the paths for new entrants in the freight and passenger activities would be obtained; Whether this capacity would be obtained from the capacity reserved under the RUC for the "Railways" (50%), or from the remaining capacity (50%) and from which part of the Channel Fixed Link's existing capacity are taken the paths used by maintenance work; seraient prélevés les sillons des nouveaux entrants pour les activités fret et voyageurs ; si ces capacités proviendraient des capacités réservées par le RUC aux « *Réseaux* » (50%) ou des capacités restantes (50%) et sur quelle part des capacités existantes de la Liaison Fixe Transmanche sont prélevés les sillons utilisés pour les travaux de maintenance ; b) How many paths are offered for passenger and freight rail services during the different time periods (i.e peak period, off-peak period and intermediate period); b) combien de sillons sont offerts aux activités ferroviaires de fret et de voyageurs pour chacune des périodes horaires (*i.e.* période de pointe, période creuse et période intermédiaire) ; c) compte tenu des taux d'utilisation antérieurs de la Liaison Fixe c) Based on the prior utilisation rate of the Channel Fixed Link by current services and maintenance work, the approximate share of these paths that is available for new rail services during these different time periods. Transmanche par les services existants et les travaux de maintenance, la part approximative de ces sillons disponible pour de nouveaux services ferroviaires pendant ces différentes périodes horaires. ## The Scheduling And Coordination Process La Procédure De Programmation Et De Coordination 33. Third, in section 4.3.2 of the 2018 Network Statement, Eurotunnel presents a list of a "*decreasing order of priority*" to be applied "in the process of coordinating capacity requests from applicants, during the resolution of conflicts between competing requests for the same capacities, or in potential future situations of congestion". However, Arafer and ORR emphasise that, according to the provisions laid down in article 45 of the Directive, the infrastructure manager is only allowed to give priority to specific services within the scheduling and coordination process in the situations set out in article 47 for congested infrastructure or 49 for specialised infrastructure. 33. Troisièmement, dans la section 4.3.2 du document de référence du réseau 2018, Eurotunnel présente, par « *ordre décroissant de priorité* », une liste de critères à appliquer « dans le cadre du processus de coordination de demandes de capacité des candidats, et durant la résolution de conflits entre demandes concurrentes pour les mêmes capacités, ou dans l'éventualité de futures situations de saturation». Cependant, conformément aux dispositions de l'article 45 de la directive, le gestionnaire de l'infrastructure n'est autorisé, dans le cadre de la procédure de programmation et de coordination, à accorder la priorité à certains services que dans les cas visés aux articles 47 relatif aux infrastructures saturées et 49 relatif aux infrastructures spécialisées 34. The 2018 Network Statement should therefore be amended to clarify the procedure used for competing applications, with particular regard to the possible effects of the commitments made by Eurotunnel under the RUC. 34. Le DRE 2018 devrait donc être modifié pour clarifier la procédure applicable en cas de demandes concurrentes, notamment au regard des effets éventuels des engagements pris par Eurotunnel au titre du RUC. 35. In general, Eurotunnel should justify the criteria currently defined in the 2018 Network Statement with respect to the principles set out in Articles 39, 45 and 46 of the Directive, to ensure that infrastructure capacity is allocated in a fair and non-discriminatory manner. 35. De façon générale, Eurotunnel devrait justifier l'ensemble des critères définis dans le document de référence du réseau 2018 s'agissant du respect des principes fixés par les articles 39, 45 et 46 de la directive, afin d'assurer que la capacité de l'infrastructure est allouée de façon équitable et non discriminatoire. ## 2.1.2 Observations On Charges 2.1.2 Observations Relatives À La Tarification 36. Dans cette section, l'Arafer et l'ORR présentent leurs observations sur la section 6 du DRE 2018 relative à la tarification. 36. In this section, Arafer and ORR comment on section 6 of Eurotunnel's 2018 Network Statement dedicated to charges. 37. In general, they have checked that it clearly and transparently provides all the information necessary for any applicant to access the Channel Fixed Link in a fair and non-discriminatory manner. As required by Article 56(2) and 56(6) of the Directive, Arafer and ORR have sought to check whether the Network Statement contains discriminatory clauses or creates discretionary powers for the infrastructure manager that may be used to discriminate against applicants. Arafer and ORR have also checked whether the charges set by the infrastructure manager are non-discriminatory and comply with Section 2 of Chapter IV of the Directive on the rules and principles on Infrastructure and services charges. 37. De façon générale, ils se sont attachés à vérifier que le DRE 2018 présente de manière claire et transparente l'ensemble des informations nécessaires pour que tout candidat puisse accéder à la Liaison Fixe Transmanche dans des conditions équitables et non-discriminatoires. Comme les articles 56(2) et 56(6) de la Directive le prévoient, l'Arafer et l'ORR ont cherché à vérifier que le document de référence du réseau ne comporte pas de clauses discriminatoires ou n'octroie pas au gestionnaire d'infrastructure des pouvoirs discrétionnaires pouvant être utilisés à des fins de discrimination à l'égard des candidats. L'Arafer et l'ORR se sont également attachés à vérifier que les redevances fixées par le gestionnaire de l'infrastructure ne sont pas discriminatoires et qu'elles sont conformes aux les règles et principes de tarification de l'infrastructure et des services définis dans la section 2 du chapitre VI de la directive. 38. Their comments are organized according to the following themes: 38. Leurs commentaires sont organisés autour des thématiques suivantes : a) The structure and development of access charges (the access charges offers, the relationship between charges and costs and the indexation of charges); b) The ETICA scheme4. a) la structure et l'évolution des redevances d'accès (les modulations appliquées aux redevances, la relation entre les redevances et les coûts et l'indexation des redevances) ; b) l'initiative ETICA5. ## A. The Structure And Development Of Access Charges A. La Structure Et L'Évolution Des Redevances D'Accès Adjustments applied to access charges Les modulations appliquées aux redevances d'accès 39. In general, Arafer and ORR's view is that the presentation and transparency of the applicable charging principles, as well as that of the resulting charges for the use of the infrastructure should be improved. Arafer and ORR note also that section 6.1.2 of the 2018 Network Statement states that the "charging principle of long term costs recovery through access charges underpins the economic model for private funding of the Fixed Link. The applicability of this principle to the Channel Fixed Link has been validated6 by the European Commission and by the IGC, and its application within the charging structure of the Usage Contract has been demonstrated to the IGC-JEC" (). This paragraph should be removed as it is neither for the European Commission nor the IGC to validate Eurotunnel's charging model. 39. De manière générale, l'Arafer et l'ORR estiment que la présentation et la transparence des principes de tarification applicables et leur déclinaison en redevances d'utilisation de l'infrastructure devraient être améliorées. L'Arafer et l'ORR notent également que la section 6.1.2 du DRE 2018 précise que « le principe de tarification de recouvrement des coûts à long terme à travers les péages est le fondement du modèle économique de financement privé du Lien Fixe. L'applicabilité de ce principe au Lien Fixe Transmanche a été validé7 par la Commission Européenne et par la CIG, et son application dans la tarification de la Convention d'Utilisation a été démontrée au CBE- CIG ». Cette mention doit être supprimée du fait qu'il n'est aujourd'hui pas du ressort de la Commission Européenne ou de la CIG de valider le modèle de tarification d'Eurotunnel. 40. The relationship between Eurotunnel's proposed charge structure and its actual and forecast costs lacks transparency. In particular Eurotunnel does not identify the costs directly incurred. Furthermore, Arafer and ORR 40. La relation entre la structure tarifaire proposée par Eurotunnel et ses coûts réels et prévisionnels manque de transparence. Eurotunnel n'identifie pas, en particulier, les coûts directement imputables. L'Arafer et l'ORR understand that Eurotunnel's current charges to Eurostar (the only rail passenger operator) are actually based on the RUC not the Network Statement and it is not demonstrated how the charges in the RUC are consistent with those in the Network Statement. The table in Annex 4 is a useful step in trying to provide the reconciliation between the RUC charges and the charges defined in the Network Statement but it should be more clearly explained. Moreover, there is no explanation for stakeholders of the method used to convert the charges in the RUC to the charging scales provided in the network statement. comprennent en outre que les redevances actuellement facturées à Eurostar (seul opérateur de transport ferroviaire de passagers) sont en réalité fondées sur le RUC et non sur le document de référence du réseau. Or, la cohérence entre la tarification prévue par le RUC et celle qui est définie par le document de référence du réseau n'est pas établie. Le tableau figurant en Annexe 4 constitue une avancée notable pour tenter de réconcilier la tarification prévue par le RUC et celle qui est définie dans le cadre du document de référence du réseau. Pour autant, aucune explication n'est fournie pour permettre aux parties prenantes de comprendre la façon dont la conversion de la tarification du RUC en barème de redevance dans le document de référence est réalisée. 41. Annexes 3 and 4 of the Network Statement set out charging scales for freight and passenger services, with a separate table for each of the corresponding offers. Arafer and ORR think that an additional table presenting the access and reservation fees of all offers should be included to allow stakeholders to compare the different offers more easily. 41. Les annexes 3 et 4 du document de référence du réseau présentent les barèmes de tarification pour les trains de passagers et de fret. Chacune des offres correspondantes fait l'objet d'une présentation dans un tableau distinct. L'Arafer et l'ORR estiment qu'un tableau supplémentaire détaillant les droits d'accès et de réservation de toutes les offres devrait être inclus pour permettre aux parties prenantes de comparer plus aisément les différentes offres. 42. Le barème de tarification applicable aux trains de fret et de passagers prévoit quatre « *Offres* » distinctes, pour lesquelles les redevances font l'objet de modulations en fonctions des trois paramètres suivants : 42. The scale of charges payable by freight trains and passenger trains consists of four separate "Offers", for which the charge levels are subject to adjustments according to the following three criteria: a) la régularité d'utilisation des sillons ; a) regularity of use of train paths; b) le délai entre la date de réservation et la date d'utilisation du sillon ; b) time between date of reservation and date of use of train path; c) type of service (traffic described as "*empty passenger trains*" or c) le type de service (circulation dites « *rames voyageurs à vide* » ou «*haut-le-pied* », par opposition aux circulations commerciales). "*light-running*" in contrast to commercial traffic). 43. Arafer and ORR think that Eurotunnel should provide better justification for these adjustments, with regard to the requirements of the Directive, and in particular with the charging principles and the corresponding exceptions to those principles laid down in Articles 31 and 32 of the Directive, respectively. 43. L'Arafer et l'ORR estiment qu'Eurotunnel devrait mieux justifier ces modulations au regard des dispositions de la directive, en particulier en ce qui concerne les principes tarifaires et les exceptions à ces principes définis respectivement aux articles 31 et 32 de la directive. 44. On this subject, Arafer and ORR noted in their recommendations regarding the 2017 Network Statement that sections 6.2 and 6.3 included an additional comment to explain that the breakdown of the proposed charges scales into four separate offers was based on Article 26 of Directive 2012/34/EU. A sentence has been added to the 2018 Network Statement explaining that the four separate offers are "open to all Railway Undertakings without discrimination" and are "based on objective criteria […] allowing to promote effective use of capacity (2012/34/EU art.26)". 44. Sur ce point, l'Arafer et l'ORR avaient relevé, dans leurs recommandations relatives au DRE 2017, que les sections 6.2 et 6.3 incluaient un commentaire supplémentaire pour préciser que le découpage du barème proposé en quatre offres distinctes était fondé sur l'article 26 de la directive. Une précision a été ajoutée au DRE 2018 pour indiquer que les quatre offres distinctes sont « ouvertes à toutes entreprise ferroviaire sans discrimination » et qu'elles sont fondées sur « *des critères objectifs* […] permettant ainsi de promouvoir l'utilisation efficace des capacités (article 26 de la directive 2012/34/UE) ». 45. Cette tentative de démonstration de la conformité de la tarification par référence à l'article 26 de la directive n'est pas suffisante. La référence à ces dispositions n'exonère pas le gestionnaire d'infrastructure de l'obligation de fixer des redevances conformes aux principes de tarification fixés par les articles 31 et 32 de la directive et de le démontrer dans le DRE 2018. 45. This attempt to demonstrate compliance by quoting Article 26 of the Directive is insufficient. A reference to Article 26 does not override the requirement that charges should comply with the charging principles laid down in Articles 31 and 32 of the Directive and that the 2018 Network Statement should demonstrate how they do so. 46. Furthermore, Arafer and ORR note that the structure and level of adjustments of charges differ between freight trains and passenger trains. For instance, the definition of peak periods is different for freight and passenger trains (*i.e.* the peak period extends from 17h to 22h in the evening for freight trains whereas for passenger trains the peak period during the evening is between 17h and 23h). Moreover, as Arafer and ORR pointed out in their recommendations on the 2017 Network Statement, the fees for reservation and access paid by freight trains are adjusted according to the timetabled period of use of the infrastructure and the speed of travel during "*off-peak periods*". The charges applicable to passenger trains differ in this aspect, as only the reservation fee is variable according to the timetable period of traffic. 46. Par ailleurs, l'Arafer et l'ORR relèvent que la structure des modulations des redevances diffère entre les trains de voyageurs et les trains de marchandises. A titre d'exemple, la définition des heures de pointe varie entre les trains de fret et de voyageurs (*i.e.* la période de pointe du soir s'étend de 17 heures à 22 heures pour les trains de marchandises alors que pour les trains de voyageurs cette période court de 17 heures et 23 heures). En outre, comme l'Arafer et l'ORR l'ont souligné dans leurs recommandations sur le DRE 2017, le droit de réservation et le droit de circulation applicables aux trains de marchandises sont modulés en fonction de la période d'utilisation de l'infrastructure et de la vitesse de circulation en « période creuse ». La tarification applicable aux trains de voyageurs diffère sur ce point, seul le droit de réservation étant modulé en fonction de la période horaire de circulation. 47. Likewise, Arafer and ORR observe that the level of adjustment of charges applied differs between freight and passenger trains. For example, the reservation fee and access fee paid by freight trains reserved under "Offer 2" (individual trains) and running during "off-peak periods" are 41% higher than charges paid by freight trains reserved under "Offer 1" (weekly trains) and running during the same period. By comparison, the percentage change between "Offer 1" and Offer 2" is only of 10% for passenger trains running during the same time period. In general, Arafer and ORR note that for freight trains, the variation of charges between the different time periods is heterogeneous amongst the offers, while it is homogeneous for passenger trains. Eurotunnel should justify how the structure and levels of adjustments of charges applied for freight and passenger activities are consistent with the charging principles laid down in the Directive. It should include an explanation of the purposes of these adjustments and their consistency with the charging principles of the Directive in order to increase transparency and clarify the economic signals of the charging system. 47. De même, l'Arafer et l'ORR constatent que le niveau des modulations appliquées diffère entre les trains de passagers et les trains de fret. En période creuse par exemple, le droit de réservation et le droit de circulation facturés aux trains de fret est 41 % plus élevé pour l'« *Offre 2* » (trains individuels réservés) que pour l'« *Offre 1* » (trains hebdomadaires réservés), alors que, pour les trains de passagers, la différence tarifaire entre ces deux Offres ne s'élève qu'à 10% pour la même période horaire. De manière générale, l'Arafer et l'ORR relèvent que, pour les trains de fret, la variation des redevances entre les différentes périodes horaires est hétérogène entre les « *Offres* » alors qu'elle est homogène pour les trains de passagers. Eurotunnel devrait justifier de la conformité de la structure et du niveau des modulations appliquées aux trains de passagers et de fret avec les principes tarifaires posés par la directive. Il devrait préciser les objectifs visés par ces modulations et la conformité avec les principes définis par la directive afin d'accroître la transparence et de clarifier les signaux économiques associés au système de tarification. 48. On this subject, Arafer and ORR also note that the 2018 Network Statement explains in section 6.1.2, regarding the rules and implementation of the European Union legislation charging principles, that the "charges published in the Fixed Link Usage Annual Statement have been designed to provide fair and non-discriminatory open access reflecting the charging framework of the Usage Contract, entirely based upon the long term costs of the Fixed Link, in accordance with EC Directive 2012/34 (Art. 8.4 & 32.3) and with the Fixed Link Concession Agreement". 48. A ce sujet, l'Arafer et l'ORR constatent également que, dans sa section 6.1.2 relative à la règlementation et l'application des principes de tarification du droit communautaire, le DRE 2018 précise que « les tarifs publiés dans le Document de Référence Annuel pour l'Utilisation du Lien Fixe ont été conçus de manière à fournir un accès libéralisé équitable et non-discriminatoire reflétant le cadre de la tarification de la Convention d'Utilisation, entièrement fondé sur les coûts à long terme de la Liaison Fixe, conformément à la Directive 2012/34/UE (Art. 8.4 & 32.3) et à la Concession de la Liaison Fixe Transmanche ». 49. Arafer and ORR emphasise that Article 32(3), which Eurotunnel uses as a reference to justify is charging scale, does not exempt the charging framework from being compliant with other Articles in the Directive which underline the necessity of designing a charging system that does not create undue discrimination against applicants. This is the case with Articles 29(3), 32(5) and 56(2) of the Directive. 49. L'Arafer et l'ORR soulignent que l'article 32.3 de la directive 2012/34/UE, auquel Eurotunnel fait référence pour justifier son barème tarifaire, n'exempte pas de la conformité à d'autres dispositions de la directive, notamment ses articles 29(3), 32(5) et 56(2), qui imposent, en particulier, que le dispositif de tarification n'emporte pas de risque discrimination à l'égard des candidats. 50. In particular, Article 32(5) of the Directive states that Member States shall ensure that comparable services in the same market segment are subject to the same charges in order to ensure that the charging system does not create undue discrimination. Thus, Eurotunnel should demonstrate how the Network Statement complies with this provision of the directive. 50. L'article 32(5) de la directive prévoit, en particulier, que les Etats Membres veillent à ce que des services comparables fournis dans le même segment de marché soient soumis aux mêmes redevances afin d'assurer que le cadre tarifaire ne crée pas de discrimination. Ainsi, Eurotunnel devrait démontrer la conformité du document de référence du réseau avec cette disposition de la directive. 51. L'Arafer et l'ORR s'interrogent sur la référence à l'article 8(4) de la directive présentée dans la section 6.1.2 relative à la règlementation et à l'application des principes de tarification du droit communautaire. En effet, cet article, relatif au « financement du gestionnaire de l'infrastructure », n'exempte pas le cadre tarifaire d'une conformité aux articles 31 et 32 de la directive. 51. Arafer and ORR question the reference to Article 8(4) of the Directive presented in section 6.1.2 regarding the rules and implementation of the European Union legislation charging principles. Indeed, this article, which relates to the "*financing of the infrastructure manager*", does not exempt the charging framework from being compliant with Articles 31 and 32 of Directive. ## Supplementary Charges In The Event Of Technical Breakdown Les Frais Supplémentaires En Cas De Panne Technique 52. Arafer and ORR noted in their recommendations on the 2017 Network Statement that the charging regime for freight transport allowed an increase in the access fee "in the event of breakdown of a rail freight train in the Channel Fixed Link involving a prolonged stationary period, in particular for recurring failures". 52. Dans leurs recommandations relatives au DRE 2017, l'Arafer et l'ORR ont relevé que le cadre tarifaire pour les trains de fret prévoyait que des frais supplémentaires soient appliqués au droit de circulation « en cas de panne technique d'un train de marchandises dans le Lien Fixe Transmanche avec une durée d'immobilisation prolongée, notamment pour les défaillances récurrentes ». 53. On this subject, Arafer and ORR commented that "Eurotunnel should specify how far this increment conforms to the principles of Directive 2012/34/EU, and to present the method followed to work out this increment"8 . 53. Sur ce point, l'Arafer et l'ORR avaient demandé à Eurotunnel de « préciser dans quelle mesure cette majoration est conforme aux principes de la directive ainsi que de présenter la méthode utilisée pour déterminer cette majoration »9. 54. In section 6.2, the 2018 Network Statement now refers to section 7.2 and paragraph E of Annex 3 which provides additional explanations on the imposition of additional charges in the event of the breakdown of a rail freight train. Section 7.2 of the 2018 Network Statement presents the "*penalties for performance incidents comprised within the charging regime*". It explains that "where a Railway Undertaking operating a rail freight train or a passenger train experiences a technical fault or operational incident leading to a stoppage in the Channel Fixed Link exceeding 15 minutes […] the Railway undertaking will be liable for the additional charges specified in paragraph E of Annex 3 (freight trains) or Annex 4 (passenger trains)". 54. En sa section 6.2, le DRE 2018 fait désormais référence à la section 7.2 et au paragraphe E de l'annexe tarifaire 3, lesquelles apportent des informations additionnelles relatives aux frais supplémentaires appliqués en cas de panne technique d'un train de marchandises. La section 7.2 du DRE 2018 présente les « pénalités pour perturbation de performance comprises dans le système de tarification ». Elle précise que « lorsqu'une entreprise ferroviaire exploitant un train de marchandises ou de voyageurs connaît une défaillance technique ou incident opérationnel conduisant à une immobilisation dans le Lien Fixe Transmanche dépassant 15 minutes […] l'entreprise ferroviaire sera exposée aux charges supplémentaires définies au paragraphe E de l'Annexe 3 (trains de marchandises) ou de l'Annexe 4 (trains de voyageurs) ». 55. Paragraph E of Annex 3 details the access charge that a freight train should pay in the event of a technical breakdown involving a stationary period exceeding 15 minutes. Arafer and ORR understand from Eurotunnel's responses to their recommendations on the 2017 Network Statement that this additional charge is intended to be an economic signal to encourage the use of reliable equipment. 55. Le paragraphe E de l'annexe 3 détaille le droit de réservation à acquitter par un train de fret en cas de panne technique entraînant une durée d'immobilisation supérieure à 15 minutes. L'Arafer et l'ORR comprennent, d'après les réponses d'Eurotunnel à leurs recommandations sur le DRE 2017, que ces frais supplémentaires visent à constituer un signal économique incitatif à l'utilisation d'un matériel fiable. 56. Arafer and ORR note that passenger trains are also subject to a supplementary charge in the event of technical failure in the Channel Fixed Link, as specified in paragraph E of Annex 4. This charge is to be paid for the shunting service provided by Eurotunnel and, according to Eurotunnel, it amounts to 7500 euros per rescued train. Unlike the charge applied to freight trains, the charge paid by passenger trains does not seem to be based on a clear threshold set out in the Network Statement. Furthermore, section 6.3 of the 2018 Network Statement containing the rules of the charging regime for passenger transport does not include any information presenting this supplementary charge, as is included for freight trains in section 6.2 of the 2018 Network Statement. 56. L'Arafer et l'ORR constatent que les trains de passagers sont également soumis à des frais supplémentaires en cas de panne technique dans la Liaison Fixe Transmanche, comme cela est précisé dans le paragraphe E de l'Annexe 4. Ce montant, qui s'élève à 7 500 euros par train secouru, correspond, d'après Eurotunnel, à la contrepartie du service de manœuvre qu'il fournit. A la différence des trains de fret, l'application de ces frais pour les trains de voyageurs semble ne pas dépendre d'un seuil minimal fixé dans le document de référence du réseau. En outre, la section 6.3 du DRE 2018 relative aux règles du système de tarification applicable au transport de voyageurs ne fait pas mention de ces frais supplémentaires, alors que la section 6.2 du DRE 2018 l'inclut pour les trains de fret. 57. In order to improve transparency and provide equal access conditions to railway undertakings, the 2018 Network Statement should present the information regarding supplementary charges in the event of technical breakdown in a similar way, for both passenger and freight trains. 57. Afin d'accroître la transparence et d'offrir des conditions d'accès équitables aux entreprises ferroviaires, le DRE 2018 devrait présenter les informations relatives aux frais supplémentaires applicables en cas de panne technique de manière homogène pour les trains de fret et les trains de passagers. 58. En outre, afin d'améliorer la transparence et de clarifier les signaux économiques associés au cadre tarifaire et au système d'amélioration des performances, le DRE 2018 devrait distinguer clairement les redevances d'accès des paiements associés au système d'amélioration des 58. Moreover, in order to increase transparency and clarify the economic signals of the charging system and the performance scheme, the 2018 Network Statement should clearly distinguish between infrastructure charges and the charges relating to the performance scheme, such as the penalties for technical breakdown in the Channel Fixed Link. performances, tels que les frais/pénalités en cas de panne technique dans la Liaison Fixe Transmanche. ## Supplementary Charges In The Event Of Delay Of Trains Les Frais Supplémentaires En Cas De Retard Des Trains 59. Arafer and ORR noted in their recommendations on the 2017 Network Statement that the charging scheme applied to freight trains and presented in Annex 3 allowed Eurotunnel to apply higher charges in case of delay. Indeed, "in the case of trains running late or early compared with their reserved time period, the charge for the reserved train path will apply up to a limit of 10% of the annual movements of this train (excluding delays caused by external IMs). Beyond this threshold, the charges of Offer 3 will apply". 59. Dans leurs recommandations relatives au DRE 2017, l'Arafer et l'ORR ont relevé que le cadre tarifaire appliqué aux trains de marchandises et présenté dans l'Annexe 3 permettait à Eurotunnel d'appliquer des frais supplémentaires en cas de retard. En effet, « pour les trains circulant en retard ou en avance par rapport à la période horaire réservée, le prix applicable est celui du sillon réservé dans la limite de 10% des circulations annuelles de ce train (hors retards causés par GI externes), ou celui de l'Offre 3 au-delà de ce seuil ». 60. Arafer and ORR understand from Eurotunnel's responses to their recommendations on the 2017 Network Statement that this charge is intended to be a deterrent within the charging system against improper planning and usage practices. 60. L'Arafer et l'ORR comprennent, d'après les réponses d'Eurotunnel à leurs recommandations relatives au DRE 2017, que cette redevance vise, au sein du système tarifaire, à dissuader le recours à des pratiques inappropriées de planification et d'utilisation des sillons. 61. Arafer and ORR consider that any price signal which aims to "[…] encourage railway undertakings and the infrastructure manager to minimize disruption and improve the performance of the railway network […]" in accordance with Article 35 of the Directive should be shown clearly in the performance scheme. The higher charges for freight trains should thus be justified by Eurotunnel with regard to this requirement. 61. L'Arafer et l'ORR estiment que tout signal prix visant, conformément à l'article 35 de la directive, à « *encourage*[r] les entreprises ferroviaires et les gestionnaires de l'infrastructure à réduire au minimum les défaillances et à améliorer les performances du réseau ferroviaire […] », devrait être clairement identifié au sein du système d'amélioration des performances. Les frais supplémentaires appliqués aux trains de fret devraient ainsi être justifiés par Eurotunnel au regard de cette disposition. ## Administration Charges Les Frais De Dossier 62. In their recommendations on the 2017 Network Statement, Arafer and ORR pointed out that "Offer 1" for freight trains does not include a specific charge for administration costs contrary to the other "Offers". 62. Dans leurs recommandations relatives au DRE 2017, l'Arafer et l'ORR ont mis en avant que l'« *Offre* 1 » pour les trains de fret n'incluait pas de frais de dossier spécifiques, contrairement aux autres « *Offres* ». 63. Arafer and ORR note that in the 2018 Network Statement Eurotunnel has changed Annex 3 to explain why the administration charge is not applied to "Offer 1". That explanation helps to increase transparency and the stakeholders' understanding of charges. 63. L'Arafer et l'ORR constatent qu'Eurotunnel a modifié l'annexe 3 du DRE 2018, qui précise désormais les raisons pour lesquelles les frais de dossier ne s'appliquent pas pour l'« *Offre 1* ». Cette explication contribue à accroître la transparence et la compréhension des redevances par les parties prenantes. 64. The 2018 Network Statement specifies that the administration fee "is not applied in the event of a simple request for pre-established paths, which is indeed the case for the reserved weekly paths", reserved through "Offer 1". 64. Le DRE 2018 précise que les frais de dossier « ne sont pas appliqués dans le cas d'une demande simple de sillons préétablis, ce qui est précisément le cas pour les sillons hebdomadaires réservés », qui sont réservés en utilisant « l'Offre 1 ». 65. However, freight train paths reserved under "Offers" 2, 3 and 4 pay 7500 euros per contract. It is now specified that "this charge is not applied in the event of a simple request for pre-established paths, within the limit of one order per month and per operator - this charge applies to special paths outside the pre-established catalogue, and to repetitive requests". Arafer and ORR think that this explanation would benefit from clarification in order to improve transparency. 65. Les montants à acquitter par les trains de fret réservés en utilisant les « *Offres* » 2, 3 et 4 s'élèvent en revanche à 7 500 euros par contrat. Il est désormais précisé que « ces frais ne sont pas appliqués dans le cas d'une demande simple de sillons préétablis, dans la limite d'une commande par mois et par opérateur - ces frais s'appliquent aux sillons spéciaux hors catalogue de sillons préétablis, et aux demandes répétitives ». L'Arafer et l'ORR estiment que cette précision mériterait d'être clarifiée afin d'améliorer la transparence. 66. Eurotunnel should also provide more detailed justification of the compliance of those administration charges with the charging principles laid down in the Directive. 66. Eurotunnel devrait également justifier de manière plus détaillée la conformité de ces frais de dossier avec les principes de tarification posés par la directive. 67. Moreover, Eurotunnel should explain why passenger trains have to pay administration charges for all "Offers", even in the case of pre-established paths which applies to paths being reserved under "Offer 1". 67. De plus, Eurotunnel devrait expliquer les raisons pour lesquelles les trains de voyageurs doivent s'acquitter de frais de dossier pour toutes les « Offres », même dans le cas de sillons préétablis réservés sous l'« Offre 1 ». 68. Dans l'annexe 4 du DRE 2018, Eurotunnel précise qu'il « pourra renoncer à l'application des frais de dossier de contrat Offre 1 lorsque l'EF maintient des systèmes de documentation particulièrement fiables et efficaces afin de faciliter l'audit des unités de trafic, permettant de minimiser la charge administrative d'Eurotunnel dans la mise en œuvre de ses besoins de vérification à son entière satisfaction ». 68. Eurotunnel explains in Annex 4 of the 2018 Network Statement, that it "may [renounce] to apply the administration charge for Offer 1 contracts where the Railway Undertaking maintains a documentation system particularly reliable and efficient in order to facilitate the audit of traffic units, allowing Eurotunnel to minimize its administrative workload in the implementation of its verification requirements to its full satisfaction". 69. To ensure equal treatment and equal access conditions for freight and passenger train operators, the 2018 Network Statement should explain what is meant by a "*documentation system particularly reliable and efficient".* In addition, it should detail the reasons why this condition applies only to passenger trains and not to freight trains. 69. Afin de garantir des conditions d'accès équitables pour les opérateurs de trains de marchandises et de voyageurs, le DRE 2018 devrait préciser ce que recouvre des « systèmes de documentation particulièrement fiables et efficaces ». En outre, Eurotunnel devrait détailler les raisons pour lesquelles les frais de dossier ne s'appliquent pas suivant les mêmes critères pour les trains de passagers et de fret. Relationship between access charges and infrastructure manager's costs La relation entre les redevances d'accès et les coûts du gestionnaire de l'infrastructure 70. In their recommendations on the 2017 Network Statement, Arafer and ORR noted that it "does not provide clarification of the relationship between Eurotunnel's proposed charge structure and the actual or future costs". Since the 2018 Network Statement has not been changed on this point, Arafer and ORR repeat the observation. In this regard, Arafer and ORR were unable to address the problem properly in the absence of a response in due time from Eurotunnel to their information request. 70. Dans leurs recommandations relatives au DRE 2017, l'Arafer et l'ORR ont relevé que le DRE « n'explicite pas la relation entre la structure des redevances proposées par Eurotunnel et les coûts actuels ou futurs ». Le DRE 2018 n'ayant pas été modifié sur ce point, l'Arafer et l'ORR renouvellent cette observation. A cet égard, l'Arafer et l'ORR n'ont pas été en mesure d'examiner cette question dans de bonnes conditions du fait qu'Eurotunnel n'a pas répondu dans les temps à la demande d'information qui lui a été adressée. 71. Following this comment on the 2017 Network Statement, Eurotunnel indicated that applicants have little interest in understanding how an exclusive private funding of the infrastructure was achieved. Eurotunnel believes that applicants just need certainty for the charging formula to be maintained, which is secured through the long term stability provided by the Treaty, the Concession and the RUC. 71. A la suite de cette remarque sur le DRE 2017, Eurotunnel a indiqué que les candidats n'ont que peu d'intérêt à comprendre la façon dont un financement de l'infrastructure exclusivement privé a été réalisé. Eurotunnel considère que les candidats ont pour seul besoin d'être certains que la formule tarifaire sera maintenue, ce qui se trouve garanti par la stabilité de long terme offerte par le Traité, la Concession et le RUC. 72. Arafer and ORR disagree with this statement. Evidence from stakeholders demonstrates that this subject is of importance to users of the Channel Fixed Link. In this regard, the information provided on the recovery of costs (and principally of long term costs) through charges is insufficient and, therefore, lacks transparency. 72. L'Arafer et l'ORR sont en désaccord avec cette affirmation. Il ressort de l'instruction que cette question est importante pour les usagers de la Liaison Fixe Transmanche. A cet égard, les informations fournies sur le recouvrement des coûts (et principalement sur les coûts à long terme) par les redevances ne sont pas suffisantes et, partant, manquent de transparence. 73. As an example, while various rates of return are quoted in the 2018 Network Statement (11.7% and 3%), no methodological explanation is provided to justify these values. 73. A titre d'exemple, le DRE 2018 mentionne plusieurs taux de retour sur investissement (11,7% et 3%) mais aucune explication méthodologique n'est donnée pour justifier ces valeurs. 74. On this topic, Arafer and ORR had already pointed out in their recommendations on the 2017 Network Statement that it would improve transparency if Eurotunnel were able to clarify what the rate of return on investment on long term costs of 3% represents. 74. A ce sujet, l'Arafer et l'ORR avaient déjà souligné, dans leurs recommandations sur le DRE 2017, que la transparence du document de référence du réseau serait améliorée si Eurotunnel clarifiait ce que représente le taux de retour sur investissement sur les coûts à long terme de 3%. 75. Eurotunnel's position is that the rate of 3% represents both the current forecast lifetime investment rate of return of the project and also the annual value of the basic return on investment for railway activities. 75. D'après Eurotunnel, le taux de 3% représente à la fois la prévision actuelle du taux de retour sur investissement du projet et la valeur annuelle du retour sur investissement des activités ferroviaires. 76. Nevertheless, Eurotunnel has not made any modification to the 2018 Network Statement to set out clearly what this figure represents. Eurotunnel should provide more information about how this figure was calculated and what it represents as it is essential to the stakeholders' understanding of the costs that are recovered through charges. 76. Néanmoins, Eurotunnel n'a introduit aucune modification dans le DRE 2018 pour expliciter de manière claire ce que ces chiffres représentent. Eurotunnel devrait fournir plus d'informations détaillant la méthode de calcul mobilisée et ce que ces taux de retour représentent, dans la mesure où il est essentiel que les parties prenantes comprennent la nature des coûts recouverts par les redevances. ## 77. In The Same Context, Eurotunnel Should Update Annex 7 ("Open Access Statistical Declaration"), To Which Section 6.1.2 Of The 2018 Network Statement Refers, And Annex It Directly To The Network Statement. 77. Sur Ce Même Sujet, Eurotunnel Devrait Mettre À Jour L'Annexe 7 (« Déclaration Statistique Open Access ») À Laquelle La Section 6.1.2 Du Dre 2018 Fait Mention Et L'Annexer Directement Au Dre. 78. Eurotunnel indicated in response to Arafer and ORR's recommendations on the 2017 Network Statement that it was willing to publish updates of the "*Open Access Statistical Declaration*". However, Eurotunnel thinks that the information in Annex 7 represents an additional form of statistical reporting aimed at further promoting transparency and includes information which goes beyond the scope of the mandatory Network Statement contents required by the Directive. In Eurotunnel's opinion, it is therefore not appropriate for this information to be included directly in the Network Statement. 78. En réponse aux recommandations de l'Arafer et de l'ORR relatives au DRE 2017, Eurotunnel a indiqué être enclin à publier des mises à jour de cette « *Déclaration Statistique Open Access* ». Cependant, Eurotunnel considère que les informations fournies dans l'annexe 7 sont des informations statistiques supplémentaires qui visent à améliorer la transparence et qui vont au-delà des obligations fixées par la directive en matière de contenu du document de référence du réseau. Eurotunnel estime ainsi que la publication de ces informations directement dans le DRE n'est pas appropriée. 79. Arafer and ORR think that the publication of updated data on long term costs and the corresponding return on investment does not go beyond the scope of the mandatory contents of a Network Statement, as defined in Annex IV to the Directive. Indeed, paragraph 2 of Annex IV to the directive indicates that the Network Statement "shall contain appropriate details of the charging scheme as well as sufficient information on charges […]. It shall detail the methodology, rules and, where applicable, scales used for the application of articles 31 to 36, as regards both costs and charges". 79. L'Arafer et l'ORR estiment que la publication de données mises à jour sur les coûts de long terme et les informations correspondantes sur le taux de retour sur investissement ne va pas au-delà des obligations de la directive quant au contenu du document de référence du réseau définies à l'annexe IV. Le paragraphe 2 de l'annexe IV de la directive dispose en effet que le document de référence du réseau « contient des précisions appropriées concernant le système de tarification ainsi que les informations suffisantes sur les redevances […]. Il décrit en détail la méthode, les règles et, le cas échéant, les barèmes utilisés pour appliquer les articles 31 à 36 en ce qui concerne les coûts et les redevances ». 80. On that basis, Arafer and ORR believe that the provision of updated data from the Open Access Statistical Declaration annexed directly to the Network Statement is essential to improving transparency on the costs recovered through charges. 80. Sur ce fondement, l'Arafer et l'ORR estiment que la publication des données actualisées dans la « *Déclaration Statistique Open Access* », annexée directement au DRE, est essentielle pour améliorer la transparence relative aux coûts couverts par les redevances. ## Indexation Of Access Charges For Freight Transport L'Indexation Des Redevances D'Accès Pour Les Services De Fret 81. Section 6.1.2 of the 2018 Network Statement explains that "for the 2018 working timetable, the rail freight charging scales remain unchanged compared with 2017 and since the amended versions of the 2014/2015 Annual Statements published on 1/6/2014, thus equating to further reductions in real terms". 81. La section 6.1.2 du DRE 2018 précise que « pour l'horaire de service 2018 le barème tarifaire marchandises reste inchangé par rapport à 2017 et depuis les versions révisées 2014 et 2015 du Document de Référence Annuel 2014 publiées le 1/6/2014, aboutissant ainsi à de nouvelles réductions en termes réels ». 82. La transparence et la prévisibilité des redevances seraient améliorées si le DRE 2018 précisait les conditions et la période pour lesquelles les redevances des trains de fret devraient rester inchangées. 82. The transparency and predictability of freight train charges would be improved if the 2018 Network Statement indicated the conditions and the period of time during which these charges would be unchanged. ## Indexation Of Access Fee Per Passenger L'Indexation Du Droit De Circulation Par Passager 83. Regarding passenger train charges, Annex 4 of the 2018 Network Statement explains that "the access fee per passenger is denominated in pounds and in euros at January 2015 prices, with these amounts being indexed on a monthly basis using inflation indices (pounds: RPI all items / euros: IPC France entire, hors tabac), decreased by an annual factor of - 1.1%". Annex 4 also includes a table presenting the "inflation forecasts for the indexation of Access Fees from 2015 prices (Offers 1, 2 & 3)". Eurotunnel indicates that the inflation indices presented are "estimates for indicative purposes only. Actual Access Fees are invoiced monthly based on actual inflation indices as published by ONS & INSEE". 83. S'agissant du droit de circulation par passager, l'annexe 4 du DRE 2018 indique que « le droit de réservation par passager est exprimé en livres et en euros en valeur de Janvier 2015, dont les montants sont indexés mensuellement par rapport aux indices d'inflation (livres : RPI all items / euros : IPC France entière, hors tabac), minorés d'un facteur annuel de -1.1% ». L'annexe 4 inclut aussi un tableau qui présente les « prévisions d'inflation pour l'indexation des Droits de Circulation à partir des valeurs 2015 (Offres 1, 2 & 3) ». Eurotunnel précise que les indices d'inflation présentés sont « des estimations à fin indicative. Les redevances réelles de Circulation sont facturées mensuellement sur la base des indices d'inflation réelles publiés par ONS & INSEE ». 84. This table raises some questions. First, the table provides the actual value of the access fee per passenger for January 2016 and forecasts of the same charge for January 2017 and January 2018. The method used to index charges consists of an annual indexation comparing the inflation indices values of January. However, as indicated in each "Offer" in Annex 4, the access fee per passenger is to be indexed on a monthly basis. Arafer and 84. Ce tableau soulève plusieurs questions. En premier lieu, il présente la valeur constatée du droit de circulation par passager pour janvier 2016 et les montants prévisionnels de cette redevance pour janvier 2017 et janvier 2018. La méthode utilisée pour indexer les redevances consiste en une indexation annuelle à partir de l'évolution annuelle de la valeur des indices au mois de Janvier. Néanmoins, comme cela est précisé pour chaque ORR think that this table would be more useful if the methodology used to prepare the estimate of the indicative values of the access fee per passenger were the same as that used in practice to inflate this charge. « *Offre* » de l'annexe 4, le droit de circulation par passager doit être indexé mensuellement. L'Arafer et l'ORR estiment que ce tableau serait plus utile si la méthode utilisée pour renseigner l'indexation prévisionnelle des droits de circulation des trains de passagers était la même que celle qui est mobilisée, en pratique, pour indexer cette redevance. 85. Second, this table has been updated to include all the actual values for 2015 and the actual values for 2016 (where available). The table has also adjusted forecasts for 2016 (for the remaining forecasts) and 2017. A further column has been added with forecasts for 2018. 85. Deuxièmement, ce tableau a été actualisé avec les valeurs constatées pour les années 2015 et 2016 (lorsqu'elles étaient disponibles). Le tableau renseigne aussi les prévisions pour l'année 2016 (pour celles qui ont pu l'être) ainsi que les prévisions pour l'année 2017. Une colonne a également été ajoutée pour indiquer les prévisions relatives à l'année 2018. 86. Arafer and ORR note that the 2017 and 2018 Network Statements show two different values for the same figure. While the 2017 Network Statement states that the IMP monthly value for January 2015 was of 124.5, the 2018 Network Statement presents a value equal to 98.85. Arafer and ORR think that the reason for this difference should be clarified. 86. L'Arafer et l'ORR relèvent que le DRE 2017 et le DRE 2018 présentent deux valeurs différentes pour la même variable. Si le DRE 2017 indique que la valeur mensuelle de l'indice IMP pour le mois de janvier 2015 est égale à 124,5, le DRE 2018 présente une valeur de 98,85. L'Arafer et l'ORR estiment que l'origine de cette différence devrait être clarifiée. 87. Moreover, Eurotunnel has adjusted its forecasts of the annual variation of the inflation index for 2016 and 2017 downwards. For example, the expected annual inflation for 2016 presented in the 2017 Network Statement was 1.5% for the IMP (assimilated to the French index IPC) and 2.5% for the RPI, whereas in the 2018 Network Statement the 2016 inflation forecast of the IMP and the RPI is 0.3% and 1.8% respectively for the same year. 87. De plus, Eurotunnel a ajusté à la baisse ses prévisions relatives à la variation annuelle de l'indice d'inflation pour les années 2016 et 2017. A titre d'exemple, la variation annuelle prévue pour l'année 2016 dans le DRE 2017 s'élevait à 1,5% pour l'IMP (assimilé à l'indice français lPC) et 2,5% pour le RPI, alors que pour le DRE 2018 l'inflation prévisionnelle de l'IMP et du RPI est respectivement fixée à 0,3% et 1,8% pour cette même année. 88. Again, Arafer and ORR emphasise that information on the future indexation of charges should enable all applicants to benefit from a sufficient understanding on charges which will be invoiced to them, and from predictability in relation to the development of access charges. In particular, Eurotunnel should clearly state whether charges are adjusted for the difference between actual inflation and Eurotunnel's forecast of inflation. Eurotunnel should also indicate the source of forecasts used to estimate these values. 88. L'Arafer et l'ORR soulignent à nouveau que les informations relatives à l'indexation future des redevances devraient permettre aux candidats de bénéficier d'une bonne compréhension des redevances qui leur seront appliquées et d'une prévisibilité relative à leur évolution. En particulier, Eurotunnel devrait préciser clairement si les redevances ont vocation à être ajustées pour compenser l'écart entre l'inflation constatée et les prévisions faites par Eurotunnel. Eurotunnel devrait également renseigner la source des prévisions utilisée pour estimer ces valeurs. Indexation of reservation fee per train paid by passenger trains L'indexation du droit de réservation par train payé par les trains des voyageurs 89. Annex 4 of the 2018 Network Statement explains that the reservation fee per train paid for passenger trains "is denominated in pounds and euros at 2015 prices, with these amounts being indexed on an annual basis using inflation indices (pounds: RPI all items / euros: IPC France entire, hors tabac). This reservation fee is subject to annual adjustments to reflect any variances in provisional and actual figures for train volumes, indexation, performance and costs (Energy, Insurance & Renewals adjustment)". Since the 2017 Network Statement, Annex 4 also includes a table presenting the "Visibility over 5 years on Reservation Fees per Train in 2015 prices (Offer 1)". 89. L'annexe 4 du DRE 2018 précise que le droit de réservation dont les trains de passagers doivent s'acquitter est « exprimé en livres et en euros en valeur 2015, dont les montants sont indexés annuellement par rapport aux indices d'inflation (livres : RPI all items / euros : IPC France entière, hors tabac). Ce droit de réservation fait l'objet d'ajustements annuels pour refléter les éventuelles variations des chiffres prévisionnels et réalisés de volume de trains, d'indexation, de performance et de coûts (Energie, Assurances & ajustement Renouvellements). Depuis le DRE 2017, l'annexe 4 inclut un tableau présentant la « visibilité sur 5 ans des droits de réservation par train en valeur 2015 (Offre 1) ». 90. Following our recommendations on the 2017 Network Statement, Eurotunnel has changed this table. First, the table now indicates that this fee is "subject to annual adjustments to reflect any variances in provisional & actual vs. forecasts for volumes, indexation, performance and costs". In this respect, Arafer and ORR believe that Eurotunnel should explain more clearly the method for making these adjustments. 90. Faisant suite aux recommandations sur le DRE 2017, Eurotunnel a modifié ce tableau. Premièrement, le tableau précise désormais que cette redevance est « *soumis*[e] à ajustements annuels pour refléter les variations des prévisionnels et réalisés vs. projections de volume, d'indexation, de performance et de coûts ». A cet égard, l'Arafer et l'ORR estiment qu'Eurotunnel devrait expliquer de manière plus claire la méthode qu'il utilisera pour réaliser ces ajustements. 91. Secondly, Eurotunnel has also added a sentence to the table indicating that "the evolution of Reservation Fees for Offers 2, 3 & 4 is directly proportional to Reservation Fee for Offer 1, and can be simply derived prorata". Arafer and ORR think that the supplementary detail is unclear and the table should therefore be revised. 91. Deuxièmement, Eurotunnel a également ajouté une précision pour ce tableau, selon laquelle «l'évolution des Droits de Réservation pour les Offres 2, 3 & 4 est directement proportionnelle aux Droits de Réservation pour l'Offre 1, et peut se déduire par simple prorata ». L'Arafer et l'ORR estiment que ces précisions supplémentaires n'apportent pas plus de clarté et que le tableau devrait, en conséquence, être révisé. ## B. The Etica Scheme B. L'Initiative Etica 92.. Arafer and ORR believe that it would improve transparency if the detailed conditions of the ETICA initiative were annexed directly to the 2018 Network Statement, in addition to being published on Eurotunnel's website. . Introduced in 2013, the ETICA Scheme aims to promote the development of new rail freight services by means of reduced charges 92. L'Arafer et l'ORR considèrent que la transparence serait améliorée si les conditions détaillées de l'initiative ETICA étaient annexées directement au DRE 2018, en plus d'être publiées sur le site internet d'Eurotunnel. Instauré en 2013, le système ETICA vise, au moyen de réductions tarifaires, à favoriser le développement de nouveaux services ferroviaires de fret. 93. Moreover, section 6.5.1 of the 2018 Network Statement states that 2018 will be the last year in which this system of incentives for the development of new rail freight services will be applied. Therefore, they would hope that Eurotunnel will provide some visibility on what, if any, discounts may be applied beyond 2018. 93. De plus, la section 6.5.1 du DRE 2018 indique que 2018 sera la dernière année d'application de ce système d'encouragement au développement de nouveaux services ferroviaires de fret. Il serait donc souhaitable qu'Eurotunnel offre une certaine visibilité sur les éventuelles réductions qui pourraient être appliquées au-delà de 2018, le cas échéant. ## 2.2. Operational Performance And Performance Scheme 2.2. La Performance Opérationnelle Et Le Système D'Amélioration Des Performances 94. L'ARAFER et l'ORR ont examiné la section 7 du DRE au regard des dispositions de la directive, laquelle a été entièrement transposée en France et au Royaume-Uni. Eurotunnel est par conséquent tenu d'assurer que les informations présentées dans le DRE sont conformes avec ces dispositions. 94. Arafer and ORR have considered section 7 of the Network Statement in the context of the requirements of the Directive, which has now been fully implemented both in France and the UK. Eurotunnel is therefore obliged to ensure that the information it supplies in the Network Statement complies with those requirements. 95. During the workshop organised by Arafer and ORR in 2016, stakeholders have insisted on the fact that operational performance in the Channel Fixed Link is important to their business needs and that delays can give rise to additional costs in some circumstances. Arafer and ORR also know that Eurotunnel's own shuttle business, though not covered by any of the conditions described in this Network Statement, can also be adversely affected by delays. This provides a further incentive for Eurotunnel to manage operational performance efficiently. 95. A l'occasion de l'atelier de travail organisé par l'Arafer et l'ORR en 2016, les parties prenantes ont insisté sur le fait que la performance opérationnelle au sein de la Liaison Fixe Transmanche est importante pour leurs besoins commerciaux et que les retards peuvent, dans certaines circonstances, entraîner des coûts supplémentaires. Si l'activité de navette n'est pas l'objet du DRE, l'Arafer et l'ORR sont conscients du fait qu'elle puisse également être affectée par les retards. Pour Eurotunnel, cette situation emporte des incitations supplémentaires à gérer efficacement la performance opérationnelle. 96. Arafer and ORR noted in 2016 the conclusion of negotiations regarding the agreement on the implementation of RUC provisions on operation, maintenance and renewal costs. In particular, in the context of performance management, Arafer and ORR consider the inclusion of provisions which make part of the costs payable to Eurotunnel contingent on its performance levels, quarter by quarter, to be highly positive. In addition, although this is not made explicit in the 2018 Network Statement, Arafer and ORR have been pleased to receive confirmation from Eurotunnel that the agreement includes "reopener provisions" which allow any new passenger railway undertaking to review the agreement's provisions with Eurotunnel. Arafer and ORR note however that this agreement does not apply to freight railway undertakings using the Channel Fixed Link. 96. En 2016, l'Arafer et l'ORR ont pu constater la finalisation des négociations relatives à l'accord d'application des dispositions du RUC concernant les coûts d'exploitation, d'entretien et de renouvellement. S'agissant, en particulier, de la gestion de performance, l'Arafer et l'ORR accueillent favorablement l'introduction des dispositions consistant à ce qu'une partie du coût payé à Eurotunnel soit conditionnée aux niveaux de performance atteints par le gestionnaire d'infrastructure, trimestre par trimestre. En outre, bien que cela ne soit pas explicité dans le DRE 2018, l'Arafer et l'ORR ont, avec satisfaction, reçu la confirmation d'Eurotunnel que cet accord comporte des « clauses de revoyure », permettant à toute nouvelle entreprise de transport ferroviaire de passagers de revoir les termes de l'accord avec Eurotunnel. L'Arafer et l'ORR relèvent toutefois que cet accord ne s'applique pas aux entreprises de fret ferroviaire empruntant la Liaison Fixe Transmanche. 97. In this context and with regard to the requirements of the Directive, Arafer and ORR have considered section 7 of the 2018 Network Statement. 97. Dans ce contexte et au regard des dispositions de la directive, l'Arafer et l'ORR ont examiné la section 7 du DRE 2018. 98. Article 35 of the Directive states: 98. L'article 35 de la Directive dispose que : "1. Infrastructure charging schemes shall encourage railway undertakings and the infrastructure manager to minimise disruption and improve the performance of the railway network through a performance scheme. This scheme may include penalties for actions which disrupt the operation of the "1. Par l'établissement d'un système d'amélioration des performances, les systèmes de tarification de l'infrastructure encouragent les entreprises ferroviaires et le gestionnaire de l'infrastructure à réduire au minimum les défaillances et à améliorer les performances du réseau ferroviaire. Ce network, compensation for undertakings which suffer from disruption and bonuses that reward better-than-planned performance". système peut comporter des sanctions en cas d'actes à l'origine de défaillances du réseau, des compensations pour les entreprises qui sont victimes de ces défaillances et des primes en cas de bonnes performances dépassant les prévisions". 99. L'Arafer et l'ORR relèvent que le DRE 2018 ne prévoit pas de paiements en cas de « *bonnes performances dépassant les prévisions* ». 99. Arafer and ORR note that there is no acknowledgement in the 2018 Network Statement of payments for "*better-than-planned performance*." 100. "2. The basic principles of the performance scheme as listed in point 2 of Annex VI shall apply throughout the network". 100. "2. Les principes de base du système d'amélioration des performances énumérés au point 2 de l'annexe VI s'appliquent à l'ensemble du réseau. 3. The Commission shall be empowered to adopt delegated acts in accordance with Article 60 concerning amendments to point 2(c) of Annex VI. Thus point 2(c) of Annex VI, may be amended in the light of the evolution of the rail market and experience gained by regulatory bodies referred to in Article 55, infrastructure managers and railway undertakings. Such amendments shall adapt the classes of delay to the best practices developed by industry. 3. La Commission est habilitée à adopter des actes délégués conformément à l'article 60 en ce qui concerne des modifications à apporter à l'annexe VI, point 2 c). Ainsi, le point 2 c) de l'annexe VI peut être modifié en fonction de l'évolution du marché ferroviaire et à la lumière de l'expérience acquise par les organismes de contrôle visés à l'article 55, les gestionnaires de l'infrastructure et les entreprises ferroviaires. Ces modifications adaptent les catégories de retard aux meilleures pratiques élaborées par le secteur". 101. Point 2 of Annex VI to the Directive then contains the following: 101. Le point 2 de l'annexe VI précise que : "2. The performance scheme as referred to in Article 35 shall be based on the following basic principles: "2. Le système d'amélioration des performances visé à l'article 35 repose sur les principes de base ci-après. (a) In order to achieve an agreed level of performance and not to a) Pour parvenir à un niveau de performance convenu sans endanger the economic viability of a service, the infrastructure manager shall agree with applicants the main parameters of the performance scheme, in particular the value of delays, the thresholds for payments due under the performance scheme relative both to individual train runs and to all train runs of a railway undertaking in a given period of time;" compromettre la viabilité économique d'un service, le gestionnaire de l'infrastructure arrête, en accord avec les candidats, les principaux paramètres du système d'amélioration des performances, et notamment la valeur des retards et les seuils applicables aux paiements dus au titre du système d'amélioration des performances par rapport à la fois aux mouvements de trains individuels et à l'ensemble des mouvements de trains d'une entreprise ferroviaire au cours d'une période donnée". 102. Bien que les principaux paramètres du système d'amélioration des performances d'Eurotunnel soient présentés dans le DRE 2018, l'Arafer et l'ORR constatent qu'aucune précision n'est donnée pour indiquer si ces paramètres ont été fixés en accord avec les candidats. Les objectifs de performance globale, les modalités de paiement des pénalités associées et la valeur des retards ne sont en outre pas définis. 102. Arafer and ORR note that whilst the main parameters of Eurotunnel's performance scheme are set out in the 2018 Network Statement, it is not clear that these have been agreed with applicants. Further, overall performance targets, associated penalty payments and the value of delays are not defined, either for the infrastructure manager or for railway undertakings. 103. "(b) The infrastructure manager shall communicate to the railway undertakings the working timetable, on the basis of which delays will be calculated, at least five days before the train run. The infrastructure manager may apply a shorter notice period in case of force majeure or late alterations of the working timetable;" 103. b) Le gestionnaire de l'infrastructure communique aux entreprises ferroviaires, cinq jours au moins avant le mouvement de train, l'horaire de service sur la base duquel les retards seront calculés. Le gestionnaire de l'infrastructure peut, en cas de force majeure ou de modification tardive de l'horaire de service, effectuer cette communication dans un délai plus court. 104. Arafer and ORR believe that the allocation process and timetable described by Eurotunnel complies with this requirement. 104. L'Arafer et l'ORR estiment que la procédure et le calendrier d'allocation des capacités présentés par Eurotunnel sont conformes avec cette exigence. 105. "c) Tous les retards sont rangés dans l'une des catégories et souscatégories de retards suivantes: [l'annexe détaille une liste exhaustive des categories et sous-catégories des retards]" 105. "(c) All delays shall be attributable to one of the following delay classes and sub-classes: [The annex sets out a comprehensive list of delay classes and sub-classes]" (d) Wherever possible, delays shall be attributed to a single organisation, considering both the responsibility for causing the disruption and the ability to re-establish normal traffic conditions; "d) Dans la mesure du possible, le retard est imputé à une seule organisation, en tenant compte à la fois de la responsabilité pour la perturbation causée et de l'aptitude à rétablir des conditions de circulation normales". 106. Eurotunnel asserts that its delay attribution and allocation is compliant with the directive. However, Eurotunnel should provide a more detailed explanation of both systems in the 2018 Network Statement so as to demonstrate compliance with the directive. 106. Eurotunnel affirme que l'attribution et l'allocation des retards est conforme à la directive. Eurotunnel devrait cependant fournir plus de détails sur la classification des retards dans le DRE 2018 afin de justifier de la conformité avec la directive. 107. (e) The calculation of payments shall take into account the average delay of train services of similar punctuality requirements; 107. "e) Le calcul des paiements tient compte du retard moyen des services ferroviaires soumis à des exigences de ponctualité similaires". 108. Arafer and ORR have seen no indication that Eurotunnel has complied with this requirement. Specifically, there are no targets for "delay minutes" and "cancellations". There appear to be no charges if a delay is below 15 minutes. Eurotunnel should provide sufficient explanation to demonstrate compliance with the directive on this issue. 108. L'Arafer et l'ORR n'ont pas identifié d'éléments qui permettraient de justifier qu'Eurotunnel satisfait cette exigence. En particulier, aucun objectif relatif aux minutes de retard et aux annulations n'est défini. Il semble, en outre, qu'il n'y ait aucun paiement prévu en cas de retard inférieur à 15 minutes. Eurotunnel devrait fournir plus d'explications sur ces points afin de justifier de la conformité avec la directive. 109. (f) The infrastructure manager shall, as soon as possible, communicate to the railway undertakings a calculation of payments due under the performance scheme. This calculation shall encompass all delayed train runs within a period of at most one month; 109. "f) Le gestionnaire de l'infrastructure communique, dans les meilleurs délais, aux entreprises ferroviaires un calcul des paiements dus au titre du système d'amélioration des performances. Ce calcul comprend tous les mouvements de trains ayant subi un retard au cours d'une période maximale d'un mois" 110. Eurotunnel's performance scheme does not generally give rise to performance payments. However poor performance can have other financial implications, both for Eurotunnel and for applicants. Section 7.2 of the 2018 Network Statement does set out financial payments for specific scenarios, but any applicable payments beyond these are not covered. Eurotunnel should provide further clarity on this. 110. Le système d'amélioration des performances d'Eurotunnel ne donne pas lieu à des paiements liés à la performance. Néanmoins, une mauvaise performance peut avoir un impact financier, tant pour Eurotunnel que pour les candidats. La Section 7.2 du DRE 2018 prévoit des pénalités financières pour des situations spécifiques mais elle ne précise pas les paiements applicables en dehors de ces cas précis. Eurotunnel devrait clarifier ce point. 111. (g) Without prejudice to the existing appeal procedures and to the provisions of Article 56, in the case of disputes relating to the performance scheme, a dispute resolution system shall be made available in order to settle such matters promptly. This dispute resolution system shall be impartial towards the parties involved. If this system is applied, a decision shall be reached within a time limit of 10 working days; 111. "g) Sans préjudice des voies de recours existantes et des dispositions de l'article 56, en cas de litige concernant le système d'amélioration des performances, un système de règlement des litiges est mis à disposition pour régler rapidement ces litiges. Ce système est impartial à l'égard des parties concernées. En cas de recours à ce système, une décision est prise dans un délai de dix jours ouvrables". 112. The 2018 Network Statement contains no specific description of a performance dispute resolution system provided by Eurotunnel to address performance scheme disputes. However, there is a footnote (in section 7 of the 2018 Network Statement) that references the dispute resolution system described in section 4.3.3 (for capacity allocation disputes) and notes that 112. Le DRE 2018 ne présente pas de description précise du système de règlement des litiges prévu par Eurotunnel qui permettrait de résoudre des différends relatifs au système d'amélioration des performances. Néanmoins, une note de bas de page (en section 7 du DRE 2018) fait référence au système de règlement des litiges décrit en section 4.3.3 (pour la résolution this may be applied. Arafer and ORR believe that this issue should be further developed in the 2018 Network Statement so as to ensure that applicants have access to a clear description of the manner in which disputes are to be settled. des conflits dans la répartition des capacités) et indique que ce système pourrait être appliqué. L'Arafer et l'ORR estiment que ce point devrait être davantage développé dans le DRE 2018 de telle sorte que les candidats aient accès à une information transparente sur les conditions de règlement d'éventuels litiges. 113. "(h) Once a year, the infrastructure manager shall publish the annual average level of performance achieved by the railway undertakings on the basis of the main parameters agreed in the performance scheme". 113. "h) Une fois par an, le gestionnaire de l'infrastructure publie le niveau moyen annuel de performance auquel sont parvenues les entreprises ferroviaires au regard des principaux paramètres arrêtés dans le système d'amélioration des performances". 114. Arafer and ORR note that there is no mention of this in the Network Statement. Eurotunnel should remedy this by publishing the required information. 114. L'Arafer et l'ORR notent que le document de référence du réseau n'en fait pas mention. Eurotunnel devrait remédier à cette situation en publiant les informations requises. ## Schedule 1 Services And Operators Using The Channel Fixed Link 1. In 2015, the following operators used the Channel Fixed Link: Operators 2. There has been differences in traffic evolution between activities in the recent past, as depicted in the following tables: | | 2011 | 2012 | |-------------------------------|-----------|-----------| | 2 262 811 | 2 424 342 | | | 2 481 167 | | | | | | | | (-) | | | | (+7.1%) | (+2.3%) | | | Number of cars transported by | | | | the Shuttles | | | | | | | | (annual change) | | | | 1 263 327 | 1 464 880 | 1 362 849 | | | | | | (-) | (+16%) | (-7.0%) | | Number of trucks transported | | | | by the Shuttles | | | | | | | | (annual change) | | | Source: Eurotunnel, annual reports 2013, 2014 and 2015 and Eurotunnel's press release of 10 January 2017. 10 Sold on November 15 2016 to EQT Infrastructure. | 2 572 263 | 2 556 585 | 2 610 242 | |--------------|--------------|--------------| | | | | | | | | | (+3.7%) | | | | (-0.6%) | | | | (+ 2.1%) | | | | 1 440 214 | 1 483 741 | 1 641 638 | | | | | | (+5.7%) | (+3%) | (+10.6 %) | | | 2011 | 2012 | 2013 | 2014 | 2015 | |-----------------------------|---------|---------|---------|----------|----------| | 2 388 | 2 325 | 2 547 | 2 900 | 2 421 | | | | | | | | | | Number of freight trains | | | | | | | | | | | | | | (annual change) | (-) | (-2.6%) | (+9.5%) | (+13.9%) | (-16.5%) | | 1 420 826 | | | | | | | 1 648 047 | | | | | | | 1 363 834 | | | | | | | 1 227 139 | | | | | | | 1 324 673 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | (-13.8%) | | | | | | | (+20.8%) | | | | | | | (+11.1%) | | | | | | | (-7.4%) | | | | | | | (-) | | | | | | | Number of tonnes of freight | | | | | | | transported | | | | | | | | | | | | | | (annual change) | | | | | | Source: Eurotunnel, response to the questionnaire of ARAFER and ORR on the 2017 Network Statement | | 2011 | 2012 | 2013 | 2014 | |----------------------------|---------|---------|---------|---------| | 18 292 | 18 419 | 18 560 | 18 960 | 19 020 | | | | | | | | Number of passenger trains | | | | | | | | | | | | | | | | | | (annual change) | | | | | | | | | | | | (-) | (+0.7%) | (+0.8%) | (+2.2%) | (+0.3%) | Source: Eurotunnel, response to the questionnaire of ARAFER and ORR on the 2017 Network Statement ## Annexe 1 Les Services Et Les Opérateurs Utilisant La Liaison Fixe Transmanche 1. En 2015, les opérateurs suivants ont utilisé la Liaison Fixe Transmanche: | Type de service | Opérateurs | |--------------------------------|---------------| | Navettes (voitures et camions) | Eurotunnel | | Trains de fret | | | Trains de passagers | Eurostar | | Source: Eurotunnel | | 2. Les tableaux suivants illustrent des évolutions de trafic différentes selon les activités : | | 2011 | 2012 | |------------------------------------------------------------------------------------------------------------------|-----------|----------| | Nombre | de | voitures | | 2 262 811 | 2 424 342 | | | 2 481 167 | | | | | | | | (-) | | | | (+7.1%) | (+2.3%) | | | transportées par les navettes | | | | | | | | (taux d'évolution annuel) | | | | | | | | Nombre | de | camions | | 1 263 327 | | | | 1 464 880 | | | | 1 362 849 | | | | | | | | | | | | (-) | (+16%) | (-7.0%) | | transportés par les navettes | | | | | | | | (taux d'évolution annuel) | | | | | | | | Source: Eurotunnel, rapports annuels 2013, 2014 et 2015 et communiqué de presse d'Eurotunnel du 10 janvier 2017. | | | Dans le cadre du RUC : DB Cargo, SNCF/Captrain Fournisseurs de services en Open Access: Europorte (filiale d'Eurotunnel SE), GB Railfreight (auparavant filiale d'Eurotunnel SE11) 2 572 263 2 556 585 2 610 242 (+3.7%) (-0.6%) (+ 2.1%) 1 440 214 1 483 741 1 641 638 (+5.7%) (+3%) (+10.6 %) | | 2011 | 2012 | 2013 | 2014 | |---------------------------|-----------|--------------|-----------|-----------| | 2 421 | | | | | | 2 900 | | | | | | 2 547 | | | | | | 2 325 | | | | | | 2 388 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | (-16.5%) | | | | | | (+13.9%) | | | | | | (+9.5%) | | | | | | (-2.6%) | | | | | | (-) | | | | | | Nombre de trains de fret | | | | | | | | | | | | (taux d'évolution annuel) | | | | | | | | | | | | Volume | de | marchandises | | | | 1 324 673 | 1 227 139 | 1 363 834 | 1 648 047 | 1 420 826 | | | | | | | | (-) | (-7.4%) | (+11.1%) | (+20.8%) | (-13.8%) | | transportées (en tonnes) | | | | | | | | | | | | (taux d'évolution annuel) | | | | | Source: Eurotunnel, réponse au questionnaire de l'ARAFER et de l'ORR dans le cadre des recommandations relatives au DRE 2017 | | |-------------------------------| | 19 020 | | 18 960 | | 18 560 | | 18 419 | | 18 292 | | | | | | | | | | | | (+0.3%) | | (+2.2%) | | (+0.8%) | | (+0.7%) | | (-) | | Nombre de trains de passagers | | | | (taux d'évolution annuel) | | | Source: Eurotunnel, réponse au questionnaire de l'ARAFER et de l'ORR dans le cadre des recommandations relatives au DRE 2017
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## Disciplinary Policy And Procedure Document Control Version: Amendment Approved By: Divisional Director Human Resources And Trade Unions Effective From: 8 October 2009 1. **Policy ...............................................................................................................................3** 1.1 Aim.......................................................................................................................... 3 1.2 Scope...................................................................................................................... 3 1.3 Responsibilities........................................................................................................ 3 1.4 General principles.................................................................................................... 4 2. **Procedure ........................................................................................................................5** 2.1 Introduction.............................................................................................................. 5 2.2 Setting standards..................................................................................................... 5 2.3 Confidentiality.......................................................................................................... 5 2.4 Criminal offences committed in and outside of employment .................................... 5 3. **Informal stage..................................................................................................................7** 3.1 Informal discussions ................................................................................................ 7 3.2 Disciplinary investigation ......................................................................................... 7 3.3 Suspension.............................................................................................................. 8 4. **Formal stage..................................................................................................................10** 4.1 Disciplinary hearing ............................................................................................... 10 4.2 Notification of formal hearing ................................................................................. 10 4.3 Attendance at a formal hearing.............................................................................. 11 4.4 Requests for postponement ................................................................................. 11 4.5 Order of business .................................................................................................. 11 4.6 Outcomes at a disciplinary hearing........................................................................ 12 a) Written warning...................................................................................................... 12 b) Final written warning.............................................................................................. 12 c) Disciplinary transfer and/or demotion..................................................................... 12 d) Dismissal /Summary dismissal .............................................................................. 12 4.7 Notification of the decision..................................................................................... 13 5. **Appeal............................................................................................................................14** 5.2 Common appeal conditions ................................................................................... 14 6. **Details of approval and variation process...................................................................15** Appendix one: Disciplinary rules ..................................................................................16 1. Policy 1.1 Aim The aim of the disciplinary policy and procedure is to help and encourage all employees to achieve and maintain appropriate standards of conduct. The disciplinary policy and procedure are intended to provide consistency in the treatment of staff and to promote good practice. This procedure is closely aligned with the Council's values relating to **Fairness, Respect, Excellence, Service** and Honesty. 1.2 Scope The disciplinary policy and procedure applies to all employees of the Council with the exception of: - The Chief Executive, - The Council's Monitoring Officer and - The Council's Section 151 Officer Issues of poor performance should be addressed in line with the Council's **capability policy and procedure**. No formal disciplinary action will be taken against an accredited trade union representative until the case has been discussed, by HR and the Branch Secretary or fulltime officer of the appropriate trade union. 1.3 Responsibilities Employees are responsible for: - familiarising themselves with and adhering to the standards of conduct expected of them as set out in the code of conduct Line Managers are responsible for: - providing employees with copies of the Council's disciplinary rules and **code of conduct**, ensuring that these are understood - making employees aware of what is expected of them and to act as a role model in setting and maintaining high standards - dealing with cases of misconduct promptly, in a fair and consistent manner and attending relevant training - making any reasonable adjustments that may be required in accordance with the Disability Discrimination Act The **Human Resources Division (HR)** is responsible for: - providing advice and support throughout the process - monitoring application of the procedure and reporting trends and non-compliance - maintaining a list of disciplinary authority within in each Council department; updating this on a regular basis in conjunction with Heads of Service. 1.4 General principles 1.4.1 Disciplinary action is the responsibility of all managers; however, only designated managers may suspend or discipline an employee. Heads of Service are responsible for ensuring that managers know their responsibilities and their level of authority, for example, who can give warnings or dismiss, and for maintaining an up to date record of authorised managers. HR will keep a full register of this information and Heads of Service will be responsible for advising them of any changes to these records. 1.4.2 Where an investigation indicates that the outcome of a disciplinary hearing could lead to dismissal, prior approval to proceed must be sought from the Head of Service or Director and advice sought from HR before continuing. 1.4.3 In order to comply with the legal requirements as set out in the Employment Act 2002, all stages of this procedure must be followed; any deviation from the procedure may be a disciplinary matter in itself. These incorporate the standard statutory procedure which is detailed in the **ACAS Code of Practice**. 1.4.5 Employees will not be dismissed for a first breach of discipline except in the case of gross misconduct. In extreme cases the penalty may be summary dismissal without notice or payment in lieu of notice. 2. Procedure 2.1 Introduction 2.1.1 The London Borough of Lambeth sets the standard of conduct it expects from all employees in its **disciplinary rules (appendix one)** and **code of conduct.** 2.1.2 This procedure has been adopted to ensure that all employees understand the behaviour expected of them and what course of action may be taken should these rules be breached. The Council wishes to ensure that the procedures applied to all staff are fair and consistent; the disciplinary policy and procedure are designed to encourage employees to achieve and maintain acceptable standards of behaviour in the workplace and is not to be used primarily to impose punishment. 2.2 Setting standards 2.2.1 It is essential that all employees are aware of the standards of conduct and behaviour expected of them as soon as they start and throughout their employment with the Council. Such standards are communicated in: - Disciplinary rules - Code of conduct - recruitment packs - information provided at interview - induction - one-to-one discussions and feedback - appraisals/ supervision - policies and procedures 2.3 Confidentiality 2.3.1 All parties involved in a disciplinary process will be expected to respect the process and must not disclose any confidential information in relation to the disciplinary case, except as required or permitted in accordance with this procedure. Any person who breaches confidentiality in this manner may be subject to disciplinary action. An employee may choose, however, to disclose confidential matters concerning themselves. 2.4 Criminal offences committed in and outside of employment 2.4.1 Charges brought against an individual by other parties, including the Police, and investigations by the Police are procedurally separate from this disciplinary procedure. Allegations that employees have committed criminal offences either in or outside of employment may lead to disciplinary action; particularly where the alleged acts are relevant to the employee's employment with the Council or which may bring the Council into disrepute. Investigations conducted by the Police or the Council's Internal Audit Team into alleged criminal or fraudulent activity, may take place outside of the Disciplinary Policy and Procedure and without the employee's knowledge. The outcome of such investigations may be taken into account in a subsequent disciplinary investigation in accordance with section 3.2.4. 2.4.2 Action may be taken by management irrespective of Court proceedings. It does not automatically follow that an employee will be disciplined if found guilty in Court or taken into custody. Similarly, disciplinary action may be taken if an employee has been found not guilty in the Courts of a criminal offence or if charges are not brought. 2.4.3 It is not necessary for a disciplinary investigation to be put on hold until the criminal or other investigation is complete, however this may be the most reasonable course of action in the circumstances. 2.4.4 In all such cases the Head of Service shall investigate the facts as far as possible, and in consultation with HR, come to a view as to whether the conduct warrants invoking the Disciplinary Procedure. 2.4.5 The Internal Audit section must be advised by HR where there is any suspicion of fraud or corruption. 3. Informal stage 3.1 Informal discussions An initial informal discussion can often be a more effective way of dealing with minor conduct issues than a disciplinary hearing. In the event that a manager has concerns about the conduct of an employee they should meet with the employee to discuss their concerns, state expected standards of conduct and take into consideration the employee's comments including any mitigating circumstances. 3.1.1 The informal meeting should be in a confidential environment with the managerial concerns being drawn to the employee's attention in a constructive, supportive and respectful manner. 3.1.2 The employee will be told of the expected standards of conduct required and when the matter will be reviewed again, which should generally be within three months. Should further problems arise before the review date, the manager may take further action before the timescale has elapsed. The employee should be made aware that this could happen. 3.1.3 Notes of the discussion should be written for the manager's own reference and a copy given to the employee. The notes should detail the nature of misconduct discussed, the required standard of conduct, any training, support or additional supervision that is to be provided, and the likely consequence of further breaches of conduct. The notes should be kept confidentially by the manager and disposed of as confidential waste at the end of the review period. 3.1.4 Informal discussions may not always be appropriate action. Where a manager is uncertain as to whether or not informal action is appropriate they should seek advice from HR. 3.2 Disciplinary investigation 3.2.1 Where, following an initial review, the manager considers that it is inappropriate to have an informal discussion or where an informal discussion has already taken place, a full and impartial investigation must be undertaken. 3.2.3. Where a manager wishes to commence a disciplinary investigation they must seek authority from the relevant senior manager with appropriate delegation authority. The senior manager will nominate a manager to lead the investigation with the support of HR 3.2.4 The employee under investigation will be informed that an investigation is being carried out, the nature of the complaint or allegation under investigation, together with the name of the person leading the investigation. This will be confirmed in writing together with a copy of the Council's disciplinary policy and procedure, rules and code of conduct. 3.2.5 The purpose of the investigation is to establish the facts. The size and make up of the investigation panel will depend on the seriousness and complexity of the allegations. Anyone connected with the allegations should not be involved in conducting the investigation. The investigating officer will present the management case in the event that a case proceeds to a disciplinary hearing. 3.2.6 The employee and any witnesses will be required to attend separate investigatory meetings. A minimum of three days written notice shall be provided of such meetings. With the consent of all parties this period of notice may be reduced as it is desirable that such meetings should take place as soon as possible. 3.2.7 The employee being investigated has the right to be represented at the investigation meeting, by either a recognised Trade Union representative or a work colleague. 3.2.8 An investigation meeting may be postponed at the discretion of the investigating officer if the chosen representative is unavailable. The investigating officer shall generally agree such a postponement where a reasonable alternative date and time in the near future is proposed by the employee/representative. 3.2.10 Witnesses will not normally need to be accompanied to an investigation meeting, but may request to be accompanied by a Trade Union representative or work colleague where they feel that there are special circumstances in which they feel that they require such support, for example, where the witness is alleged to have experienced bullying, harassment or discrimination. Where a witness is accompanied at an investigation meeting the role of the person accompanying them is to provide support. 3.2.11 Notes of the meeting will be taken in writing by a designated note-taker, arranged by the investigating manager. A copy of the notes taken will be provided to the employee, as soon as is reasonably practicable, to be checked for accuracy. Notes of the meeting should be kept, together with any supporting documents as possible evidence at any future disciplinary hearing, if appropriate 3.2.12 The investigating manager will prepare a report of their investigation indicating their findings to the relevant senior manager who will determine whether or not a disciplinary hearing is required based upon the findings of the investigation. If it is decided that it is not appropriate to convene a disciplinary hearing the employee will be informed in writing that no disciplinary action is being taken. Where appropriate, informal advice or guidance may be given to an employee by their line manager. 3.3 Suspension 3.3.1 During the investigation, it may be necessary, to suspend the employee where there is the possibility of a charge of **gross misconduct**. This will be in exceptional circumstances in order to enable investigations to be made which could be hindered by an employee's continued presence at work. Before suspending an employee, consideration must be given to whether short-term relocation to another work area or temporary suspension from some duties is a feasible alternative. Whether to suspend or not will depend on the circumstances of the case. Advice must be sought from HR before a suspension is arranged. 3.3.2 Where an employee is to be suspended, they should be informed that such suspension is a neutral action and is not in itself a disciplinary sanction. An employee who is to be suspended from some or all of their duties or relocated shall be invited to a confidential meeting, having been given sufficient notice, where possible, to enable them to arrange to be accompanied by a Trade Union representative or work colleague, so that they may be advised in person of the terms of their suspension/relocation. Where the employee is unable to obtain Trade Union representation at the suspension/relocation meeting, they must be advised that they may seek TU advice/representation at any subsequent meeting. 3.3.3 An employee can only be suspended by an officer with delegated authority to suspend. The Executive Director and the Departmental HR Business Partner or Employee Relations Officer shall be advised of all suspensions. 3.3.4 Suspension will be: - on full pay - for a specified period of no more than three months, although this may be extended for further periods of no more than one month on each occasion - clear as to the conditions that may apply, for example entry to Council premises, contact with Council staff, recording any periods of sickness or of annual leave during the suspension, use of Council equipment and resources etc. (The Council shall not generally prevent employees from using Council facilities as a member of the public, or seek to restrict social contact outside of a work context with fellow employees who may be friends or relatives of the suspended employee) - subject to regular review in light of changed circumstances and for no longer than necessary - confirmed in writing to the employee stating the reason(s) for the suspension, its likely duration, and any conditions that apply. A copy of the letter confirming suspension will be given to the employee's representative 3.3.5 HR is responsible for advising Service Directors, on a monthly basis, details of all suspensions in their service area. 4. Formal stage 4.1 Disciplinary hearing 4.1 Where it is genuinely believed that there is a disciplinary case to answer a formal disciplinary hearing will be convened. 4.1.2 The hearing will be conducted by a disciplinary panel and a HR representative, who will provide guidance on the procedural aspects of the process. 4.1.3 The disciplinary panel shall consist of a minimum of two managers neither of whom shall have had any prior involvement in the case and at least one of whom shall not be in the management line of the employee. The panel Chair shall be either trained or suitably experienced in chairing formal panels. 4.2 Notification of formal hearing 4.2.1 The manager will notify the employee in writing, with a copy to the employee's representative of the intention to hold a disciplinary hearing. The letter instructing the employee to attend the disciplinary hearing should: - give the employee at least 5 full working days notice of the hearing - set out the date, time and place of the hearing and the names of the managers on the panel - confirm the nature of the alleged offence, conduct or complaint. This should be set out as one or more disciplinary charges specifying in each case the allegation the Disciplinary Rule which it is alleged that the employee has breached. [e.g. It is alleged that on date X you did Y in breach of disciplinary rule Z] - advise the employee of their right to be represented at the hearing by either a recognised trade union representative or a workplace colleague - where possible, be accompanied by the documents that the manager will present at the hearing, although these can be sent under separate cover provided they arrive no later than five full working days before the hearing. Documents to be considered at a formal hearing should be set out in a logical order, indexed and paginated, with a written introduction including any conclusions and recommendations to the panel. - advise of the names of any witness intended to be called and copies of any documents or statements which will be produced. This will include the investigation report - advise that the offence, if proved may result in formal disciplinary action being taken. Where the allegations are allegations of gross misconduct or where the employee already has a live final warning, the letter should indicate that the outcome could be dismissal from employment - advise of the requirement that the employee advise the manager of the name of their representative and the names of any witnesses to be called at least one working day before the hearing - Advise of the requirement to provide copies of any documentation material at least one working day prior to the hearing. (NB. A disciplinary panel shall have discretion to consider documentation submitted after this deadline where they consider it to be relevant to the disciplinary charge(s) 4.3 Attendance at a formal hearing 4.3.1 The following may attend a disciplinary hearing: - The employee facing disciplinary action. - The Panel of managers who will hear the case - A HR representative who shall act as an impartial advisor to the panel - The employee - The employee's representative - The investigating officer - A note taker - Any other member of staff invited by the Panel to advise or give information as a witness who shall remain only for the duration of their evidence - Other employees may attend for training purposes with the consent of the Chair of the Panel 4.4 Requests for postponement 4.4.1 At the request of the employee the hearing may be postponed on one occasion. The reasons for the postponement must be explained to the chair of the panel, who will decide whether to agree or not to the postponement. If agreed, the employee must give an alternative date, no more than 5 working days after the original date for the hearing. 4.4.2 The hearing will not normally be re-arranged more than once. Further requests for postponement of a hearing will be considered on their merits by the Chair of the panel and will not always be agreed. Following one postponement the hearing may proceed in the absence of the employee. 4.5 Order of business 4.5.1 The order of business at a disciplinary hearing will normally be: - Introductions - Presentation by management, which may include the calling of witnesses, who may give their evidence, be cross-examined by the employee/representative and questioned by the panel - Questions to management by employee/representative and the panel - Presentation by the employee/representative, which may include the calling of witnesses, who may give their evidence, be crossexamined by management and questioned by the panel - Questions to the employee/representative by management and the panel - Summing up by the management representative - Summing up by the employee/representative - Decision of the panel 4.6 Outcomes at a disciplinary hearing 4.6.1 Having considered everything they have heard at the disciplinary hearing, the disciplinary panel shall consider first of all whether the procedure has been correctly applied and, if so, whether the disciplinary charges have been proven. 4.6.2 Where the disciplinary charges have been found proven the panel shall consider whether or not to apply any disciplinary sanction. In discerning an appropriate disciplinary sanction, no account should be taken of any lapsed warnings. The following sanctions are available; a) Written warning A written warning will be issued for serious matters or repetition or continuation of an offence for which an informal warning was issued (and remains live). A written warning will generally be given for a first offence of misconduct (other than gross misconduct). A copy of the warning will remain on the personal file for 12 - 24 months after which time it will be disregarded for disciplinary purposes. The disciplinary panel shall determine the appropriate duration of the warning having regard to the seriousness of the offence and any mitigating circumstances. b) Final written warning A final written warning will be issued if a written warning has already been issued and another offence has occurred or, where the conduct is of such a serious nature that a first written warning is not deemed appropriate, or where the offence could have warranted dismissal but the panel decides that this is not appropriate in all the circumstances (including having regard to any mitigating circumstances). A copy of the warning will normally remain on the personal file for 24 - 60 months after which time it will be disregarded for disciplinary purposes. The disciplinary panel shall determine the appropriate duration of the warning having regard to the seriousness of the offence and any mitigating circumstances. c) Disciplinary transfer and/or demotion Disciplinary transfer and/or demotion shall be available as an alternative to dismissal with the consent of the employee. Before deciding to offer disciplinary transfer or demotion as an alternative to dismissal the disciplinary panel shall satisfy themselves that a suitable post has been identified. In cases of transfer to a lower graded post, the employee will be expected to undertake the full range of duties for that post. There will be no salary protection where a loss of pay is incurred as a result of the transfer or demotion. d) Dismissal /Summary dismissal Dismissal may only be applied where a final warning has previously been issued or where an allegation of gross misconduct is found to be proven. Summary dismissal, dismissal without previous warning and without notice, will only apply in cases of gross misconduct, where there has been a serious breach of discipline and where it would be inappropriate for the employee to remain in the employment of the Council for the notice period. 4.7 Notification of the decision 4.7.1 The outcome of the disciplinary hearing will be communicated to the employee in writing within five working days of the date of the meeting. The outcome letter will contain the following points: - the allegations addressed at the hearing - any matters taken into account in reaching the decision - any mitigating circumstances put forward by the employee - the decision on the findings of the allegations - the sanction to be imposed, and the reason for that sanction - where the sanction is summary dismissal, an explanation of the circumstances warranting summary dismissal - the period that any warning will stay live for - full particulars of what is expected of the employee in future in terms of behaviour, performance, attitude etc and the time scale in which improvements must be made - any actions to be undertaken by management - that further occurrences of the allegations or any of a similar nature will result in further disciplinary action. Where a final warning has been issued it will be made clear that further occurrences of the allegations or any of a similar nature may, after a further disciplinary hearing, result in dismissal - details of the employee's right of appeal against the decision of the panel, together with time scales for exercising these rights - that if there is no need to take further disciplinary action during the time period specified, the warning will be expunged from the employee's record 5. Appeal 5.1 Lodging an appeal 5.1.1 The employee can appeal against any formal action taken under this procedure. The purpose of the appeal is to review the decision taken by the disciplinary panel, not to re-hear the case. 5.1.2 The appeal must be made in writing, to the Executive Director, within 10 working days of receipt of written confirmation of the decision and will normally be heard within twenty working days from receipt of the appeal letter. 5.1.3 The Executive Director or his or her nominee shall arrange for the appeal to be heard by a panel of at least two officers, one of whom must be at the same or higher grade as the chair of the original panel. Neither shall be in the direct line management of the employee. 5.2 Common appeal conditions 5.2.1 The grounds of appeal should relate to one or more of the following: a) The procedure An appeal can be lodged on the grounds that the disciplinary procedure was applied unfairly or inaccurately. b) The facts An appeal can be lodged where the employee believes that the facts of the case did not support the decision made; that the facts considered were not relevant; that the facts were nor substantiated; or where there are new facts/evidence which needs to be considered that has come to light subsequent to the hearing c) The decision An appeal can be lodged where the employee feels that the sanction received is disproportionate to the charges found taking into account the evidence/mitigating circumstances presented. 5.2.1 The appellant will be given 5 working days notice of the appeal hearing along with any documents which management will present at the appeal. The appellant must provide their own documents within two working days of the hearing. 5.2.3 The panel will review whether the original decision was reasonable having reviewed the grounds for appeal. The Appeal Panel shall have discretion to go into as much detail as they consider necessary in order to give a fair hearing to the appeal. The decision at appeal shall be either to uphold the original decision of the formal hearing or to issue a lesser sanction the appeal decision, or to overturn the original decision and impose no sanction. This decision shall be final and will be confirmed in writing. 5.2.4 Notes shall be taken at an appeal hearing and a copy provided to the appellant within 10 working days of the hearing. ## 6. Details Of Approval And Variation Process 6.1 Where the Council wishes to amend or terminate this procedure, it will consult with the relevant trade union with a view to reaching agreement over the proposed amendment(s)/termination. This procedure may be amended or terminated by agreement with the relevant trade unions at any time. Where agreement has not been reached with the relevant trade unions arising from consultations, the Council reserve the right to implement its proposed amendment(s)/termination by giving one months notice to employees of its proposal(s). 6.2 This policy is approved and signed by: Nana Amoa-Buahin Divisional Director Human Resources Jon Rogers (Branch Secretary - UNISON) On behalf of Trade Unions ## Appendix One: Disciplinary Rules 1. Introduction 1.1 These rules apply to all Council employees. Any breaches of these rules may result in disciplinary action. 1.2 The list of rules amounting to misconduct or gross misconduct are neither exclusive nor exhaustive. There may be other offences of a similar gravity which will constitute misconduct or gross misconduct. 1.3 It should be noted that there may be circumstances where breaches listed as misconduct may be regarded as gross misconduct due to the nature, severity and/or frequency of the misconduct and taking into account the seniority of the job held by the employee 2. Misconduct 2.1 Misconduct is conduct that falls below the Council expected standards of behaviour as set out in the staff code of conduct. Instances of misconduct will not warrant dismissal on the first occasion or without previous warning. 2.2 Examples of misconduct are: 1. Refusal to obey legitimate management instructions 2. Negligence in performance of duties 3. Bad time keeping including taking excess breaks 4. Absenteeism and leaving the workplace without permission 5. Misconduct in relationships with fellow employees, clients or members of the public 6. Damage to Council property 7. Swearing or verbal abuse of fellow employees, clients or members of the public 8. Being under the influence of drink or other intoxicants 9. Breach of safety rules 10. Non-compliance with sick pay scheme 11. Unauthorised use of Councils facilities, for example, email and internet, telephone, photocopiers and vehicles 12. Breaches of the Council's financial regulations, code of conduct 13. Mismanagement of council finances leading to the overspend of a manager's budget. 14. Failure to declare personal interests as outlined in the staff code if conduct 3. Gross Misconduct 3.1 Gross Misconduct is misconduct of such a serious nature that the Council is justified in no longer tolerating an employee's continued presence at their place of work. 3.2 An allegation of gross misconduct may lead to the employee's immediate suspension from work, pending a full investigation. Where, after due consideration, the allegations against the employee are substantiated, the employee will be dismissed without notice, unless there are any mitigating circumstances 3.2 Examples of gross misconduct are: 1. Acts of discrimination, harassment or verbal abuse against employees, clients or members of the public on the grounds of race, colour, creed, ethnic or national origin, disability age, gender, sexuality or marital status. This may include the production, distribution, display or communication of material which may give rise to offence on any of these grounds. (Materials will be taken to include books, posters, magazines, cartoons, cards, emails, advertisements, calendar, photographs, videos etc) 2. Harassment, bullying and victimisation of any employee 3. Unauthorised removal, possession or theft of property belonging to the Council, a fellow employee, client or member of the public. 4. Acts of violence including the physical assault on, or serious threat against a fellow employee, client, or member of the public 5. Falsification of qualifications or information in connection with employment 6. Sexual misconduct at work 7. Malicious damage to Council property 8. Falsification of time sheets, subsistence and expenses claims etc 9. Acceptance or bribes or other corrupt practices 10. Unauthorised access to, use or disclosure of confidential matters including the unauthorised use or disclosure of any computer-held or computer generated information from which a living individual can be identified 11. Conviction for a criminal offence unconnected with the Council but which removes an employees acceptability to remain in employment; for example a cashier convicted of theft, a residential child care officer or a driver convicted of driving under the influence of drink or drugs 12. Serious breaches of safety rules including deliberate damage to, or misappropriation of safety equipment or endangering others under the influence of intoxicants 13. Holding unauthorised (un)paid employment during Council time 14. Acts of fraud against the Council or other public organisations, for example, other local authorities and benefits agencies 15. Serious breaches of the Staff Code of Conduct 16. Unauthorised indebtness to the Council 17. Serious mismanagement of council finances leading to the significant overspend of a manager's budget. 18. Failure to renew a Criminal Records Bureau (CRB) Disclosure or any membership to a professional body, where this is prerequisite to the role.
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## Joint Forest Sector Questionnaire: Provisional 2015 Data Publication Date: 19 May 2016 (Revised 25 August 2016) Coverage: United Kingdom Geographical Breakdown: None The Joint Forest Sector Questionnaire (JFSQ) collects data on removals, production and trade of wood and wood products. Statistics are collected annually and the collection is co-ordinated by a number of international organisations: Eurostat, UNECE, FAO and ITTO. Notes: 1. In the JQ1 and JQ1 OB tables, "removals" data is as delivered to processors and others. 2. The product codes tables are provided as guidance by international organisations, the exact list of commodity codes used by the Forestry Commission for specific JQ categories can differ. List of Tables JQ1 OB: Removals over bark JQ1: Removals and production JQ2: Trade JQ3: Trade in secondary processed wood and paper products Glulam and X-lam ECE-EU: Trade in roundwood and sawnwood by species EU1: Trade with countries outside the EU EU2: Removals by type of ownership Conversion factors Product codes for the JQ2 and EU1 tables Product codes for the JQ3 table UK data that is submitted to international organisations via the JFSQ is published twice a year, in May (provisional data) and September (final data) at: www.forestry.gov.uk/forestry/infd-7aqhzh Next update: 22 September 2016: final results for 2015 18 May 2017: provisional results for 2016 Issued by: IFOS - Statistics, Forest Research, 231 Corstorphine Road, Edinburgh, EH12 7AT Enquiries: Jackie Watson 0300 067 5238 statistics@forestry.gsi.gov.uk Statistician: Sheila Ward 0300 067 5236 www.forestry.gov.uk/statistics UK Date: 19 May 2016 Name of Official responsible for reply: Sheila Ward Official Address (in full): IFOS-Statistics, Forest Research, 231 Corstorphine Road, Edinburgh EH12 7AT, UK ## Eu Jq1 Ob Telephone:+ 44 300 067 5236 Fax: ## Forest Sector Questionnaire E-mail: sheila.ward@forestry.gsi.gov.uk ## Removals Product Product 2014 2015 Unit Code Quantity Quantity ROUNDWOOD REMOVALS OVERBARK 3 12,537 11,827 1 ROUNDWOOD 1000 m 3 12,005 11,299 1.C Coniferous 1000 m 3 532 528 1.NC Non-Coniferous 1000 m 3 2,050 2,160 1.1 WOOD FUEL, INCLUDING WOOD FOR CHARCOAL 1000 m 3 1,650 1,760 1.1.C Coniferous 1000 m 3 400 400 1.1.NC Non-Coniferous 1000 m 3 10,487 9,667 1.2 INDUSTRIAL ROUNDWOOD (WOOD IN THE ROUGH) 1000 m 3 10,355 9,539 1.2.C Coniferous 1000 m 3 132 128 1.2.NC Non-Coniferous 1000 m 3 7,704 7,076 1.2.1 SAWLOGS AND VENEER LOGS 1000 m 3 7,627 7,003 1.2.1.C Coniferous 1000 m 3 77 73 1.2.1.NC Non-Coniferous 1000 m 3 2,174 2,028 1.2.2 PULPWOOD (ROUND & SPLIT) 1000 m 3 2,174 2,028 1.2.2.C Coniferous 1000 m 3 0 0 1.2.2.NC Non-Coniferous 1000 m 3 610 563 1.2.3 OTHER INDUSTRIAL ROUNDWOOD 1000 m 3 555 508 1.2.3.C Coniferous 1000 m 3 55 55 1.2.3.NC Non-Coniferous 1000 m Sheila Ward ## Jq1 Forest Sector Questionnaire Removals And Production Product Product 2014 2015 Code Quantity Quantity ROUNDWOOD REMOVALS (under bark) 1 ROUNDWOOD 1000 m 1.C Coniferous 1000 m 1.NC Non-Coniferous 1000 m 1.1 WOOD FUEL, INCLUDING WOOD FOR CHARCOAL 1000 m 1.1.C Coniferous 1000 m 1.1.NC Non-Coniferous 1000 m 1.2 INDUSTRIAL ROUNDWOOD (WOOD IN THE ROUGH) 1000 m 1.2.C Coniferous 1000 m 1.2.NC Non-Coniferous 1000 m 1.2.1 SAWLOGS AND VENEER LOGS 1000 m 1.2.1.C Coniferous 1000 m 1.2.1.NC Non-Coniferous 1000 m 1.2.2 PULPWOOD (ROUND & SPLIT) 1000 m 1.2.2.C Coniferous 1000 m 1.2.2.NC Non-Coniferous 1000 m 1.2.3 OTHER INDUSTRIAL ROUNDWOOD 1000 m 1.2.3.C Coniferous 1000 m 1.2.3.NC Non-Coniferous 1000 m PRODUCTION 2 WOOD CHARCOAL 1000 mt 5 5 3 CO-PRODUCTS / CHIPS, PARTICLES, RESIDUES 1000 m 3.1 Chips and particles 1000 m 3.2 Residues including wood for agglomerates 1000 m 4 WOOD PELLETS AND OTHER AGGLOMERATES 1000 mt 354 343 4.1 Wood pellets 1000 mt 354 343 4.2 Other agglomerates 1000 mt 0 0 5 SAWNWOOD 1000 m 5.C Coniferous 1000 m 5.NC Non-Coniferous 1000 m 5.NC.T of which:Tropical 1000 m 6 WOOD-BASED PANELS 1000 m 6.1 VENEER SHEETS 1000 m 6.1.C Coniferous 1000 m 6.1.NC Non-Coniferous 1000 m 6.1.NC.T of which:Tropical 1000 m 6.2 PLYWOOD 1000 m 6.2.C Coniferous 1000 m 6.2.NC Non-Coniferous 1000 m 6.2.NC.T of which:Tropical 1000 m 6.3 PARTICLE BOARD, OSB and OTHERS 1000 m 6.3.1 of which:OSB 1000 m 6.4 FIBREBOARD 1000 m 6.4.1 HARDBOARD 1000 m 6.4.2 MDF (MEDIUM DENSITY) 1000 m 6.4.3 OTHER FIBREBOARD 1000 m 7 WOOD PULP 1000 mt + + + + + + 7.1 MECHANICAL 1000 mt + + + + + + 7.2 SEMI-CHEMICAL 1000 mt 0 0 7.3 CHEMICAL 1000 mt 0 0 7.3.1 SULPHATE UNBLEACHED 1000 mt 0 0 7.3.2 SULPHATE BLEACHED 1000 mt 0 0 7.3.3 SULPHITE UNBLEACHED 1000 mt 0 0 7.3.4 SULPHITE BLEACHED 1000 mt 0 0 7.4 DISSOLVING GRADES 1000 mt 0 0 8 OTHER PULP 1000 mt 3,164 2,880 8.1 PULP FROM FIBRES OTHER THAN WOOD 1000 mt 7 7 8.2 RECOVERED FIBRE PULP 1000 mt 3,157 2,873 9 RECOVERED PAPER 1000 mt 8,014 7,977 10 PAPER AND PAPERBOARD 1000 mt 4,397 3,970 10.1 GRAPHIC PAPERS 1000 mt 1,544 1,053 10.1.1 NEWSPRINT 1000 mt 1,159 + + + 10.1.2 UNCOATED MECHANICAL 1000 mt + + + + + + 10.1.3 UNCOATED WOODFREE 1000 mt + + + + + + 10.1.4 COATED PAPERS 1000 mt + + + + + + 10.2 SANITARY AND HOUSEHOLD PAPERS 1000 mt 768 772 10.3 PACKAGING MATERIALS 1000 mt 1,801 1,894 10.3.1 CASE MATERIALS 1000 mt + + + + + + 10.3.2 CARTONBOARD 1000 mt + + + + + + 10.3.3 WRAPPING PAPERS 1000 mt + + + + + + 10.3.4 OTHER PAPERS MAINLY FOR PACKAGING 1000 mt + + + + + + 10.4 OTHER PAPER AND PAPERBOARD N.E.S. 1000 mt 284 251 + + + denotes data not available. Country: UK Date: 19 May 2016 (Revised 25 August 2016) Name of Official responsible for reply: Official Address (in full): Forestry Commission, IFOS-Statistics, Forest Research, 231 Corstorphine Road, Edinburgh EH12 7AT, UK Telephone: + 44 300 067 5236 Fax: E-mail: sheila.w ard@forestry.gsi.gov.uk Unit 3 11,184 10,550 3 10,719 10,088 3 466 462 3 1,823 1,921 3 1,473 1,571 3 350 350 3 9,361 8,629 3 9,246 8,517 3 116 112 3 6,877 6,316 3 6,810 6,253 3 67 64 3 1,941 1,811 3 1,941 1,811 3 0 0 3 543 502 3 495 454 3 48 48 3 3,410 3,184 3 2,557 2,388 3 852 796 3 3,764 3,493 3 3,716 3,449 3 47 44 3 0 0 3 3,068 3,080 3 0 0 3 0 0 3 0 0 3 0 0 3 0 0 3 0 0 3 0 0 3 0 0 3 2,319 2,324 3 + + + + + + 3 749 756 3 0 0 3 749 756 3 0 0 UK Country: Date: 19 May 2016 Name of Official responsible for reply: Sheila Ward ## Jq2 FOREST SECTOR QUESTIONNAIRE Official Address (in full): IFOS-Statistics, Forest Research, 231 Corstorphine Road, Edinburgh EH12 7AT, UK Trade Telephone: + 44 300 067 5236 Fax: E-mail: sheila.w ard@forestry.gsi.gov.uk 1000 UK £ (Sterling) | I M P O R T | E X P O R T | |------------------------------------------|---------------| | Product | | | | | | Unit of | | | 2015 | 2014 | | code | Product | | quantity | | | | | | | | | Quantity | Value | | 1 | | | ROUNDWOOD | | | 1000 m | | | 3 | | | 545 | 45,383 | | 1.1 | | | WOOD FUEL, INCLUDING WOOD FOR CHARCOAL | | | 1000 m | | | 3 | | | 58 | 8,448 | | 1.2 | | | INDUSTRIAL ROUNDWOOD (WOOD IN THE ROUGH) | | | 1000 m | | | 3 | | | 488 | 36,935 | | 1.2.C | | | Coniferous | | | 1000 m | | | 3 | | | 440 | 28,989 | | 1.2.NC | | | Non-Coniferous | | | 1000 m | | | 3 | | | 48 | 7,946 | | 1.2.NC.T | | | of which: Tropical | | | 1000 m | | | 3 | | | 4 | 1,745 | | 2 | | | WOOD CHARCOAL | | | 1000 mt | 118 | | 3 | | | CO-PRODUCTS / CHIPS, PARTICLES, RESIDUES | | | 1000 m | | | 3 | | | 96 | 3,317 | | 3.1 | | | Chips and particles | | | 1000 m | | | 3 | | | 96 | 3,317 | | 3.2 | | | Residues including wood for agglomerates | | | 1000 m | | | 3 | | | 0 | 0 | | 4 | | | WOOD PELLETS AND OTHER AGGLOMERATES | | | 1000 mt | 4,757 | | 4.1 | | | Wood pellets | | | 1000 mt | 4,757 | | 4.2 | | | Other agglomerates | | | 1000 mt | 0 | | 5 | | | SAWNWOOD | | | 1000 m | | | 3 | | | 6,425 | 1,420,498 | | 5.C | | | Coniferous | | | 1000 m | | | 3 | | | 5,928 | 1,145,194 | | 5.NC | | | Non-Coniferous | | | 1000 m | | | 3 | | | 496 | 275,304 | | 5.NC.T | | | of which: Tropical | | | 1000 m | | | 3 | | | 143 | 86,457 | | 6 | | | WOOD-BASED PANELS | | | 1000 m | | | 3 | | | 3,260 | 936,411 | | 6.1 | | | VENEER SHEETS | | | 1000 m | | | 3 | | | 24 | 41,664 | | 6.1.C | | | Coniferous | | | 1000 m | | | 3 | | | 1 | 1,189 | | 6.1.NC | | | Non-Coniferous | | | 1000 m | | | 3 | | | 23 | 40,475 | | 6.1.NC.T | | | of which: Tropical | | | 1000 m | | | 3 | | | 8 | 11,060 | | 6.2 | | | PLYWOOD | | | 1000 m | | | 3 | | | 1,399 | 423,927 | | 6.2.C | | | Coniferous | | | 1000 m | | | 3 | | | 489 | 116,077 | | 6.2.NC | | | Non-Coniferous | | | 1000 m | | | 3 | | | 911 | 307,850 | | 6.2.NC.T | | | of which: Tropical | | | 1000 m | | | 3 | | | 95 | 41,603 | | 6.3 | | | PARTICLE BOARD, OSB and OTHERS | | | 1000 m | | | 3 | | | 980 | 188,062 | | 6.3.1 | | | of which: OSB | | | 1000 m | | | 3 | | | 278 | 47,117 | | 6.4 | | | FIBREBOARD | | | 1000 m | | | 3 | | | 857 | 282,758 | | 6.4.1 | | | HARDBOARD | | | 1000 m | | | 3 | | | 144 | 83,046 | | 6.4.2 | | | MDF (MEDIUM DENSITY) | | | 1000 m | | | 3 | | | 669 | 189,928 | | 6.4.3 | | | OTHER FIBREBOARD | | | 1000 m | | | 3 | | | 44 | 9,784 | | 7 | | | WOOD PULP | | | 1000 mt | 1,213 | | 7.1 | | | MECHANICAL | | | 1000 mt | 1 | | 7.2 | | | SEMI-CHEMICAL | | | 1000 mt | 176 | | 7.3 | | | CHEMICAL | | | 1000 mt | 993 | | 7.3.1 | | | SULPHATE UNBLEACHED | | | 1000 mt | 15 | | 7.3.2 | | | SULPHATE BLEACHED | | | 1000 mt | 969 | | 7.3.3 | | | SULPHITE UNBLEACHED | | | 1000 mt | 0 | | 7.3.4 | | | SULPHITE BLEACHED | | | 1000 mt | 9 | | 7.4 | | | DISSOLVING GRADES | | | 1000 mt | 43 | | 8 | | | OTHER PULP | | | 1000 mt | 21 | | 8.1 | | | PULP FROM FIBRES OTHER THAN WOOD | | | 1000 mt | 20 | | 8.2 | | | RECOVERED FIBRE PULP | | | 1000 mt | 1 | | 9 | | | RECOVERED PAPER | | | 1000 mt | 136 | | 10 | | | PAPER AND PAPERBOARD | | | 1000 mt | 5,869 | | 10.1 | | | GRAPHIC PAPERS | | | 1000 mt | 3,293 | | 10.1.1 | | | NEWSPRINT | | | 1000 mt | 521 | | 10.1.2 | | | UNCOATED MECHANICAL | | | 1000 mt | 443 | | 10.1.3 | | | UNCOATED WOODFREE | | | 1000 mt | 948 | | 10.1.4 | | | COATED PAPERS | | | 1000 mt | 1,381 | | 10.2 | | | SANITARY AND HOUSEHOLD PAPERS | | | 1000 mt | 235 | | 10.3 | | | PACKAGING MATERIALS | | | 1000 mt | 2,191 | | 10.3.1 | | | CASE MATERIALS | | | 1000 mt | 1,108 | | 10.3.2 | | | CARTONBOARD | | | 1000 mt | 731 | | 10.3.3 | | | WRAPPING PAPERS | | | 1000 mt | 296 | | 10.3.4 | | | OTHER PAPERS MAINLY FOR PACKAGING | | | 1000 mt | 56 | | 10.4 | | | OTHER PAPER AND PAPERBOARD N.E.S. | | | 1000 mt | 150 | UK Official Address (in full): 231 Corstorphine Road, Edinburgh EH12 7AT, UK IFOS-Statistics, Forest Research, JQ3 Telephone/Fax: + 44 300 067 5236 ## Forest Sector Questionnaire E-mail: sheila.w ard@forestry.gsi.gov.uk ## Secondary Processed Wood And Paper Products Trade 1000 UK £ (Sterling) I M P O R T V A L U E E X P O R T V A L U E Product Product code 2014 2015 2014 2015 11 Secondary wood products 11.1 Further processed sawnwood 152,897 159,305 15,932 18,345 11.1.C Coniferous 45,033 41,884 9,112 11,065 11.1.NC Non-coniferous 107,865 117,420 6,820 7,280 11.1.NC.T of which: Tropical 53,932 58,710 3,410 3,640 11.2 Wooden wrapping and packing equipment 155,799 182,844 33,188 42,417 11.3 Wood products for domestic/decorative use (excl. furniture) 148,343 167,680 22,183 26,373 11.4 Other manufactured wood products 219,794 243,889 37,010 39,906 11.5 Builder's joinery and carpentry of wood 558,197 678,885 48,011 52,383 11.6 Wooden furniture 2,580,058 3,007,411 341,391 351,858 11.7 Prefabricated buildings 146,861 179,824 88,659 92,805 11.7.1 of which: made of wood 47,581 65,950 3,908 5,386 12 Secondary paper products 12.1 Composite paper and paperboard 43,552 46,224 10,189 11,962 12.2 Special coated paper 315,178 282,065 238,951 229,667 12.3 Carbon paper and copying paper, ready for use 13,663 14,722 4,538 4,034 12.4 Household and sanitary paper, ready for use 285,639 328,975 174,660 187,587 12.5 Packaging cartons, boxes, etc. 654,276 732,766 291,541 274,531 12.6 Other articles of paper or paperboard 654,561 703,235 537,512 572,205 12.6.1 of which: printing & writing paper, ready for use 17,852 18,920 3,298 4,010 12.6.2 of which: articles, moulded or pressed from pulp 18,259 19,527 8,753 8,326 12.6.3 of which: filter paper & paperboard, ready for use 21,910 20,790 100,074 107,381 Flow Product Year Total Export Total Import Extra-EU Export Extra-EU Import Production 1000 mt 1000 mt 1000 NAC 1000 mt 1000 NAC 1000 mt 1000 NAC 1000 mt 1000 NAC 2014 +++ 2 2,455 24 26,195 0 595 7 8,571 Glulam 2015 +++ 2 2,725 28 33,181 0 483 8 13,808 2014 +++ +++ +++ +++ +++ +++ +++ +++ +++ X-lam 2015 +++ +++ +++ +++ +++ +++ +++ +++ +++ Definitions: Glulam: Builders' carpentry also includes glue-laminated timber (glulam), which is a structural timber product obtained by gluing together a number of wood laminations having their grain essentially parallel. Laminations of curved members are arranged so that the plane of each lamination is at 90 degrees to the plane of the applied load; thus, laminations of a straight gluman beam are laid flat. [from HS 4418, Builders' joinery and carpentry of wood, including cellular wood panels, assembled flooring panels, shingles and shakes] X-lam: Panels consisting of laths of roughly sawn wood, assembled with glue in order to facilitate transport or later working. [from HS4421, Other articles of wood] + + + denotes data not available. Country: Date: Sheila Ward ## Ece/Eu Species Trade Forest Sector Questionnaire Trade In Roundwood And Sawnwood By Species 1000 UK £ (Sterling) Product Classification Classification Unit of Code HS2007 CN2007 Product Quantity Quantity Value Quantity Value Quantity Value Quantity Value 3 440 28,989 414 30,618 429 23,513 271 18,213 1.2.C 44.03.20 Industrial Roundwood (wood in the rough), Coniferous 1000 m 3 74 8,260 70 9,555 154 5,206 163 7,146 ex 44.03.20 Fir/Spruce (Abies spp., Picea spp.) 1000 m 3 63 6,952 55 6,931 154 5,206 157 6,824 44.03.20.11 sawlogs and veneer logs (Abies alba, Picea abies) 1000 m 3 12 1,307 16 2,625 0 0 6 322 44.03.20.19 pulpwood and other industrial roundwood (Abies alba, Picea abies) 1000 m 3 91 7,213 93 7,906 117 6,843 39 3,426 ex 44.03.20 Pine (Pinus spp.) 1000 m 3 12 1,002 25 2,585 0 6 1 43 44.03.20.31 sawlogs and veneer logs (Pinus sylvestris) 1000 m 3 79 6,211 68 5,321 117 6,838 38 3,383 44.03.20.39 pulpwood and other industrial roundwood (Pinus sylvestris) 1000 m 3 275 13,516 251 13,157 158 11,464 70 7,640 ex 44.03.20 Other / Non-specified 1000 m 3 273 13,092 246 12,471 51 2,360 41 2,154 44.03.20.91 sawlogs and veneer logs 1000 m 3 2 424 5 686 107 9,104 30 5,486 44.03.20.99 pulpwood and other industrial roundwood 1000 m 3 48 7,946 59 8,152 0 1,861 0 1,958 1.2.NC 44.03.40/90 Industrial Roundwood (wood in the rough), Non-Coniferous 1000 m 3 23 3,081 4 726 0 378 0 118 44.03.91 of which: Oak (Quercus spp.) 1000 m 3 13 1,903 1 226 0 0 0 0 44.03.91.10 sawlogs and veneer logs 1000 m 3 10 1,178 2 499 0 378 0 118 44.03.91.90 pulpwood and other industrial roundwood 1000 m 3 9 740 3 413 0 0 0 39 44.03.92 of which: Beech (Fagus spp.) 1000 m 3 1 120 0 83 0 0 0 0 44.03.92.10 sawlogs and veneer logs 1000 m 3 8 620 3 330 0 0 0 39 44.03.92.90 pulpwood and other industrial roundwood 1000 m 3 0 4 5 298 0 1 0 34 ex 44.03.99 of which: Birch (Betula spp.) 1000 m 3 0 0 3 186 0 1 0 31 44.03.99.51 sawlogs and veneer logs 1000 m 3 0 4 2 112 0 0 0 3 44.03.99.59 pulpwood and other industrial roundwood 1000 m 3 0 0 0 33 0 19 0 209 44.03.99.10 of which: Poplar (Populus spp.) 1000 m 3 1 118 3 402 0 22 0 0 44.03.99.30 of which: Eucalyptus (Eucalyptus spp.) 1000 m 3 5,928 1,145,194 5,888 1,057,830 157 30,552 167 31,291 5.C 44.07.10 Sawnwood, Coniferous 1000 m 3 2,843 535,458 2,906 501,472 38 7,694 27 5,298 ex 44.07.10 of which: Fir/Spruce (Abies spp., Picea spp.) 1000 m 3 1,699 338,894 1,632 304,920 1 278 1 234 ex 44.07.10 of which: Pine (Pinus spp.) 1000 m 3 496 275,304 435 252,931 18 12,591 20 12,964 5.NC 44.07.20/90 Sawnwood, Non-coniferous 1000 m 3 168 117,563 175 125,370 5 2,866 5 3,132 44.07.91 of which: Oak (Quercus spp.) 1000 m 3 25 8,766 26 9,541 0 14 0 45 44.07.92 of which: Beech (Fagus spp.) 1000 m 3 3 2,237 4 2,704 0 163 0 76 44.07.93 of which: Maple (Acer spp.) 1000 m 3 1 706 1 896 0 31 0 36 44.07.94 of which: Cherry (Prunus spp.) 1000 m 3 16 8,897 13 8,718 1 347 1 385 44.07.95 of which: Ash (Fraxinus spp.) 1000 m 3 23 8,621 23 9,466 1 314 1 305 ex 44.07.99 of which: Poplar (Populus spp.) 1000 m 3 + + + + + + + + + + + + + + + + + + + + + + + + ex 44.07.99 of which: Birch (Betula spp.) 1000 m Light blue cells are requested only for EU members using the Combined Nomenclature to fill in - other countries are welcome to do so if their trade classification nomenclature permits "ex" codes indicate that only part of that trade classication code is used + + + denotes data not available. UK 19 May 2016 Name of Official responsible for reply: Official Address (in full): IFOS-Statistics, Forest Research, 231 Corstorphine Road, Edinburgh EH12 7AT, UK + 44 300 067 5236 Telephone: Fax: E-mail: sheila.ward@forestry.gsi.gov.uk | | | I M P O R T | E X P O R T | |------|------|---------------|---------------| | 2014 | 2015 | 2014 | 2015 | UK Country: Date: 19 May 2016 Name of Official responsible for reply: Sheila Ward ## Eu1 FOREST SECTOR QUESTIONNAIRE Official Address (in full): IFOS-Statistics, Forest Research, 231 Corstorphine Road, Edinburgh EH12 7AT, UK Trade with countries outside EU Telephone: + 44 300 067 5236 Fax: E-mail: sheila.ward@forestry.gsi.gov.uk 1000 UK £ (Sterling) | I M P O R T | E X P O R T | |------------------------------------------|---------------| | Product | | | | | | Unit of | | | 2014 | 2014 | | code | Product | | quantity | | | | | | | | | Quantity | Value | | 1 | | | ROUNDWOOD | | | 1000 m | | | 3 | | | 33 | 6,143 | | 1.1 | | | WOOD FUEL, INCLUDING WOOD FOR CHARCOAL | | | 1000 m | | | 3 | | | 25 | 2,818 | | 1.2 | | | INDUSTRIAL ROUNDWOOD (WOOD IN THE ROUGH) | | | 1000 m | | | 3 | | | 9 | 3,325 | | 1.2.C | | | Coniferous | | | 1000 m | | | 3 | | | 2 | 478 | | 1.2.NC | | | Non-Coniferous | | | 1000 m | | | 3 | | | 7 | 2,847 | | 1.2.NC.T | | | of which: Tropical | | | 1000 m | | | 3 | | | 3 | 1,244 | | 2 | | | WOOD CHARCOAL | | | 1000 mt | 80 | | 3 | | | CO-PRODUCTS / CHIPS, PARTICLES, RESIDUES | | | 1000 m | | | 3 | | | 0 | 206 | | 3.1 | | | Chips and particles | | | 1000 m | | | 3 | | | 0 | 206 | | 3.2 | | | Residues including wood for agglomerates | | | 1000 m | | | 3 | | | 0 | 0 | | 4 | | | WOOD PELLETS AND OTHER AGGLOMERATES | | | 1000 mt | 3,789 | | 4.1 | | | Wood pellets | | | 1000 mt | 3,789 | | 4.2 | | | Other agglomerates | | | 1000 mt | 0 | | 5 | | | SAWNWOOD | | | 1000 m | | | 3 | | | 695 | 245,569 | | 5.C | | | Coniferous | | | 1000 m | | | 3 | | | 452 | 96,744 | | 5.NC | | | Non-Coniferous | | | 1000 m | | | 3 | | | 243 | 148,825 | | 5.NC.T | | | of which: Tropical | | | 1000 m | | | 3 | | | 92 | 51,516 | | 6 | | | WOOD-BASED PANELS | | | 1000 m | | | 3 | | | 1,156 | 335,404 | | 6.1 | | | VENEER SHEETS | | | 1000 m | | | 3 | | | 3 | 14,433 | | 6.1.C | | | Coniferous | | | 1000 m | | | 3 | | | 0 | 574 | | 6.1.NC | | | Non-Coniferous | | | 1000 m | | | 3 | | | 3 | 13,859 | | 6.1.NC.T | | | of which: Tropical | | | 1000 m | | | 3 | | | 0 | 740 | | 6.2 | | | PLYWOOD | | | 1000 m | | | 3 | | | 1,114 | 304,775 | | 6.2.C | | | Coniferous | | | 1000 m | | | 3 | | | 393 | 90,827 | | 6.2.NC | | | Non-Coniferous | | | 1000 m | | | 3 | | | 721 | 213,948 | | 6.2.NC.T | | | of which: Tropical | | | 1000 m | | | 3 | | | 65 | 23,739 | | 6.3 | | | PARTICLE BOARD, OSB and OTHERS | | | 1000 m | | | 3 | | | 3 | 2,158 | | 6.3.1 | | | of which: OSB | | | 1000 m | | | 3 | | | 1 | 253 | | 6.4 | | | FIBREBOARD | | | 1000 m | | | 3 | | | 36 | 14,038 | | 6.4.1 | | | HARDBOARD | | | 1000 m | | | 3 | | | 7 | 4,232 | | 6.4.2 | | | MDF (MEDIUM DENSITY) | | | 1000 m | | | 3 | | | 14 | 5,506 | | 6.4.3 | | | OTHER FIBREBOARD | | | 1000 m | | | 3 | | | 15 | 4,300 | | 7 | | | WOOD PULP | | | 1000 mt | 503 | | 7.1 | | | MECHANICAL | | | 1000 mt | 0 | | 7.2 | | | SEMI-CHEMICAL | | | 1000 mt | 0 | | 7.3 | | | CHEMICAL | | | 1000 mt | 461 | | 7.3.1 | | | SULPHATE UNBLEACHED | | | 1000 mt | 3 | | 7.3.2 | | | SULPHATE BLEACHED | | | 1000 mt | 458 | | 7.3.3 | | | SULPHITE UNBLEACHED | | | 1000 mt | 0 | | 7.3.4 | | | SULPHITE BLEACHED | | | 1000 mt | 0 | | 7.4 | | | DISSOLVING GRADES | | | 1000 mt | 41 | | 8 | | | OTHER PULP | | | 1000 mt | 14 | | 8.1 | | | PULP FROM FIBRES OTHER THAN WOOD | | | 1000 mt | 13 | | 8.2 | | | RECOVERED FIBRE PULP | | | 1000 mt | 1 | | 9 | | | RECOVERED PAPER | | | 1000 mt | 4 | | 10 | | | PAPER AND PAPERBOARD | | | 1000 mt | 1,144 | | 10.1 | | | GRAPHIC PAPERS | | | 1000 mt | 659 | | 10.1.1 | | | NEWSPRINT | | | 1000 mt | 348 | | 10.1.2 | | | UNCOATED MECHANICAL | | | 1000 mt | 71 | | 10.1.3 | | | UNCOATED WOODFREE | | | 1000 mt | 193 | | 10.1.4 | | | COATED PAPERS | | | 1000 mt | 48 | | 10.2 | | | SANITARY AND HOUSEHOLD PAPERS | | | 1000 mt | 120 | | 10.3 | | | PACKAGING MATERIALS | | | 1000 mt | 347 | | 10.3.1 | | | CASE MATERIALS | | | 1000 mt | 106 | | 10.3.2 | | | CARTONBOARD | | | 1000 mt | 164 | | 10.3.3 | | | WRAPPING PAPERS | | | 1000 mt | 74 | | 10.3.4 | | | OTHER PAPERS MAINLY FOR PACKAGING | | | 1000 mt | 3 | | 10.4 | | | OTHER PAPER AND PAPERBOARD N.E.S. | | | 1000 mt | 17 | Country: UK Date: 19 May 2016 Name of Official responsible for reply: Sheila Ward Official Address (in full): IFOS-Statistics, Forest Research, 231 Corstorphine Road, Edinburgh EH12 7AT, UK Phone/Fax: + 44 300 067 5236 E-mail: sheila.ward@forestry.gsi.gov.uk ## Eu2 Forest Sector Questionnaire Removals By Type Of Ownership Product Unit 2014 2015 Ownership code Quantity Quantity ROUNDWOOD REMOVALS (under bark) 3 11,184 10,550 1 ROUNDWOOD 1000 m 3 10,719 10,088 1.C Coniferous 1000 m 3 466 462 1.NC Non-coniferous 1000 m 3 4,874 4,725 State forests 1000 m 3 4,812 4,661 Coniferous 1000 m 3 62 65 Non-coniferous 1000 m 3 + + + + + + Other publicly owned forests 1000 m 3 + + + + + + Coniferous 1000 m 3 + + + + + + Non-coniferous 1000 m 3 6,310 5,825 Private forest 1000 m 3 5,907 5,428 Coniferous 1000 m 3 403 397 Non-coniferous 1000 m ## Note: - Ownership categories correspond to those of the TBFRA. State forests: Forests owned by national, state and regional governments, or government-owned corporations; Crown forests. Other publicly owned forests: Forests belonging to cities, municipalities, villages and communes. Private forests: Forests owned by individuals, co-operatives, enterprises and industries and other private institutions. - The unit should be solid cubic metres, under bark. + + + denotes data not available. ## The Following Factors Have Been Used To Convert Between Cubic Metres (M3) And Metric Tonnes: Product m3 / tonne Fuelwood, including wood for charcoal 1.38 Wood chips, sawdust, etc 1.48 Industrial roundwood (wood in the rough) - softwood 1.43 Industrial roundwood (wood in the rough) - hardwood 1.25 Sawnwood - softwood 1.82 Sawnwood - hardwood 1.43 Veneer sheets 1.33 Plywood, particleboard 1.54 Hardboard 1.053 MDF (medium density fibreboard) 1.667 Insulating board - density 0.35-0.5 g/cm3 1.667 Insulating board - other 4 Codes for the JQ2 and EU1, EU and EFTA countries ## Joint Forest Sector Questionnaire C l a s s i f i c a t i o n s Product Product Code HS2007 CN 2012 CN 2013 CN 2011 HS2012 1 ROUNDWOOD 44.01.10 44.03.20/40/90 1.1 WOOD FUEL, INCLUDING WOOD FOR CHARCOAL 44.01.10 1.2 INDUSTRIAL ROUNDWOOD (WOOD IN THE ROUGH) 44.03.20/40/90 1.2.C Coniferous 44.03.20 1.2.NC Non-Coniferous (Eurostat to attribute all of 440399.95 to 1.2.NC) 44.03.40/90 1.2.NC.T of which:Tropical ex440399.95 44.03.41/49 44.03.40 ex440399 2 WOOD CHARCOAL 44.02.90 440120 440139.10 440120 ex440130 44.01.20 ex44.01.39 44.01.20 ex44.01.30 3 CO-PRODUCTS / CHIPS, PARTICLES, RESIDUES 440120 440139.30 440139.80 3.1 Chips and particles 440121/22 440121/22 44.01.21/22 3.2 Residues including wood for agglomerates 440139.30 440139.80 440139.10 ex440130 ex44.01.39 ex44.01.39 4 WOOD PELLETS AND OTHER AGGLOMERATES 440131.00 440139.20 440131.00 ex440139.90 440130.20 ex440130.80 44.01.31 ex44.01.39 4.1 Wood pellets 440131.00 440130.20 44.01.31 44.01.30 4.2 Other agglomerates 440139.20 ex440139.90 ex440130.80 ex44.01.39 5 SAWNWOOD 44.07 5.C Coniferous 44.07.10 5.NC Non-Coniferous 44.07.20/90 5.NC.T of which:Tropical 440799.96 44.07.20 ex44.07.99 6 WOOD-BASED PANELS 44.08 44.10 44.11 44.12.30/90 6.1 VENEER SHEETS 44.08 6.1.C Coniferous 44.08.10 6.1.NC Non-Coniferous (Eurostat to attribute all of 440890 to 6.1.NC) 44.08.30/90 6.1.NC.T of which:Tropical ex440890 44.08.30 ex44.08.90 6.2 PLYWOOD 44.12.30/90 44.12.39 ex44.12.90 6.2.C Coniferous 441239.00; 441294.90; 441299.85 44.12.31/32 ex44.12.90 6.2.NC Non-Coniferous 441231.10 and 441231.90; 441232.10; 441232.90; 441294.10; 441299.30; 441299.40; 441299.50 44.12.31 ex44.12.32 ex44.12.90 6.2.NC.T of which:Tropical 441231.10 and 441231.90; 441232.90; 441299.50 6.3 PARTICLE BOARD, OSB and OTHERS 44.10 6.3.1 of which: OSB 44.10.12 6.4 FIBREBOARD 44.11 6.4.1 HARDBOARD 44.11.92 6.4.2 MDF (Medium Density) 44.11.10 6.4.3 OTHER FIBREBOARD 44.11.93/94 7 WOOD PULP 47.01 47.02 47.03 47.04 47.05 7.1 MECHANICAL 47.01 7.2 SEMI-CHEMICAL 47.05 7.3 CHEMICAL 47.03 47.04 7.3.1 SULPHATE UNBLEACHED 47.03.10 7.3.2 SULPHATE BLEACHED 47.03.20 7.3.3 SULPHITE UNBLEACHED 47.04.10 7.3.4 SULPHITE BLEACHED 47.04.20 7.4 DISSOLVING GRADES 47.02 8 OTHER PULP 47.06 8.1 PULP FROM FIBRES OTHER THAN WOOD 47.06.10/30/90 8.2 RECOVERED FIBRE PULP 47.06.20 9 RECOVERED PAPER 47.07 10 PAPER AND PAPERBOARD 48.01/02/03/04/05/06/08/09/10 48.11.50 48.12/13 10.1 GRAPHIC PAPERS 48.01 48.02.10/20/50/60 48.09 48.10.10/20 10.1.1 NEWSPRINT 48.01 10.1.2 UNCOATED MECHANICAL 48.02.60 10.1.3 UNCOATED WOODFREE 48.02.10/20/50 10.1.4 COATED PAPERS 48.09 48.10.10/20 10.2 SANITARY AND HOUSEHOLD PAPERS 48.03 10.3 PACKAGING MATERIALS 48.04.10/20/30/42/49/50 48.05.10/20/30/90 48.06.10/20/40 48.08 48.10.30/90 48.11.50 10.3.1 CASE MATERIALS 48.04.10 48.05.10/20/91 10.3.2 CARTONBOARD 48.04.42/49/50 48.05.92 48.10.32/39/92 48.11.50 10.3.3 WRAPPING PAPERS 48.04.20/30 48.05.30 48.06.10/20/40 48.08 48.10.31/99 10.3.4 OTHER PAPERS MAINLY FOR PACKAGING 48.05.93 10.4 OTHER PAPER AND PAPERBOARD N.E.S 480441.98 48.02.40 48.04.41 48.05.40/50 48.06.30 48.12/13 HS: The Harmonised Commodity Description and Coding Systems, a multipurpose international product nomenclature developed by the World Customs Organization (WCO), comprises up to six digits and is updated every 4 - 6 years. CN: The Combined Nomenclature of the EU is identical to the HS on the first six digits and comprises two extra digits, making it more detailed than the HS. It is updated and published every year. How to interpret the notation: The dots are used for readability and have no meaning. A code ending in " 0" means that all subcodes are to be included, e.g. 47.03.10 includes subcodes 47.03.11 and 47.03.19. If only 4 digits are indicated, all subcodes are included, e.g. 47.06 includes 47.06.10, 47.06.20, 47.06.30, and 47.06.90. Code numbers separated by " /" mean that all the following codes ending in the digits indicated (and their subcodes) are to be included. The term " ex" means that only part of the data available under a code is usable because the code encompasses a wider product range. For instance, " ex44.07.99" under " Sawnwood - of which tropical" means that only part of the data under HS-code 44.07.99 is usable, because insufficient detail is available. However, the table shows that CN code 440799.96 is sufficiently detailed to identify " Sawnwood - of which tropical" . In case even the CN is not detailed enough, bold print is used in the CN column. Many tropical timber products contain " ex" codes in the above list, since the HS explicitly recognises less than 100 tropical timber species. Species not explicitly recognised as tropical are grouped in " other" categories with non-tropical, non-coniferous timbers that are likewise not explicitly recognised by the HS (e.g. 44.07.99). Estimates of tropical timber trade totals therefore require that these " other" categories be analysed to ascertain how much of the total was sourced from tropical countries. This can only be done at country level; Eurostat produces ## Codes For The Jq3, Eu And Efta Countries JOINT FOREST SECTOR QUESTIONNAIRE Trade in Secondary Processed Wood and Paper Products CROSS REFERENCE between the HS (bold print) and the CN (normal print) C l a s s i f i c a t i o n s Code HS2007 CN 2012 HS2012 CN 2011 11 Secondary wood products 11.1 Further processed sawnwood 44.09.10 44.09.29 11.1.C Coniferous 44.09.10 11.1.NC Non-coniferous (Eurostat to attribute all of 440929 to 11.1.NC) 44.09.29 11.1.NC.T of which: Tropical ex440929 ex44.09.29 11.2 Wooden wrapping and packing equipment 44.15 44.16 11.3 Wood products for domestic/decorative use (excl. furniture) 44.14 44.19 44.20 11.4 Other manufactured wood products 44.17 44.21 11.5 Builder's joinery and carpentry of wood 44.18 94.01.60 ex 94.01.90 94.03.30/40/50/60 ex94.03.90 11.6 Wooden furniture 940190.30 (parts, of seats, of wood) 940390.30 (furniture, parts, of wood) 11.7 Prefabricated buildings 94.06 11.7.1 of which made of wood 940600.20 ex94.06 12 Secondary paper products 12.1 Composite paper and paperboard 48.07 12.2 Special coated paper 48.11.10/40/60/90 12.3 Carbon paper and copying paper, ready for use 48.16 12.4 Household and sanitary paper, ready for use 48.18 12.5 Packaging cartons, boxes, etc. 48.19 12.6 Other articles of paper or paperboard 48.14/15/17/20/21/22/23 12.6.1 of which printing & writing paper, ready for use 482390.40 ex48.23.90 12.6.2 of which articles, moulded or pressed from pulp 48.23.70 12.6.3 of which filter paper & paperboard, ready for use 48.23.20 HS: The Harmonised Commodity Description and Coding Systems, a multipurpose international product nomenclature developed by the World Customs Organization (WCO), comprises up to six digits and is updated every 4 - 6 years. CN: The Combined Nomenclature of the EU is identical to the HS on the first six digits and comprises two extra digits, making it more detailed than the HS. It is updated and published every How to interpret the notation: The dots are used for readability and have no meaning. A code ending in "0" means that all subcodes are to be included, e.g. 49.00 includes all codes from 49.01 to 49.11. If only 4 digits are indicated, all subcodes are included, e.g. 48.18 includes 48.18.10, 48.18.20, 48.18.30, 48.18.40, 48.18.50 and 48.18.90. Code numbers separated by "/" mean that all the follow ing codes ending in the digits indicated (and their subcodes) are to be included. The term "ex" means that only part of the data available under a code is usable because the code encompasses a wider product range. For instance, "ex94.06" under "Prefabricated buildings - of w hich made of w ood" means that only part of the data under HS-code 94.06 is usable, since mobile homes and prefabricated buildings of wood, iron or steel are all lumped together under that code. How ever, the table show s that the CN classification covers sufficient detail to identify "Prefabricated buildings of wood". In case even the CN is not detailed enough, bold print is used in the CN column. Many tropical timber products contain "ex" codes in the above list, since the HS explicitly recognises less than 100 tropical timber species. Species not explicitly recognised as tropical are grouped in "other" categories with non-tropical, non-coniferous timbers that are likewise not explicitly recognised by the HS. Estimates of tropical timber trade totals therefore require that these "other" categories be analysed to ascertain how much of the total was sourced from tropical countries. This can only be done at country level; Eurostat produces foreign trade data for all countries.
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## Healthy Meals In Schools: Policy Innovations Linking Agriculture, Food Systems And Nutrition This policy brief explains why a greater policy emphasis is needed on the multiple-win agenda that couples meals in schools with benefits to agriculture, education and nutrition. Evidence-based successes from diverse contexts are highlighted to illustrate what is technically feasible and economically viable. POLICY BRIEF No. 3 | November 2015 ABOUT THE GLOBAL PANEL ON AGRICULTURE AND FOOD SYSTEMS FOR NUTRITION: The Global Panel is an independent group of influential experts with a commitment to tackling global challenges in food and nutrition security. The Global Panel is working to ensure that agriculture and food systems support access to nutritious foods at every stage of life. ## Global Panel Members: John Beddington (Co-Chair), Former UK Chief Scientific Adviser John Kufuor (Co-Chair), Former President of Ghana Akinwumi Adesina, President of the African Development Bank Tom Arnold, Interim Coordinator, Scaling Up Nutrition (SUN) Movement; and Director General, Institute of International and European Affairs (IIEA) Maurício Antônio Lopes, President, Brazilian Enterprise for Agricultural Research (Embrapa) José Graziano da Silva, Director General, Food and Agricultural Organization (FAO) Mahabub Hossain, Former Executive Director, BRAC Rachel Kyte, Vice President and Special Envoy, Climate Change Group, World Bank Group; and Chair of CGIAR Fund Council Srinath Reddy, President, Public Health Foundation of India Emmy Simmons, Board Member, Partnership to Cut Hunger and Poverty in Africa/AGree Rhoda Peace Tumusiime, Commissioner for Rural Economy and Agriculture, African Union Commission © 2015 by the Global Panel on Agriculture and Food Systems for Nutrition. This report may be freely reproduced, in whole or in part, provided the original source is acknowledged. This publication is a product of the Global Panel on Agriculture and Food Systems for Nutrition, supported by the Panel Secretariat. This publication was peer-reviewed. The findings, interpretations and conclusions expressed in this work do not necessarily reflect the views of the organisations or the governments the Global Panel members represent. RECOMMENDED CITATION: Global Panel. 2015. Healthy Meals in Schools: Policy Innovations Linking Agriculture, Food Systems and Nutrition. Policy Brief. London, UK: Global Panel on Agriculture and Food Systems for Nutrition. Cover photo: WFP/Dragaj ## Executive Summary Evidence from around the world on locally-sourced school meals reveals a multiple-win opportunity for policymakers with important benefits for school achievement, employment and national economic growth. Providing nutritionally balanced school meals with complementary nutrition education and health measures can deliver improved school performance, nutrition literacy as well as employment and income in later life. The procurement of food for schools from local farming communities supports farming households and livelihoods, and promotes sustainable local markets for diverse, nutritious foods. Combined interventions can also unleash a chain of beneficial impacts that break the cycle of poverty: better child nutrition supports better education, which supports improved dietary and health choices by mothers, which in turn leads to better birth outcomes and enhanced educational success for the next generation. Many local and national governments are today implementing components of this strategy. Few, however, are integrating the different components to create multiple benefits. Achieving a multiple-win outcome requires: • School meals that are consistent with current national dietary guidelines and formulated to increase emphasis on nutritious ingredients, including vegetables, fruits, pulses and animal products, such as milk. The meals should meet a significant portion of the nutritional requirements of school-aged children. • Policies that facilitate local and regional procurement of foods for schools. • Predictable national budget allocations to support integrated activities. • An effective, inter-sectoral mechanism for managing such food programmes, which includes careful measurement and monitoring of their efficiency and of their expected educational, nutritional and agricultural outcomes. • Capacity to promote change in the actual consumption of healthy school meals and to encourage children's lifelong healthy eating habits. This involves multisector actions that link school meals with nutrition education, family and school community involvement, school gardening, and training and technical support to help schools achieve an overall healthier environment. ## Introduction Meals provided in schools offer direct benefits to the health and cognitive development of pupils and, with associated educational and health interventions, can prepare children for a lifetime of healthy nutrition. They may also encourage school enrolment for girls at critical nutritional stages, deliver broader nutritional benefits to households, and support other health-related interventions in schools. Furthermore, they can enhance local agricultural production, contributing to food and nutrition security. This policy brief examines these potential contributions and evaluates the evidence for their effectiveness. Evidence-based successes from diverse contexts are highlighted to illustrate what is technically feasible and economically viable. Particular emphasis is placed on win-win opportunities that can arise from linking school meals with local agriculture and food systems. While feeding children in school is not a new idea, recent policy innovations have expanded to focus on the delivery of *healthy* meals to children while at the same time stimulating agriculture through the procurement of food from local producers. Some countries have already made significant progress in this area. These include countries where national governments are consciously encouraging agriculture-education-nutrition synergies as part of a creative legislative agenda. In the United States, for example, the Agricultural Act passed in 2014 included provisions to improve meals in schools by increasing the use of local and regionally produced foods, coupled with hands-on learning activities such as school gardening, farm visits, culinary classes, and the integration of nutrition-related education into classroom curricula.1 In India, almost 100 million children across 265,000 schools currently have free access to a balanced and nutritious midday meal. An Indian Supreme Court Order of 2001 required the government to provide meals in all primary schools "with a minimum content of 300 calories and 8-12 grams of protein"2, and many of them are procuring local produce.3 Similarly, in Ghana, the government started supporting food procurement for schools from local farmers in 2005. That initiative now involves 4,000 schools serving over 1.6 million children. Former President John Kufuor described the farm-school relationship as a win-win policy choice which "has had a great impact on the economy of Ghana."4 There are many win-win situations in combining actions, from social protection to production. These examples from around the world illustrate the growing recognition of a potential for schools to provide and promote the consumption of healthy nutritionally balanced meals while increasing demand for local farm outputs, and supporting more efficient local food procurement and delivery systems. Most countries in the world are already providing school meals of various kinds: at least 368 million children are fed daily in schools, which represents an annual investment of roughly US$75 billion with most funding from government budgets.5, 6 However, relatively few governments have yet adopted the kind of crosssectorial design that allows for gains in several domains across the food system simultaneously. ## The Cost To Nations Of Low Education Levels And Their Link To Poor Nutrition There are enormous human and economic costs associated with malnutrition. According to the most recent Global Nutrition Report, 2.5 billion - or one in three persons on the planet - suffer from at least one form of malnutrition. Recent estimates suggest that countries in Asia and Africa lose as much as 11% of Gross National Product (GNP) due to undernutrition, ranging from around 6% in Uganda to over 16% in Ethiopia.7, 8 At the same time, large economies, such as China, already lose up to 4% of GNP to obesity.9 Up to 2.5% of India's lost economic output is ascribed to micronutrient deficiencies, such as iron deficiency anaemia.10 A large share of the costs associated with these manifestations of malnutrition derives from the effects of poor child nutrition on their education. That is, impaired physical and intellectual development of individuals at a young age can hinder a child's ability to enrol in school at the appropriate time, cause absenteeism or early drop-out due to ill-health, and prevent optimal educational attainment because of impaired long-term physical and mental development.11 This all-too-common train of events results in lower intellectual and labour productivity during adulthood, and imposes a drain on national economies.12 However, just as the effects of sub-par school attendance and performance are long-lasting, the benefits of good nutrition and effective schooling also persist. For example, reduced stunting among one year-olds is linked to big improvements in language ability and cognitive achievements once they reach the age of five, and those benefits carry over into subsequent school achievements.13, 14 A reduced rate of stunting (impaired growth) in children under two years of age is associated with higher levels of later schooling thanks to more grades completed.15 There is also huge value of education to adolescent girls, who benefit physically from not having a child at such a young age, which (coupled with greater literacy and numeracy) has advantages for nutrition through the knowledge, income and empowerment advantages accorded to more educated mothers.16 In other words, child nutrition supports better education, which supports improved dietary and health choices by mothers, which in turn leads to better birth outcomes and enhanced education for the next generation.17 ## How Schools Can Support Improved Child Nutrition The feedback loop between education and nutrition has long been recognised. Roughly 170 countries have instituted the feeding of pupils in schools during the past century, but the use of schools as a primary vehicle for policy action on nutrition has not always been widely accepted.6 While the United Nations' Millennium Development Goal Hunger Task Force argued that governments should provide "balanced school meals with locally produced foods", the cost-effectiveness of using schools as an entry point for achieving nutrition goals remained a point of debate.18 School feeding programmes have been widely used in developing countries where food aid was used in regions of food insecurity, to incentivise parents to send their children to school. Although the potential for school meals to improve nutrition was promoted during the 1980s by numerous United Nations agencies and non-governmental groups, that proposition was questioned because numerous studies were unable to demonstrate impacts of school meals on the physical growth of school-aged children.19 For example, although a Cochrane review of 18 school feeding studies found a significant improvement in weight gain,20 a different review of 16 studies in eight countries found the evidence to be mixed. This highlighted the difficulty of establishing causal links between food-based interventions, primarily based on food-provision, and nutrition outcomes for children over the age of five.21 Indeed, the 2013 Lancet series on maternal and child nutrition concluded that since data are "inconclusive for height gain", school meals cannot be universally promoted as an evidence-based intervention for tackling undernutrition.22 The apparent lack of impact on child growth (stunting) has been explained in several ways. Firstly, the target population (schoolaged children) is already too old; since most stunting occurs in the first 1,000 days from conception to a child's second birthday, interventions in school come too late to reverse prior damage done.23 Secondly, the provision of meals in schools is complex, and the endeavour may draw resources away from schools' primary objective (which is to teach children) and also result in poor quality meals being offered. Thirdly, there is potential substitution of food within poor families; since children are known to receive a meal in school their parents can sometimes reduce the food available to them when at home, or else food supplied without linked nutrition education does not generate student demand for healthier meals (either in school or at home). However, there are several important reasons why past failures to demonstrate a link between school meals and stunting should not deter policymakers from considering the potential for schools to promote both nutrition and agriculture. Recent evidence suggests that although stunting starts before the age of two, stunting reduction can still be achieved among children older than two,24 and children who subsequently recover their growth trajectory perform better in vocabulary and mathematics tests than children who remain stunted during their school years.25, 26 Indeed, a study in India showed that children whose families were affected by a severe drought suffered a decline in growth that left them stunted but where children during that time were participating in India's Midday Meals scheme their height was not compromised.27 In other words, the food in school can offset a loss of food at home. Such evidence suggests that nutritionally-balanced school meals, coupled with complementary nutrition education and health measures has the potential to contribute to either the prevention of malnutrition during periods of stress or to a resolution of pre-existing forms of malnutrition.28 ## Meals In Schools - A Long History The idea that governments can provide food in the context of a national education agenda dates back over 200 years. At the end of the 18th Century, informal school feeding programmes were established in Germany, and that model quickly spread to other European states. The first formal national programme was initiated around 1900 in the United Kingdom. It was set up by a government which had realised that recruitment of adult males into the military (in the context of the Boer war) was being compromised by poor nutrition across the working class population. It was decided that since schools had a country-wide institutional presence, they could be used to promote better health and growth of children by serving a nutritious meal each day.29 By the 1940s, most European countries were providing meals in schools as part of a broad social welfare programme. In Improvements in child growth and educational performance among previously stunted pre-schoolers may be related in part to the provision of macro and micronutrients often missing from the diets of children in low-income settings. For example, studies in the 1980s demonstrated the link between cognitive development and animal protein in countries like Kenya and Egypt, where school meals rich in meat and dairy were shown to improve the mental functions of students.32 Today, it is widely acknowledged that the provision in schools of animal source foods, such as milk, meat or yoghurt, and other foods that are lacking in the diets of poor households, can help resolve key nutrient gaps in the diet.33, 34 For example, an evaluation of US programmes pointed to evidence that participation in schoolbased meals was linked to improved dietary habits, a rise in the Healthy Eating Index for those children, and a reduced likelihood of deficiencies in vitamins C and E, as well as folate.35 Healthy meals in schools also offer nutritional benefits beyond the potential reversal of stunting effects. There is evidence that school meals integrated with complementary initiatives can have positive impacts on micronutrient status, adolescent girls' dietary adequacy, and even obesity prevention.38 For example, hookworm and roundworm infect more than 800 million people around the world.39 While in most cases the infection is asymptomatic, heavy infections can lead to iron-deficiency anaemia, which can impair learning in schools.40, 41 Some studies, including randomised control trials, have shown that deworming can be cost-effective in improving school participation rates by reducing incidence of sickness.42,43 A systematic review of 41 trials found that deworming programmes can improve haemoglobin values among individuals who were anaemic, but mainly where deworming was linked to the provision of more iron in the diets.22, 44 some instances, such as in Italy and Germany, these were supported by resources supplied through the post-war Marshall Plan.30 Today, most high-income countries are committed to providing meals through schools. Indeed, many are now turning to educational institutions as entry points to promote population-wide behaviour change relating to dietary choices in the context of the rising epidemic of obesity. The societal returns to investing in healthy meals in schools are rarely questioned these days. There is growing evidence that partnerships between schools and local farmers can have economic benefits as well.31 Many dozens of low-income countries are now adapting this model for their own contexts. In other words, while the body of evidence still needs to grow and generate consensus on the significance of findings, deworming can in some contexts contribute to the effectiveness of school feeding by removing one of the constraints to iron absorption in the form of parasites. In addition to preventing iron loss in the body, and to enhancing its absorption, supplemental iron is widely provided to school children, along with other key vitamins and minerals, in the form of micronutrient fortified foods or micronutrient powders added to meals in schools.45-48 Evidence suggests a positive impact of fortified food in school meals in mitigating various micronutrient deficiencies.45-48 Micronutrients such as iron, zinc, and iodine are critical components for the development of a child's brain.49-54 These combinations of actions highlight the importance of an integrated strategy that combines food-based approaches with other sectors of activity - education, health, trade.55 The idea of combining approaches is supported by the Framework for Action that emerged from the 2014 International Conference on Nutrition (ICN2).56 The global epidemic of childhood overweight and obesity is a new factor that brings governments to focus on the quality and composition of school meals.57 There is growing attention to the potential for schools to serve as a platform for enhancing students' knowledge, attitudes and behaviours related to improved food choices, while at the same time promoting nutrition education, school gardening and regular physical activity.58 A review of nine studies on the impact of school meals on weight in low-income countries found that children eating at school gained an average of 0.7kg over a year, compared with control groups.20 This is a good outcome if the school population served is generally underweight and if such children come from chronically food insecure households. That said, where a population is not underweight, there is potential for unhealthy meals to contribute to a rising prevalence of overweight among children. The key in such contexts is to ensure that any weight gain is not contributing to fat accumulation and supporting further obesity. Evidence from high-income countries suggests that the provision of healthy meals in schools does have the potential to mitigate rising rates of overweight among children where attention to meal quality is effectively integrated with nutrition education and physical activity.38, 58 Recent data from a low-income country setting suggests that meals in school may actually improve the lean muscle mass growth of pupils.59 Partnerships between schools and the food system stakeholders surrounding those schools may be a way to increase coverage in marginalised locations where services remain scarce and of low quality. In many countries, large numbers of school-aged children are not and have never been enrolled in school. For example, in Mali only 40% of primary school-age children are enrolled because access to school in remote food insecure areas is still challenging.60 In such contexts, the provision of food represents an effective incentive for parents to send their children (especially girls) to school when they could otherwise be doing economically-valued tasks at home. Studies across 32 African countries showed absolute enrolment by girls increased by 28% during the year after meals were made available, which highlights the importance of gendersensitive nutrition education.61 Similarly, public investments in local agriculture (to improve food supply and reduce poverty) can be supported through increased and sustained demand generated by local school systems - a win-win opportunity. ## Food In School Settings - Many Options There are three main approaches to providing food through schools: 1. In-school meals, in the form of breakfast or lunch; 2. Snacks eaten in school, such as high-energy vitamin and mineral fortified biscuits, fruits, milk or juice; 3. Take-home rations provided to families of school children. Strong evidence supports the impact of take-home rations in Burkina Faso on younger siblings of beneficiaries given through intra-household food reallocation.36 Similarly, the mothers of young girls enrolled in a take-home rations programme in Uganda had significantly lower anaemia rates than a control group.37 In both cases, food provision was conditional on a child's attendance in school. Healthy meals in schools should be designed to meet a significant portion of the nutritional requirements of school-aged children, ensuring appropriate micronutrient and protein content. At the same time, attention must be paid to limiting the level of meal ingredients that are associated with poor health and nutrition outcomes, including sugar, ultra-processed grains, trans-fats and salt. It is also important that meals are served in a clean environment with clean water and necessary facilities for sanitation and hygiene. ## Schools Supporting Agriculture The role of schools in supporting and understanding agricultural practices has long been promoted through school gardening activities.62 These can contribute to an understanding of farming and nutrition principles among students, supplement fresh produce to school canteens in key seasons, and encourage the development of home gardens.63 However, the potential for food procurement by schools reaches far beyond the garden. For example, a study of school food procurement activities in the United Kingdom estimated a three-fold return on investment, in the form of positive social, economic and environmental gains.64 Therefore, there is enormous scope for programmes in lowincome countries to purchase and use locally produced food. Local farmers and producers can benefit by a stable demand for their products throughout most of the agricultural season. Communities benefit from a steady demand of products throughout seasons supporting the future farmers' investment decisions and productivity. The benefits tend to be greater for smallholders who do not have access to international markets and rely on local demand.65, 66 Such programmes have been implemented in various sub-Saharan countries (Ghana, Kenya, Malawi, Nigeria, Cote d'Ivoire, and Mali), South America (Brazil and Chile), and in many developed countries. This is because there is a growing amount of information relevant to assessing the cost-effectiveness of the range of modalities for providing food in schools.67 For example, a recent review of programmes in 22 low-income countries found the annual cost of regular school meals (200 days per year) averaged US$54 per child,68 while another review of three randomised control trials found an average cost to achieve a gain of 1cm in height per year among children in schools stood at roughly US$195.69 While the potential benefits for the pupils and for farmers are clear, the institutionalisation of such programmes requires a strong and sustained emphasis on a) ensuring a clear understanding on the part of schools, parents and farmers of each other's responsibilities, codified in binding contracts, b) setting and maintaining minimum nutritional standards, c) maintaining a dependable supply of food to schools (which requires productivity gains and a minimisation of post-harvest losses), d) ensuring food safety through effective monitoring of produce quality, e) preventing undue price volatility, and f) ensuring clean water and sanitation to all schools whether they use kitchens or only provide snacks.70 Given the potential complexity and scale of local food procurement activities, policymakers are still assessing the possible value of the spill-overs and trade-offs that such programmes can provide along the food chain71 and how policies and legal frameworks can support them.72 Existing evidence suggests that the type of procurement model used and the scale of local purchases will largely determine the magnitude of benefits to both producers and consumers, and how economic benefits are distributed among producers and other supply chain actors.73 One simulation analysis from Kenya suggests that the annual income of farmers would see a net increase of around US$50 per year if schools were to purchase maize from them, rather than relying on national stocks or food aid.10 ## Schools Supporting Food Value Chains While farmers gain the principal economic benefits of local procurement for schools, the benefits to local communities may also include job creation in support of food delivery and preparation of schools meals, as well as at points in the value chain where valueadded is generated. In Chile and Brazil, for example, national policy allows for different mechanisms for decentralisation of school meals procurement and delivery involving the private sector.72 In many cases school directors purchase directly from farmer's associations and the municipalities provide logistical support for food delivery. Similarly, India's state of Rajasthan has put small and medium enterprises in charge of procurement of food for school meals.70 Additional food system activity that can be promoted includes the establishment and maintenance of local storage facilities (which most schools do not have a priori) and the procurement of domestically-produced micronutrient fortified products. In India, for example, fortified processed foods, such as factory-produced Indiamix (a micronutrient fortified maize-soy mix used to make porridge) or fortified rice-lentil mixes made by local women's groups, have been procured by state and local governments for use in primary school systems for many years.74-76 In Malawi, about 35% of school-going children benefit from a school meal program, and over 95% of such programmes are based on the direct supply of this fortified blended flour to the schools.77 Indeed, the potential for schools to procure locally-processed and packaged nutrient value-added foods continues to grow. For instance, it has been noted that rural middle-income consumers in East and Southern Africa already purchase between 60-80% of their food, of which processed foods, mainly produced locally, account for 70-80% of total food expenditure.78 The already large and growing volume of in-country food processing represents an opportunity for schools to procure easily handled and prepared products as part of their food provision activity. ## An Investment With High Returns Since schools represent country-wide institutional presences they tend to be accessible to people who obtain few other public services. This advantage accords schools an unparalleled potential for reaching underserved populations with inputs and knowledge that together support human capital in the form of well-nourished, educated children. One recommendation of the Framework for Action was that school feeding programmes should be used "to improve diets", nutrition knowledge and practices of vulnerable populations through "better access to food […] which is nutritionally adequate."56 That recommendation embeds schools in a social protection agenda, and the stipulation that school meals should be supportive of "healthy diets" links them to food system strategies. In other words, governments have come to recognise that "schools provide an opportunity, so far untapped […] for prevention and treatment of under-nutrition or obesity."67 The provision of healthy meals goes beyond educational goals. Healthier meals support the enrolment of children (including girls), improved attention span, enhanced performance, and appropriate behaviours relating to food choices and physical exercise that can last beyond the classroom.79 The resulting increases in human capital can boost both individual and national productivity, which is the engine of social and economic growth. Studies in the US have demonstrated that changed food choices and behaviours in schools have positive spill-overs into the community that include economic gains.38, 80 A recent report from the Union of Concerned Scientists found that requirements for healthier meals in US schools can have lasting economic benefits, both through local production procurement and through reduced cost of dealing with diet-related chronic diseases.31 There is, in addition, growing evidence on the cost-effectiveness of meal provision from developing countries. However, more than 80% of such programmes in low-income countries are currently funded by external donors.81 In other words, few developing country governments have yet assumed responsibility for the budgets needed to fund conventional school meals, and fewer still have committed to providing healthy meals based on local procurement of food. The evidence reported here suggests that many more national authorities should consider this policy option. As for any policy intervention, targeting beneficiaries is critical for the success of the programme, both in the implementation and impact delivered. Synergies among different domains could either be strongly enhanced or diminished depending on the effectiveness of targeting. Targeted areas must be selected by hard evidence and needs, rather than political interests. Moreover, while multiple-win strategies can be optimal in some settings, it may not be for others - for example in areas which are drought-prone or otherwise very challenging with regards to food-security. In some cases where more reliable supply of food for school meals would be provided by non-local sources, these may be preferred compared to local procurement and would still yield the benefits to children and their families. The additional benefits of local supply should not be considered necessary to motivate school-feeding in itself, as it may be that in some cases the most disadvantaged areas are the ones in which these synergies are more difficult to achieve. ## Recommendations To Policymakers The Global Panel Therefore Recommends That Policymakers: 1. Define a national policy goal to revise and update the nutritional standards for school meals, which should be consistent with national dietary guidelines: Policymakers should make 'healthy meals' a minimum requirement for all food programmes in schools, and use this requirement to promote ancillary nutrition education, physical activity and behaviour change activities. 2. Link the provision of healthy school meals with clear nutrition promotion and education objectives and activities in order to promote healthy eating habits while avoiding the double burden of malnutrition: Policymakers should review Education Curricula to incorporate nutrition education principles, while adopting practical teaching tools such as school gardens and cooking lessons, and providing technical support to help schools implement the changes. 3. Establish a policy regimen that would promote local and regional procurement of foods for meals in schools: Policymakers should establish the legislative or regulatory framework that would permit effective food procurement systems, giving priority to local procurement from smallholder farmers when possible. The framework should be streamlined with the needs of the Ministry of Education and existing interventions to support agricultural output. 4. Promote cost-effective operations that link local procurement with healthy meal provision in schools: This includes that capital budgets should be established, appropriate contractual arrangements should be defined, price bands should be established for all food categories, training plans should be elaborated for Education Ministry staff relating to budget management, logistics, establishing appropriate storage and canteen facilities, etc. 5. Review supply of locally-available processed foods that could be incorporated within procurement systems for meals in schools: This involves that nutritional standards should be defined, price bands should be established and appropriate waste disposal (of packaging) should be organised. 6. Target beneficiaries, specify goals, and measure progress: Data are needed to target areas where malnutrition is most acute and school feeding can be implemented. In cases where multi-domain synergies are possible, the linking of healthy meals in schools with promotion of local agriculture and value-chain development also requires multi-sector data collection systems that can track the cost-effective use of resources.67 This requires the integrated monitoring of food prices, school enrolment and retention by gender, educational attainment, student and teachers' nutrition knowledge, jobs created along the value-chain, food firms contributing to the healthy meals agenda, and numbers of farmers engaged in supplying food.68, 81, 82 7. Make food and nutrition education part of school staff training: Where schools are used as an institutional platform for delivering healthy meals and knowledge surrounding agriculture, healthy food choices and nutrition, food and nutrition pre-service training should be included in core staff and teacher training in order to facilitate the inclusion of these subjects as part of the educational agenda. 8. Ensure a supportive nutrition and health school environment: Integrated policies are needed to support healthy eating by students. These should include avoiding the provision of food and beverages in school grounds that are high in sugar, trans-fats and salt. Appropriate hand washing, personal hygiene and sanitation facilities are an essential component of this agenda. 9. Establish effective indicators to measure the implementation and nutritional impact of healthy school meals: These Indicators must be appropriate to evaluate the adoption of healthier choices made by children, including water intake. In seeking ways to address the global epidemic of unhealthy diets, a recent Lancet Commission on Women and Health for Sustainable Development defined the promotion of "healthy eating in schools" as one of a core set of "best buys that are highly cost effective, inexpensive and feasible".83 Policymakers around the world should actively consider how to capture the potential benefits offered by schools as platforms for promoting healthy diets among their children. ## References 1. United States Government, Agricultural Act of 2014, in *H.R.2642.* 2014: Washington DC (USA). 16. Smith, L.C. and L. Haddad, Reducing child undernutrition: Past drivers and priorities for the post-mdg era. World Development, 2015. 68: p. 180-204. 2. Supreme Court of India, Mid-day meals: Supreme court orders. 2001: New Delhi (India). 3. Ministry of Human Resource Development (Government of India). About the mid day meal scheme. 2014 May 2015]; Available from: http://mdm.nic.in/aboutus.html. 17. 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Taylor-Robinson, D.C., et al., Deworming drugs for soil-transmitted intestinal worms in children: Effects on nutritional indicators, haemoglobin and school performance. Cochrane Database of Systematic Reviews, 2012(7). 56. FAO and WHO. Conference outcome document: Framework for action, in Second International Conference on Nutrition. 2014. Rome (Italy). 44. Taylor-Robinson, D.C., et al., Deworming drugs for soil-transmitted intestinal worms in children: Effects on nutritional indicators, haemoglobin and school performance. Cochrane Database of Systematic Reviews, 2012(11). 57. Aliyar, R., A. Gelli, and S. Hamdani, A review of nutritional guidelines and menu compositions for school feeding programs in 12 countries. Partnership for Child Development: London (UK). 45. Aaron, G.J., et al., A multi-micronutrient beverage enhances the vitamin a and zinc status of nigerian primary schoolchildren. Journal of Nutrition, 2011. 141(8): p. 1565- 1572. 58. Waters, E., et al., Interventions for preventing obesity in children (review). Cochrane collaboration, 2011(12): p. 1-212. 46. Goyle, A. and S. Prakash, Effect of supplementation of micronutrient fortified biscuits on serum total proteins and vitamin a levels of adolescent girls (10-16 years) of jaipur city, india. Nutrition and Food Science, 2011. 40(5): p. 477-484. 59. Nkhoma, O.W., et al., Early-stage primary school children attending a school in the malawian school feeding program (sfp) have better reversal learning and lean muscle mass growth than those attending a non-sfp school. The Journal of Nutrition, 2013. 143(8): p. 1324- 1330. 47. Best, C., et al., Can multi-micronutrient food fortification improve the micronutrient status, growth, health, and cognition of schoolchildren? A systematic review. Nutrition Reviews, 2011. 69(4): p. 186-204. 48. Finkelstein, J.L., et al., A randomized trial of iron-biofortified pearl millet in school children in india. Journal of Nutrition, 2015. 145(7): p. 1576-81. 60. Gelli, A., et al., Agriculture, nutrition and education: On the status and determinants of primary schooling in rural mali before the crises of 2012. International Journal of Educational Development, 2014. 39: p. 215-225. 61. Gelli, A., U. Meir, and F. Espejo, Does provision of food in school increase girls' enrollment? Evidence from schools in sub-saharan africa. Food and Nutrition Bulletin, 2007. 28(2): p. 149-155. 49. Wachs, T.D., et al., Issues in the timing of integrated early interventions: Contributions from nutrition, neuroscience, and psychological research. Every Child's Potential: Integrating Nutrition and Early Childhood Development Interventions, 2014. **1308**: p. 89-106. 62. FAO, *A new deal for school gardens.* 2010, Food and Agriculture Organization: Rome (Italy). 50. Nyaradi, A., et al., The role of nutrition in children's neurocognitive development, from pregnancy through childhood. Frontiers in Human Neuroscience, 2013. 7. 63. Robinson-O'Brien, R., M. Story, and S. Heim, Impact of garden-based youth nutrition intervention programs: A review. Journal of the American Dietetic Association, 2009. 109(2): p. 273-280. 51. Abizari, A.R., et al., School feeding contributes to micronutrient adequacy of ghanaian schoolchildren. British Journal of Nutrition, 2014. 112(6): p. 1019-1033. 64. Kersley, H. and A. Knuutila, The benefits of procuring school meals through the food for life partnership: An economic analysis. 2011, New Economics Foundation: London (UK). 52. Buttenheim, A., H. Alderman, and J. Friedman, Impact evaluation of school feeding programmes in lao people's democratic republic. Journal of Development Effectiveness, 2011. 3(4): p. 520-542. 65. Sidaner, E., D. Balaban, and L. Burlandy, The brazilian school feeding programme: An example of an integrated programme in support of food and nutrition security. Public Health Nutrition, 2013. 16(6): p. 989-994. 53. Bhagwat, S., et al., Improving the nutrition quality of the school feeding program (mid day meal) in india through fortification: A case study. Asia Pacific Journal of Clinical Nutrition, 2014. 23(1): p. 9-12. 66. WFP, Structured demand and smallholder farmers in brazil: The case of paa and pnae. 2013, UN World Food Program: Brasilia (Brazil). 54. Van Stuijvenberg, M.E., Using the school feeding system as a vehicle for micronutrient fortification: Experience from south africa. Food and Nutrition Bulletin, 2005. 26(2): p. 213-219. 67. Ruel, M.T. and H. Alderman, Nutrition-sensitive interventions and programmes: How can they help to accelerate progress in improving maternal and child nutrition? The Lancet, 2013. 382(9891): p. 536-551. 68. Gelli, A. and R. Daryanani, Are school feeding programs in low-income settings sustainable? Insights on the costs of school feeding compared with investments in primary education. Food and Nutrition Bulletin, 2013. 34(3): p. 310-317. 55. Azomahou, T.T., F. Diallo, and W. Raymond, The harmony of programs package: Quasiexperimental evidence on deworming and canteen interventions in rural senegal. 2014, United Nations University-Maastricht Economic and Social Research Institute on Innovation and Technology (MERIT): Helsinki (Finland). 69. Galloway, R., et al., School feeding: Outcomes and costs. Food and Nutrition Bulletin, 2009. 30(2). 70. Bundy, D., et al., Rethinking school feeding. Directions in Development. 2009, Washington, DC (USA): The World Bank. 71. Gelli, A., et al., A comparison of supply chains for school food: Exploring operational tradeoffs across implementation models, in HGSF Working Paper. 2012, Partnership for Child Development: London (UK). 72. PCD, *A review of policy and legal frameworks.* 2013, Partnership for Child Development: London (UK). 73. Sumberg, J. and R. Sabates-Wheeler, Linking agricultural development to school feeding in sub-saharan africa: Theoretical perspectives. Food Policy, 2011. 36(3): p. 341-349. 74. van den Briel, T. and P. Webb, Fighting world hunger through micronutrient fortification programs. Food Technology, 2003. 57(11): p. 44-47. 75. Webb, P., World food program nutrition policy papers. Food & Nutrition Bulletin, 2006. 27(1): p. 46-46. 76. Beisheim, M. and A. Liese, Transnational partnerships: Effectively providing for sustainable development? 2014: Palgrave Macmillan. 77. Nanchukwa, K. and B. Mphande, Piloting a sustainable model for home grown school meals in malawi. Nutrition Exchange, 2015(5): p. 21. 78. Tschirley, D., et al., The rise of a middle class in east and southern africa: Implications for food system transformation. Journal of International Development, 2015. 27(5): p. 608-646. 79. Folta, S.C., et al., Changes in diet and physical activity resulting from the shape up somerville community intervention. BMC Pediatrics, 2013. 13(1557). 80. Sacheck J, et al., Key strategies for improving school nutrition: A case study of three school nutrition program innovators. The Journal of Child Nutrition & Management, 2012. 36(1). 81. WFP, School feeding policy: Promoting innovation to achieve national ownership. 2013, World Food Programme: Rome (Italy). 82. Gelli, A. and F. Espejo, School feeding, moving from practice to policy: Reflections on building sustainable monitoring and evaluation systems. Public Health Nutrition, 2013. 16(6): p. 995-9. 83. Langer, A., et al., Women and health: The key for sustainable development. The Lancet, 2015. 386(9999): p. 1165-1210. ## How Can Agriculture And Food System Policies Improve Nutrition? The multiple burdens on health created today for low- and middle-income countries by food-related nutrition problems include not only persistent undernutrition and stunting, but also widespread vitamin and mineral deficiencies and growing prevalence of overweight, obesity and non-communicable diseases. These different forms of malnutrition limit people's opportunity to live healthy and productive lives, and impede the growth of economies and whole societies. The food environment from which consumers should be able to create healthy diets is influenced by four domains of economic activity: In each of these domains, there is a range of policies that can have enormous influence on nutritional outcomes. In the Global Panel's Technical Brief, we explain how these policies can influence nutrition, both positively and negatively. We make an argument for an integrated approach, drawing on policies from across these domains, and the need for more empirical evidence to identify successful approaches. ## Find Out More Here: Www.Glopan.Org/Healthy-Meals Healthy meals in schools is an example of a policy in the CONSUMER PURCHASING POWER domain that can have a positive influence on nutritional outcomes. Download *Policy Brief No. 3* here: www.glopan.org/healthy-meals Jointly funded by This report is based on research funded in part by the UK Government and the Bill & Melinda Gates Foundation. The findings and conclusions contained within are those of the authors and do not necessarily reflect positions or policies of the funders
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## Northern Ireland Food Advisory Committee The Northern Ireland Food Advisory Committee acts as an independent advisory body to the Food Standards Agency. It is chaired by the Northern Ireland Board member. Its role is to advise the Agency on food safety and standards issues, with emphasis onto Northern Ireland. ## Nifac Committee Members Colm McKenna (Chair) Aodhan O'Donnell Phelim O'Neill Dr Liz Mitchell Sara McCracken Fiona Hanna Lorraine Crawford Greg Irwin ## Meetings Meetings In 2020 15 January 2020 Meeting agenda and papers (January 2 ## Meetings In 2019 | 24 October 2019 | Meeting agenda and papers (October 2 | |-------------------|-------------------------------------------| | 24 July 2019 | Meeting agenda and papers (July 2019 | | 10 April 2019 | Meeting agenda and papers (April 2019 | | 6 March 2019 | Meeting agenda and papers (March 20 | | 2018 meetings | | | 28 November 2018 | Meeting agenda and papers (November 2018) | | 2018 meetings | | |-------------------|--------------------------------------------| | 11 September 2018 | Meeting agenda and papers (September 2018) | | 13 June 2018 | Meeting agenda and papers (June 2018) | | 7 March 2018 | Meeting agenda and papers (March 2018) | | 2017 Meetings | | | 29 November 2017 | Meeting agenda and papers (November 2017) | | 13 September 2017 | Meeting agenda and papers (September 2017) | | 14 June 2017 | Meeting agenda and papers (June 2017) | | 8 March 2017 | Meeting agenda and papers (March 2017) | | 2016 Meetings | | | 16 November 2016 | Meeting agenda and papers (November 2016) | | 12 September 2016 | Meeting agenda and papers (September 2016) | | 6 July 2016 | Meeting agenda and papers (July 2016) | | 11 May 2016 | Meeting agenda and papers (May 2016) | | 9 March 2016 | Meeting agenda and papers (March 2016) | | 20 January 2016 | Meeting agenda and papers (January 2016) | Find previous meeting papers (National Archives) ## Register Your Interest If you wish to register your interest for attending any of these meetings, please email the Northern Ireland admin team with confirming the date of the meetings you would like to attend.
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RUN AT 02/08/2018 12:51:29 | Department family | Entity | Date | Expense Type | Expense area | Supplier | Transaction number | AP Amount (£) | |----------------------|---------------------------|------------|--------------------------------------------------|-------------------------------------------|--------------------------------------------------------|----------------------|-----------------| | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Clinical Other | GP FORWARD VIEW | ABBEY MEDICAL GROUP (THE) | 22926514 | 26,825.25 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Travel Booking Services | PATIENT TRANSPORT | ARRIVA TRANSPORT SOLUTIONS | 23038198 | 56,517.60 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Travel Booking Services | PATIENT TRANSPORT | ARRIVA TRANSPORT SOLUTIONS | 23038262 | 56,141.54 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | | | | | BARNBY GATE SURGERY | | | | | | | | | 23072527 | 1,668.31 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | | | | BARNBY GATE SURGERY | | | | | | | | | 23072527 | 97,804.05 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Clinical Waste | PRC DELEGATED CO-COMMISSIONING | | | | | BARNBY GATE SURGERY | | | | | | | | | 23072527 | 53.10 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | | | | | BARNBY GATE SURGERY | | | | | | | | | 23072527 | 8,194.56 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | | | | BARNBY GATE SURGERY | | | | | | | | | 23072527 | 9,873.42 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | BILSTHORPE SURGERY | 23067282 | 1,785.68 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | BILSTHORPE SURGERY | 23067282 | 28,949.10 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Clinical Waste | PRC DELEGATED CO-COMMISSIONING | BILSTHORPE SURGERY | 23067282 | 183.82 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | BILSTHORPE SURGERY | 23067282 | 7,576.30 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Other | PRC DELEGATED CO-COMMISSIONING | BILSTHORPE SURGERY | 23067282 | 398.70 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Rates | PRC DELEGATED CO-COMMISSIONING | BILSTHORPE SURGERY | 23067282 | 12,434.98 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | BILSTHORPE SURGERY | 23067282 | 3,272.20 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Independent Sector | ACUTE COMMISSIONING | BMI HEALTHCARE COLLECTIONS | 23022870 | 102,018.94 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Independent Sector - Prior Year | ACUTE COMMISSIONING | BMI HEALTHCARE COLLECTIONS | 23167385 | (45,220.59) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Independent Sector - Prior Year | ACUTE COMMISSIONING | BMI HEALTHCARE COLLECTIONS | 23212228 | 79,580.43 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Independent Sector | ACUTE COMMISSIONING | CARE UK CLINICAL SERVICES LTD | 23022880 | 34,929.85 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-Independent Sector - CQUIN | CLINICAL ASSESSMENT AND TREATMENT CENTRES | CIRCLE NOTTINGHAM LTD | 23022776 | 2,594.42 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Commercial Sector | CLINICAL ASSESSMENT AND TREATMENT CENTRES | CIRCLE NOTTINGHAM LTD | 23022776 | 153,866.67 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS GP Statutory Levy | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23072511 | (227.36) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Achievement | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23072511 | (25,760.12) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Voluntary Levy | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23072511 | (34.49) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME - GMS TPS Added Years Adj EEs | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23072511 | (307.50) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME-GMS GP Pension EEs | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23072511 | (3,491.67) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME-GMS GP Pension ERs Adjustments | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23072511 | (3,834.67) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Learn Dsblty Hlth Chk | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23083983 | 1,960.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23083983 | 1,052.26 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23083983 | 58,067.62 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PCO Locum Adop/Pat/Mat | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23083983 | 15,980.44 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Clinical Waste | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23083983 | 544.40 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23083983 | 9,091.67 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Achievement | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23083983 | 18,584.04 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23083983 | 5,861.37 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Cost of Drugs -Dispensing | PRESCRIBING | COLLINGHAM MEDICAL CENTRE | 23184686 | (47,693.92) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PrscChrgsCll&RmttdbyGPCntra | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23184686 | (3,220.80) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Cost of Drugs -Dispensing | PRESCRIBING | COLLINGHAM MEDICAL CENTRE | 23184687 | 82,269.08 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prof Fees Dispensing | PRC DELEGATED CO-COMMISSIONING | COLLINGHAM MEDICAL CENTRE | 23184687 | 15,138.56 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PrscrptnChrgsColl&RmttdbyGP | PRESCRIBING | COLLINGHAM MEDICAL CENTRE | 23184687 | 3,220.80 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Rent | ESTATES AND FACILITIES | COMMUNITY HEALTH PARTNERSHIPS LTD | 23132395 | 23,724.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Rent | RECHARGES NHS PROPERTY SERVICES LTD | COMMUNITY HEALTH PARTNERSHIPS LTD | 23132395 | 16,487.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-CQUIN | ACUTE COMMISSIONING | DERBY TEACHING HOSPITALS NHS FT | 23022818 | 1,188.81 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Baseline | ACUTE COMMISSIONING | DERBY TEACHING HOSPITALS NHS FT | 23022818 | 49,328.35 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Not For Profit | NHS 111 | DHU 111 (EAST MIDLANDS) CIC | 23022798 | 27,514.14 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Over/ Under Performance | ACUTE COMMISSIONING | DONCASTER AND BASSETLAW HOSPITALS NHS FOUNDATION TRUST | 22904998 | (168,011.00) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-CQUIN | ACUTE COMMISSIONING | DONCASTER AND BASSETLAW HOSPITALS NHS FOUNDATION TRUST | 23022896 | 3,238.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Baseline | ACUTE COMMISSIONING | DONCASTER AND BASSETLAW HOSPITALS NHS FOUNDATION TRUST | 23022896 | 270,877.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec NHS Trust-CQUIN | AMBULANCE SERVICES | EAST MIDLANDS AMBULANCE SERVICE NHS TRUST | 23022885 | 4,250.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec NHS Trust-Contract Baseline | AMBULANCE SERVICES | EAST MIDLANDS AMBULANCE SERVICE NHS TRUST | 23022885 | 339,998.00 | |----------------------------|-----------------------------|--------------|---------------------------------------------|---------------------------------------------|---------------------------------------------|------------|--------------| | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | | | | | HILL VIEW SURGERY | | | | | | | | | 23072517 | 525.10 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | | | | HILL VIEW SURGERY | | | | | | | | | 23072517 | 23,924.97 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS MPIG Correction Factor | PRC DELEGATED CO-COMMISSIONING | | | | | HILL VIEW SURGERY | | | | | | | | | 23072517 | 1,203.47 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | | | | | HILL VIEW SURGERY | | | | | | | | | 23072517 | 2,383.33 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | | | | HILL VIEW SURGERY | | | | | | | | | 23072517 | 2,490.57 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | HOUNDSFIELD SURGERY | 23072529 | 1,448.66 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | HOUNDSFIELD SURGERY | 23072529 | 32,468.99 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | HOUNDSFIELD SURGERY | 23072529 | 2,643.25 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | HOUNDSFIELD SURGERY | 23072529 | 2,540.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Cost of Drugs -Dispensing | PRESCRIBING | HOUNDSFIELD SURGERY | 23184696 | (36,610.22) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PrscChrgsCll&RmttdbyGPCntra | PRC DELEGATED CO-COMMISSIONING | HOUNDSFIELD SURGERY | 23184696 | (3,220.80) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Cost of Drugs -Dispensing | PRESCRIBING | HOUNDSFIELD SURGERY | 23184697 | 83,487.19 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prof Fees Dispensing | PRC DELEGATED CO-COMMISSIONING | HOUNDSFIELD SURGERY | 23184697 | 12,698.38 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PrscrptnChrgsColl&RmttdbyGP | PRESCRIBING | HOUNDSFIELD SURGERY | 23184697 | 3,220.80 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | | | | | LOMBARD MEDICAL CENTRE | | | | | | | | | 23072525 | 1,705.03 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | | | | LOMBARD MEDICAL CENTRE | | | | | | | | | 23072525 | 126,314.65 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS MPIG Correction Factor | PRC DELEGATED CO-COMMISSIONING | | | | | LOMBARD MEDICAL CENTRE | | | | | | | | | 23072525 | 3,276.74 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | | | | LOMBARD MEDICAL CENTRE | | | | | | | | | 23072525 | 14,608.41 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Clinical Other | GP FORWARD VIEW | LOMBARD MEDICAL CENTRE | 23089105 | 46,239.10 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | | | | | MAJOR OAK MEDICAL PRACTICE | | | | | | | | | 23072519 | 2,538.67 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | | | | MAJOR OAK MEDICAL PRACTICE | | | | | | | | | 23072519 | 54,387.28 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Actual Rent | PRC DELEGATED CO-COMMISSIONING | | | | | MAJOR OAK MEDICAL PRACTICE | | | | | | | | | 23072519 | 9,392.69 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Clinical Waste | PRC DELEGATED CO-COMMISSIONING | | | | | MAJOR OAK MEDICAL PRACTICE | | | | | | | | | 23072519 | 44.22 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Rates | PRC DELEGATED CO-COMMISSIONING | | | | | MAJOR OAK MEDICAL PRACTICE | | | | | | | | | 23072519 | 380.00 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Water Rates | PRC DELEGATED CO-COMMISSIONING | | | | | MAJOR OAK MEDICAL PRACTICE | | | | | | | | | 23072519 | 89.99 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | | | | MAJOR OAK MEDICAL PRACTICE | | | | | | | | | 23072519 | 6,006.31 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | | | | | MIDDLETON LODGE SURGERY | | | | | | | | | 23072510 | 3,154.72 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | | | | MIDDLETON LODGE SURGERY | | | | | | | | | 23072510 | 103,584.79 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PCO Locum Adop/Pat/Mat | PRC DELEGATED CO-COMMISSIONING | | | | | MIDDLETON LODGE SURGERY | | | | | | | | | 23072510 | 2,286.12 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PCO Other | PRC DELEGATED CO-COMMISSIONING | | | | | MIDDLETON LODGE SURGERY | | | | | | | | | 23072510 | 7,763.00 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Clinical Waste | PRC DELEGATED CO-COMMISSIONING | | | | | MIDDLETON LODGE SURGERY | | | | | | | | | 23072510 | 1,198.27 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | | | | | MIDDLETON LODGE SURGERY | | | | | | | | | 23072510 | 4,483.33 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | | | | MIDDLETON LODGE SURGERY | | | | | | | | | 23072510 | 11,511.36 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Clinical Other | COMMISSIONING - NON ACUTE | NEWARK OSTEOPATHIC CLINIC | 23262540 | 64,500.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Basic Sal-Rechgs to-from Other NHS | PRIMARY CARE INVESTMENTS | NHS MANSFIELD & ASHFIELD CCG | 22860089 | 27,694.83 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | E'ers NHI-Rechgs to-from Other NHS | PRIMARY CARE INVESTMENTS | NHS MANSFIELD & ASHFIELD CCG | 22860089 | 2,697.13 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | E'ers Pen-Rechgs to-from Other NHS | PRIMARY CARE INVESTMENTS | NHS MANSFIELD & ASHFIELD CCG | 22860089 | 3,973.87 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Recharge : Provided | PRIMARY CARE INVESTMENTS | NHS MANSFIELD & ASHFIELD CCG | 22860089 | 273.38 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Basic Sal-Rechgs to-from Other NHS | Service Planning & Reform | NHS MANSFIELD & ASHFIELD CCG | 22860093 | 37,124.06 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | E'ers NHI-Rechgs to-from Other NHS | Service Planning & Reform | NHS MANSFIELD & ASHFIELD CCG | 22860093 | 4,405.52 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | E'ers Pen-Rechgs to-from Other NHS | Service Planning & Reform | NHS MANSFIELD & ASHFIELD CCG | 22860093 | 4,726.52 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Recharge : Provided | Service Planning & Reform | NHS MANSFIELD & ASHFIELD CCG | 22860093 | 41.44 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Basic Sal-Rechgs to-from Other NHS | COMMISSIONING | NHS RUSHCLIFFE CCG | 22886535 | 7,183.15 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Basic Sal-Rechgs to-from Other NHS | CONTINUING HEALTHCARE ASSESSMENT & SUPPORT | NHS RUSHCLIFFE CCG | 22886535 | 5,247.67 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Basic Sal-Rechgs to-from Other NHS | MEDICINES MANAGEMENT - CLINICAL | NHS RUSHCLIFFE CCG | 22886535 | 2,732.64 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-APMS IT Comm Servs-GP Practices | PRIMARY CARE IT | NHS RUSHCLIFFE CCG | 22886535 | 35,435.66 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS IT Comm Servs -GP Practices | PRIMARY CARE IT | NHS RUSHCLIFFE CCG | 22886535 | 42,852.42 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-PMS IT Comm Servs -GP Practices | PRIMARY CARE IT | NHS RUSHCLIFFE CCG | 22886535 | 4,120.43 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Charges from CCG | NON RECURRENT PROGRAMMES | NHS RUSHCLIFFE CCG | 22886535 | 3,348.82 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Computer Network Costs | IM&T | NHS RUSHCLIFFE CCG | 22886535 | 26,696.84 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Recharge : Received | COMMISSIONING | NHS RUSHCLIFFE CCG | 22886535 | 11.44 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Recharge : Received | CONTINUING HEALTHCARE ASSESSMENT & SUPPORT | NHS RUSHCLIFFE CCG | 22886535 | 32.93 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Independent Sector | Learning Difficulties - S117 | NHS RUSHCLIFFE CCG | 23022932 | 173,859.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Independent Sector | Mental Health Services - S117 Mental Health | NHS RUSHCLIFFE CCG | 23022932 | 116,804.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care- Adult 100% Fully Funded | CHC AD FULL FUND PERS HLTH BUD | NHS RUSHCLIFFE CCG | 23022932 | 18,007.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care- Adult 100% Fully Funded | CHC ADULT FULLY FUNDED | NHS RUSHCLIFFE CCG | 23022932 | 223,675.00 | |-------------------------|-----------------------------|--------------|-------------------------------------------------|------------------------------------------------------------|-------------------------------------------|------------|--------------| | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care- Adult Joint Funded | ADULT JOINT FUNDED CONTINUING CARE | NHS RUSHCLIFFE CCG | 23022932 | 9,773.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care- Adult Joint Funded | Adult Joint Funded Continuing Care Personal Health Budgets | NHS RUSHCLIFFE CCG | 23022932 | 4,353.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care- Children | Children's Continuing Care | NHS RUSHCLIFFE CCG | 23022932 | 32,162.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care- Children | Children's Continuing Care Personal Health Budgets | NHS RUSHCLIFFE CCG | 23022932 | 1,935.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care- Palliative Care | CHC ADULT FULLY FUNDED | NHS RUSHCLIFFE CCG | 23022932 | 36,976.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Learning Disab(65+) | ADULT JOINT FUNDED CONTINUING CARE | NHS RUSHCLIFFE CCG | 23022932 | 8,567.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Learning Disab(65+) | Adult Joint Funded Continuing Care Personal Health Budgets | NHS RUSHCLIFFE CCG | 23022932 | 5,202.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Learning Disab(<65) | ADULT JOINT FUNDED CONTINUING CARE | NHS RUSHCLIFFE CCG | 23022932 | 325,572.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Learning Disab(<65) | Adult Joint Funded Continuing Care Personal Health Budgets | NHS RUSHCLIFFE CCG | 23022932 | 1,695.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Learning Disab(<65) | CHC AD FULL FUND PERS HLTH BUD | NHS RUSHCLIFFE CCG | 23022932 | 32,552.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Learning Disab(<65) | CHC ADULT FULLY FUNDED | NHS RUSHCLIFFE CCG | 23022932 | 22,864.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Mental Health (65+) | ADULT JOINT FUNDED CONTINUING CARE | NHS RUSHCLIFFE CCG | 23022932 | 6,293.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Mental Health (65+) | CHC AD FULL FUND PERS HLTH BUD | NHS RUSHCLIFFE CCG | 23022932 | 3,538.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Mental Health (65+) | CHC ADULT FULLY FUNDED | NHS RUSHCLIFFE CCG | 23022932 | 167,127.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Mental Health (<65) | ADULT JOINT FUNDED CONTINUING CARE | NHS RUSHCLIFFE CCG | 23022932 | 10,659.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Mental Health (<65) | CHC ADULT FULLY FUNDED | NHS RUSHCLIFFE CCG | 23022932 | 33,611.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Physical Disab (65+) | ADULT JOINT FUNDED CONTINUING CARE | NHS RUSHCLIFFE CCG | 23022932 | 3,135.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Physical Disab (65+) | CHC AD FULL FUND PERS HLTH BUD | NHS RUSHCLIFFE CCG | 23022932 | 7,168.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Physical Disab (65+) | CHC ADULT FULLY FUNDED | NHS RUSHCLIFFE CCG | 23022932 | 17,781.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Physical Disab (<65) | ADULT JOINT FUNDED CONTINUING CARE | NHS RUSHCLIFFE CCG | 23022932 | 32,234.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Physical Disab (<65) | Adult Joint Funded Continuing Care Personal Health Budgets | NHS RUSHCLIFFE CCG | 23022932 | 9,639.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Physical Disab (<65) | CHC AD FULL FUND PERS HLTH BUD | NHS RUSHCLIFFE CCG | 23022932 | 37,423.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Physical Disab (<65) | CHC ADULT FULLY FUNDED | NHS RUSHCLIFFE CCG | 23022932 | 45,056.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | NHS CHC/FNC Risk-Sharing Recharge between CCGs | ADULT JOINT FUNDED CONTINUING CARE | NHS RUSHCLIFFE CCG | 23022932 | (97,373.00) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | NHS CHC/FNC Risk-Sharing Recharge between CCGs | Adult Joint Funded Continuing Care Personal Health Budgets | NHS RUSHCLIFFE CCG | 23022932 | 8,521.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | NHS CHC/FNC Risk-Sharing Recharge between CCGs | CHC AD FULL FUND PERS HLTH BUD | NHS RUSHCLIFFE CCG | 23022932 | 19,061.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | NHS CHC/FNC Risk-Sharing Recharge between CCGs | CHC ADULT FULLY FUNDED | NHS RUSHCLIFFE CCG | 23022932 | (25,493.00) | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | NHS CHC/FNC Risk-Sharing Recharge between CCGs | Children's Continuing Care | NHS RUSHCLIFFE CCG | 23022932 | 13,695.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | NHS CHC/FNC Risk-Sharing Recharge between CCGs | Children's Continuing Care Personal Health Budgets | NHS RUSHCLIFFE CCG | 23022932 | 3,559.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care- Palliative Care | CHC ADULT FULLY FUNDED | NHS RUSHCLIFFE CCG | 23022943 | 60,485.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Cont Care-Funded Nursing Care Allow | FUNDED NURSING CARE | NHS RUSHCLIFFE CCG | 23022946 | 89,248.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | NHS CHC/FNC Risk-Sharing Recharge between CCGs | FUNDED NURSING CARE | NHS RUSHCLIFFE CCG | 23022946 | 339.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec NHS Trust-CQUIN | ACUTE COMMISSIONING | NOTTINGHAM UNIVERSITY HOSPITALS NHS TRUST | 23022952 | 29,036.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec NHS Trust-Contract Baseline | ACUTE COMMISSIONING | NOTTINGHAM UNIVERSITY HOSPITALS NHS TRUST | 23022952 | 1,202,831.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-Independent Sector - CQUIN | ACUTE COMMISSIONING | NOTTINGHAM WOODTHORPE HOSPITAL | 23022842 | 492.05 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Independent Sector | ACUTE COMMISSIONING | NOTTINGHAM WOODTHORPE HOSPITAL | 23022842 | 39,363.88 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Othe Public Sector | PROGRAMME PROJECTS | NOTTINGHAMSHIRE COUNTY COUNCIL | 22893776 | 252,320.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Clinical&Medical-Othe Public Sector | COMMISSIONING - NON ACUTE | NOTTINGHAMSHIRE COUNTY COUNCIL | 23212242 | 42,941.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Cost per Case | MENTAL HEALTH SERVICES - OTHER | NOTTINGHAMSHIRE HEALTHCARE NHS TRUST | 23022761 | 28,065.30 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Baseline | COMMUNITY SERVICES | NOTTINGHAMSHIRE HEALTHCARE NHS TRUST | 23022809 | 920,636.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-CQUIN | MENTAL HEALTH CONTRACTS | NOTTINGHAMSHIRE HEALTHCARE NHS TRUST | 23022822 | 24,600.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Baseline | MENTAL HEALTH CONTRACTS | NOTTINGHAMSHIRE HEALTHCARE NHS TRUST | 23022822 | 1,019,681.92 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Non Contract | IMPROVING ACCESS TO PSYCHOLOGICAL THERAPIES | NOTTINGHAMSHIRE HEALTHCARE NHS TRUST | 23022903 | 38,678.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Cost per Case | MENTAL HEALTH CONTRACTS | NOTTINGHAMSHIRE HEALTHCARE NHS TRUST | 23074389 | 30,527.25 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Cost per Case | LEARNING DIFFICULTIES | NOTTINGHAMSHIRE HEALTHCARE NHS TRUST | 23074472 | 42,366.84 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Cost per Case | LEARNING DIFFICULTIES | NOTTINGHAMSHIRE HEALTHCARE NHS TRUST | 23074565 | 43,069.28 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Cost per Case | MENTAL HEALTH SERVICES - OTHER | NOTTINGHAMSHIRE HEALTHCARE NHS TRUST | 23074578 | 29,000.81 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-APMS Contract Value | PRC DELEGATED CO-COMMISSIONING | PRIMARY INTEGRATED COMMUNITY SERVICES LTD | 22953455 | 51,000.00 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-APMS Prem Actual Rent | PRC DELEGATED CO-COMMISSIONING | PRIMARY INTEGRATED COMMUNITY SERVICES LTD | 22953455 | 14,454.82 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-APMS Prem Clinical Waste | PRC DELEGATED CO-COMMISSIONING | PRIMARY INTEGRATED COMMUNITY SERVICES LTD | 22953455 | 82.31 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-APMS Prem Rates | PRC DELEGATED CO-COMMISSIONING | PRIMARY INTEGRATED COMMUNITY SERVICES LTD | 22953455 | 1,608.33 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-APMS Prem Water Rates | PRC DELEGATED CO-COMMISSIONING | PRIMARY INTEGRATED COMMUNITY SERVICES LTD | 22953455 | 87.91 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-PMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | PRIMARY INTEGRATED COMMUNITY SERVICES LTD | 22953455 | 3,811.48 | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | | | | | RAINWORTH HEALTH CENTRE | | | | | | | | | 23072515 | 966.46 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | | | | RAINWORTH HEALTH CENTRE | | | | | | | | | 23072515 | 48,341.45 | | | | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Actual Rent | PRC DELEGATED CO-COMMISSIONING | |------------------------------|-----------------------------|--------------|--------------------------------------------------|----------------------------------| | RAINWORTH HEALTH CENTRE | | | | | | 23072515 | 18,336.23 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Rates | PRC DELEGATED CO-COMMISSIONING | | RAINWORTH HEALTH CENTRE | | | | | | 23072515 | 1,811.89 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Water Rates | PRC DELEGATED CO-COMMISSIONING | | RAINWORTH HEALTH CENTRE | | | | | | 23072515 | 221.75 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | RAINWORTH HEALTH CENTRE | | | | | | 23072515 | 4,741.78 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME - GMS GP Prior Year ERs | PRC DELEGATED CO-COMMISSIONING | | RAINWORTH HEALTH CENTRE | | | | | | 23072515 | 36.41 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME-GMS GP Prior Year EEs | PRC DELEGATED CO-COMMISSIONING | | RAINWORTH HEALTH CENTRE | | | | | | 23072515 | 954.82 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Baseline | ACUTE COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-CQUIN | ACUTE COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Baseline | ACUTE COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Contract Baseline | COMMUNITY SERVICES | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Over/ Under Performance | ACUTE COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec Fdtn Trust-Over/ Under Performance | ACUTE COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | SHERWOOD MEDICAL PARTNERSHIP | | | | | | 23072521 | 120,992.87 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Clinical Waste | PRC DELEGATED CO-COMMISSIONING | | SHERWOOD MEDICAL PARTNERSHIP | | | | | | 23072521 | 1,825.26 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | | SHERWOOD MEDICAL PARTNERSHIP | | | | | | 23072521 | 3,583.33 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Rates | PRC DELEGATED CO-COMMISSIONING | | SHERWOOD MEDICAL PARTNERSHIP | | | | | | 23072521 | 28,728.95 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Water Rates | PRC DELEGATED CO-COMMISSIONING | | SHERWOOD MEDICAL PARTNERSHIP | | | | | | 23072521 | 1,064.80 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | SHERWOOD MEDICAL PARTNERSHIP | | | | | | 23072521 | 11,575.17 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME - GMS GP Prior Year ERs | PRC DELEGATED CO-COMMISSIONING | | SHERWOOD MEDICAL PARTNERSHIP | | | | | | 23072521 | 1,078.81 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME-GMS GP Prior Year EEs | PRC DELEGATED CO-COMMISSIONING | | SHERWOOD MEDICAL PARTNERSHIP | | | | | | 23072521 | 1,830.36 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS MPIG Correction Factor | PRC DELEGATED CO-COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Other | PRC DELEGATED CO-COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Cost of Drugs -Dispensing | PRESCRIBING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PrscChrgsCll&RmttdbyGPCntra | PRC DELEGATED CO-COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Cost of Drugs -Dispensing | PRESCRIBING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prof Fees Dispensing | PRC DELEGATED CO-COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PrscrptnChrgsColl&RmttdbyGP | PRESCRIBING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS GP Statutory Levy | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072512 | (386.57) | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Voluntary Levy | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072512 | (58.64) | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME-GMS GP Pension EEs | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072512 | (16,180.92) | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME-GMS GP Pension ERs Adjustments | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072512 | (15,298.81) | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME-GMS GP Prior Year EEs | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072512 | (116.66) | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS DES Minor Surgery | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072513 | 2,676.64 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072513 | 96,783.00 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Clinical Waste | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072513 | 1,032.56 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072513 | 16,762.17 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072513 | 9,811.54 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | ME - GMS TPS Added Years Adj EEs | PRC DELEGATED CO-COMMISSIONING | | THE ABBEY MEDICAL GROUP | | | | | | 23072513 | 814.72 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Global Sum | PRC DELEGATED CO-COMMISSIONING | | THE FOUNTAIN MEDICAL CENTRE | | | | | | 23072523 | 100,048.93 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS PCO Other | PRC DELEGATED CO-COMMISSIONING | | THE FOUNTAIN MEDICAL CENTRE | | | | | | 23072523 | 8,610.00 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Clinical Waste | PRC DELEGATED CO-COMMISSIONING | | THE FOUNTAIN MEDICAL CENTRE | | | | | | 23072523 | 511.00 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS Prem Notional Rent | PRC DELEGATED CO-COMMISSIONING | | THE FOUNTAIN MEDICAL CENTRE | | | | | | 23072523 | 6,833.33 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | C&M-GMS QOF Aspiration | PRC DELEGATED CO-COMMISSIONING | | THE FOUNTAIN MEDICAL CENTRE | | | | | | 23072523 | 11,290.04 | | | | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec NHS Trust-CQUIN | ACUTE COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec NHS Trust-Contract Baseline | ACUTE COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec NHS Trust-CQUIN | ACUTE COMMISSIONING | | Department of Health | NHS Newark & Sherwood CCG | 31/07/2018 | Hcare Srv Rec NHS Trust-Contract Baseline | ACUTE COMMISSIONING | | TOTAL | 14,430,566.05 | | | |
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## Hm Treasury Special Advisers' Quarterly Information: 1 July - 30 September 2012 GIFTS RECEIVED BY SPECIAL ADVISERS1 Rupert Harrison Date gift received From Brief Description of Gift Nil return Poppy Mitchell-Rose Date gift received From Brief Description of Gift Nil return Eleanor Shawcross Date gift received From Brief Description of Gift Nil return Ramesh Chhabra Date gift received From Brief Description of Gift Nil return William de Peyer Date gift received From Brief Description of Gift Nil return Julia Goldsworthy Date gift received From Brief Description of Gift Nil return 1 Gifts should normally be refused or returned where staff have direct involvement in decisions affecting the giver or where they are worth more than about £25. Where a gift above the £25 threshold cannot be refused or returned without damaging relations, officials should inform their Human Resources Business Partner and line manager, who will decide whether to return the gift to the official, offer the official the option of paying for it or reciprocating from their own pocket, use it for the department or otherwise dispose of it. Outcome Outcome Outcome Outcome Outcome Outcome HOSPITALITY RECEIVED BY SPECIAL ADVISERS2 Rupert Harrison Date of hospitality Name of organisation Type of hospitality received 19 July 2012 Daily Mail Lunch 23 July 2012 The Economist Lunch Lunch 21 August 2012 Daily Mail and The Times Lunch 23 August 2012 Bank of America Merrill Lynch 24 August 2012 Conservative Home Lunch 10 September 2012 The Sun Lunch 12 September 2012 BBC Lunch 13 September 2012 The Guardian Lunch 14 September 2012 The Times Lunch 26 September 2012 Barclays Dinner Poppy Mitchell-Rose Date of hospitality Name of organisation Type of hospitality received Lunch 21 August 2012 Daily Mail and The Times Eleanor Shawcross Date of hospitality Name of organisation Type of hospitality received Nil return Ramesh Chhabra Date of hospitality Name of organisation Type of hospitality received 11 July 2012 Daily Mail Lunch 21 July 2012 Sky Ticket to one day cricket international, including lunch 3 August 2012 The Telegraph Lunch 19 September 2012 The Wall Street Journal Dinner 2 Does not include normally include attendance at functions hosted by HM Government; 'diplomatic' functions in the UK or abroad, hosted by overseas governments; minor refreshments at meetings, receptions, conferences, and seminars; and offers of hospitality which were declined. * Indicates if accompanied by spouse/partner or other family member or friend. | 21 September 2012 | Thomson Reuters | Lunch | |----------------------|----------------------|---------------------| | | | | | William de Peyer | | | | Date of hospitality | Name of organisation | Type of hospitality | | received | | | | | | | | Nil return | | | | | | | | Julia Goldsworthy | | | | Date of hospitality | Name of organisation | Type of hospitality | | received | | | | | | | | 11 July 2012 | Google | Dinner | | | | | Name Purpose of Meeting ## Special Advisers' Meetings Newspaper And Other Media Proprietors, Editors And Senior Executives3 Rupert Harrison Month Of Meeting | 15 August | James Harding (The Times) | Social | |---------------------|------------------------------|-----------| | Name | Purpose of Meeting | | | | | | | Poppy Mitchell-Rose | | | | Month of | | | | Meeting | | | | Nil return | | | | | | | | Name | Purpose of Meeting | | | Eleanor Shawcross | | | | Month of | | | | Meeting | | | | Nil return | | | | | | | | Name | Purpose of Meeting | | | Ramesh Chhabra | | | | Month of | | | | Meeting | | | | Nil return | | | | | | | | Name | Purpose of Meeting | | | William de Peyer | | | | Month of | | | | Meeting | | | | Nil return | | | | | | | | Name | Purpose of Meeting | | | Julia Goldsworthy | | | | Month of | | | | Meeting | | | | Nil return | | | | | | |
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# The Forum To Oversee The Implementation Of New Hmrc Powers, Deterrents And Safeguards # Final Report On The Year 1 April 2011 To 31 December 2012 To The Exchequer Secretary To The Treasury There are three annual reports all of which are historic documents and the data has been compiled in a format specifically for the Forum at the time. HMRC will not update these reports. The final Forum meeting was on 21 February 2013. ## Review Of Hmrc'S Powers, Deterrents And Safeguards: Implementation Oversight Forum Introduction This is the third report of the Forum who met once this year which is an indication that no major issues have arisen this year. The annex to this report lists the meeting agenda and content can be accessed from the HMRC website at http://www.hmrc.gov.uk/about/implementation-oversight/imploversight-forum.htm Similar to the previous year, only two meetings were scheduled this year with one being a "virtual" meeting using email depending on issues that had arisen. No issues arose. ## Schedule 36 Finance Act 2008 Information And Inspection Powers Authorisations Certain actions must be authorised by a trained and generally more senior officer. HMRC continues to see this as an important safeguard. The overall levels of authorisations have been broadly static. ## Commentary - Total authorisations requested have reduced by approximately 15% for 2011/12 compared with 2010/11 and there is also a decrease in the proportion granted. - The balance of requests has changed. Unannounced visits rose from 907 to 1031 for 2011/12. The almost complete decline in notices for applications to the tribunal for tax related penalties and copies of third party information noted in 2010/11 remain unchanged. There have been significant reductions in the requests for daily penalties and applications for approval to issue a notice. - For the period covering April - December 2012 there has been a steady decrease from previous years comparing figures at the same point: - total authorisations: 900 (December 2012); 1049 (December 2011) and 1245 (December 2010); - authorisations granted: 865 (December 2012); 1004 (December 2011) and 1140 (December 2010); - unannounced visits: 617 (December 2012); 747 (December 2011) and 687 (December 2010). HMRC will be looking at the value of continuing to record these details going forward and they will consult the Compliance Reform Forum before any final decisions are made. Authorisations requested: 2011 and 2012 April - Dec 2012 2010/11 2011/12 Deferred 7 3 2 Granted 1526 1362 865 Pending 27 12 1 Rejected 85 37 30 Withdrawn 5 1 2 Total 1650 1415 900 Authorisations granted: 2011 and 2012 April - Dec 2012 2010/11 2011/12 Apply to tribunal for approval to issue a notice 228 64 52 Apply to tribunal for inspection 18 1 14 Apply to tribunal for tax related penalty 2 1 0 Apply to tribunal not to copy 3rd party information 4 3 12 Daily penalty 272 186 113 Identity unknown notice 11 1 0 Issue notice for documents over 6 years old 81 70 50 Obstruction of inspection penalty 1 1 0 Short notice visits (less than 7 days notice) 2 3 0 Unannounced visits 907 1031 617 Total 1526 1261 861 Authorisations rejected: 2011 and 2012 2010/11 2011/12 April - Dec 2012 Insufficient evidence 33 4 1 Non compliant with HRA 1 0 0 Not relevant or proportionate to benefit 19 11 5 Preferable alternative course of action 27 6 3 Reasonable excuse accepted 0 0 0 Unspecified 0 0 0 Total 80 21 9 Schedule 24 Finance Act 2007 Penalties for Errors During the period HMRC's Local Compliance business completed its programme to implement the recommendations of the major internal review of the operation of New Penalties which took place in 2010. Process improvements In November 2011 we made significant changes to the way in which inaccuracy penalties are authorised, to further streamline the process. The effect of this was to put decision-making into the hands of front-line managers, giving them the primary role that they wanted in ensuring consistency, setting standards and driving up quality. This means that both ownership and also accountabilities are much more clearly defined, with managers taking direct responsibility for the work of their teams as opposed to pushing issues up the management chain. We have also continued to improve and extend our new interactive IT tool, which ensures that the right actions on penalties are taken at the right times, and which enables decisions to be monitored and validated, to benefit both customers and staff. This has been welcomed by caseworkers and managers, Guidance and training In March 2012 we completed the delivery of refresher training to over 7,000 front-line staff. This has been very successful, with nearly 95% of attendees reporting that the event had met their learning needs very or quite well, and nearly 90% feeling that their confidence in using inaccuracy penalties was greatly or somewhat increased. Building on this training and our existing Tax Professional Qualifications, in 2012/13 we began using some of our most senior and experienced tax professionals to run tailored professional development events on inaccuracy penalties in local offices and business units. These provide a flexible, interactive, practically-focused means of delivering support and up to date information to managers and teams. In addition we have thoroughly reviewed and updated our guidance and factsheets. | | | | Penalties recorded 2010/11 | | |------------|--------|-----------------|------------------------------|------------| | By Regime | Cases | Inc suspensions | Suspended | Due now | | CT | 149 | 29 | £82,700 | £352,095 | | Employer | | | | | | compliance | 1,637 | 485 | £1,465,768 | £1,408,175 | | ITSA | 30,803 | 1,732 | £2,520,703 | £5,957,064 | | NIC | 452 | 1 | £73 | £31,714 | | VAT | 21,555 | 4,011 | £12,603,067 | £24,233,118 | |------------------------------------------------------------------------------------|----------|-------------------------------------------------------------------------------|----------------|---------------| | Other | 335 | 2 | £162 | £592,232 | | Total | 54,931 | 6,260 | £16,672,472 | £32,574,400 | | | | | | | | | | | | | | Penalties recorded 2011/12 | | | | | | By Regime | Cases | Inc suspensions | Suspended | Due now | | CT | 282 | 21 | £29,019 | £596,950 | | Employer | | | | | | compliance | 1,662 | 433 | £2,101,332 | £1,244,584 | | ITSA | 54,106 | 1,072 | £524,831 | £9,791,651 | | NIC | 3971 | 1 | £73 | £10,360 | | VAT | 16,453 | 3,775 | £15,248,169 | £23,230,666 | | Other | 680 | 3 | £656 | £680,079 | | Total | 77,154 | 5,305 | | | | * | | | | | | £17,904,081 | | | | | | £35,554,290 | | | | | | | | | | | | | | | | | | Penalties recorded 2012/13 - April until December 2012 | | | | | | By Regime | Cases | Inc suspensions | Suspended | Due now | | CT | 259 | 31 | £80,267 | £1,130,087 | | Employer | | | | | | compliance | | | | | | 1,097 | 432 | £2,409,698 | £3,735,173 | | | ITSA | 19,363 | 1,893 | £1,123,013 | £13,832,590 | | NIC | 85 | 1 | £243 | £19,083 | | VAT | 6,241 | 1,955 | £9,280,860 | £36,968,831 | | Other | 406 | 8 | £21,508 | £45,528,258 | | Total | 27,451 | 4,320 | | | | * | | | | | | £12,915,589 | | | | | | £101,214,022 | | | | | | * | | The disparity between these figures is accounted for by the shorter recording | | | | period for 2012/13 which does not take into account any peak activity | | | | | | approaching the end of the year. | | | | | | | | | | | | | | | | | | Penalties by behaviour 2010/11 | | | | | | | | | | | | Behaviour | | | | | | | | | | | | Cases | | | | | | | | | | | | Prompted | | | | | | | | | | | | Unprompted | | | | | | | | | | | | Deliberate + concealment | 152 | 138 | 14 | | | Deliberate | 1,112 | 656 | 456 | | | Failure to take care | 19,836 | 19,344 | 492 | | | Failure to notify under- | | | | | | assessment | | | | | | 1 | | | | | | 2,384 | 2,189 | 195 | | | | Error | 32,320 | 31,240 | 1,080 | | | Other | 2,246 | 1,604 | 642 | | | Total | 58,050 | 55,171 | 2,879 | | | The total number of Cases is greater as a case can exhibit more than one behaviour | | | | | | | | | | | | Penalties by behaviour 2011/12 | | | | | | Behaviour | | | | | | | | | | | | Cases | | | | | | | | | | | | Prompted | | | | | | | | | | | | Unprompted | | | | | | Deliberate + concealment | 164 | 157 | 7 | | 1 "Failure to notify under-assessment" is no longer a behaviour category on NPPS. | Deliberate | 1,180 | 1,031 | 149 | |------------------------------------------------------------|----------|----------|--------| | Failure to take care | 22,916 | 22,532 | 384 | | Error | 47,480 | 47,370 | 110 | | Other | 8,055 | 2,522 | 3,851 | | Total | + | | 79,795 | | | | | | | | | | | | Penalties by behaviour 2012/13 - April until December 2012 | | | | | Behaviour | | | | | | | | | | Cases | | | | | | | | | | Prompted | | | | | | | | | | Unprompted | | | | | Deliberate + concealment | 241 | 233 | 8 | | Deliberate | 1,890 | 1,724 | 166 | | Failure to take care | 22,513 | 22,378 | 135 | | Error | 1,828 | 1,813 | 15 | | Other | 2,089 | 1,355 | 133 | | Total | + | | 28,561 | +The disparity between these figures is accounted for by the shorter recording period for 2012/13 and taking out the recording of nil penalty cases. Commentary Following the introduction of Schedule 24 FA 2007 penalties for inaccuracies, we put in place a system (NPPS) to 'process' behaviour-based penalties and bring them into charge. A design feature of NPPS was that it can process penalties only for cases with a live HMRC reference. As a result, there have always been minor exceptions (Certain VAT work involving overseas entities) that could not be processed via NPPS. NPPS was designed essentially as a processing system, (rather than a management information system), and has been used as a central source of data relating to behaviour-based penalties. A recent HMRC sample comparison of cases referred to the Managing Deliberate Defaulters regime with entries on NPPS has brought to light a previously unknown problem. Because NPPS is essentially a system for processing penalties and bringing them into charge, some direct tax cases concluded by 'contract settlement' in which 'FTRC' and/or 'deliberate' penalties were incurred, have not been recorded on NPPS, because it was incorrectly supposed that this was unnecessary as the penalty had effectively already been brought into charge. Whilst correcting the misunderstanding in relation to contract settlements and NPPS, going forward (and the minor exceptions aside) NPPS will record all behaviour-based penalties; we are also undertaking a more fundamental review of our management information requirements in relation to penalties. The Internal Review Process figures for 2011/12 can be found at the following link: http://www.hmrc.gov.uk/complaints-appeals/news.htm] Annex A: 2011/12 Meetings: http://www.hmrc.gov.uk/about/implementation-oversight/impl-oversight- forum.htm Meeting 29 May 2012 1. Reasonable Excuse update 2. PAYE Late Payment Penalties update 3. Schedule 55 late filing penalties update: presentation 4. Inaccuracy Penalties update ## Meeting 21 February 2013 1. Inaccuracy Penalties update 2. Third Report: Implementation Oversight Forum 3. Future of the Implementation Oversight Forum Annex B: Future of the Implementation Oversight Forum At the Implementation Oversight Forum meeting on 21 February 2013, it was agreed to close this Forum. This follows Dave Hartnett's retirement, the Chair of this Forum, and the development of the Central Tax and Strategy remit in place of the Permanent Secretary for Tax. However, it was recognised that it was important that there be an avenue by which significant issues in the use of the powers, deterrents and safeguards could be raised at a senior level inside HMRC. It was, therefore, agreed to create a specific sub-group as part of the Compliance Reform Forum, chaired by the Director of Enforcement & Compliance Change. A document about the History of Powers will be placed on the HMRC website under the Review of Powers part. ## Membership Of The Oversight Forum HMRC Chair - Dave Hartnett Permanent Secretary for Tax Mike Eland Director General of Enforcement and Compliance Anthony Inglese General Counsel and Solicitor Richard Summersgill Director of Local Compliance Head of the Review of HMRC's Powers, Deterrents and Safeguards Simon Norris/Jim Ferguson External Representatives Chas Roy-Chowdhury Association of Chartered Certified Accountants (ACCA) Ian Menzies-Connacher Confederation of British Industry(CBI) Andrew Hubbard Chartered Institute of Taxation (CIOT) Paul Aplin (OBE) or Frank Haskew Institute of Chartered Accountants in England & Wales(ICAEW ) Tax Faculty David Cruickshank or Derek Allen Institute of Chartered Accountants of Scotland (ICAS) Nigel Popplewell The Law Society Low Income Taxpayers Reform Group Robin Williamson or Anthony Thomas Robert Maas or Bob Davies Institute of Indirect Taxation
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# Operational Selection Policy Osp32 ## # Records Relating To Court Actions For Individual Insolvency (Case Files & Datasets) 1973-2003 ## Contents Introduction 1 Authority 2 Scope 3 Background and functions - The Bankruptcy Court 4 Courts within the Chancery Division with responsibility for individual bankruptcy 5 Hearings of individual bankruptcies in the English and Welsh regions 6 Appeals against individual bankruptcy decisions 7 Acquisition policy collection themes Individual Insolvency 8 Individual insolvency procedures 8.1 Overview of three formal individual insolvency procedures 8.2 County Court Administration Order 8.3 Individual Voluntary Arrangement (IVA) 8.4 Bankruptcy Petition by Debtor or Creditor 8.5 Bankruptcy Procedures 9 Court records preserved in The National Archives to date relating to cases of individual insolvency 10 County Court cases - current selection and disposal 11 Bankruptcy appeal case files 12 The National Archives policy on the preservation of Department of Trade and Industry and Agencies individual bankruptcy case file records 13 Proposals for the future permanent preservation and disposal of records of individual bankruptcy cases 13.1 Records relating to individual bankruptcies that provide a national context 13.2 Bankruptcies concerning the case files of individuals 13.3 Bankruptcy registers 13.4 Bankruptcy Court appeal case files ## Implementation Of The Policy Appendices Appendix 1 - Summary Individual Insolvency Statistics For The High Court, District Registries And County Courts 2001 Appendix 2 - County Court Administration Order - basic procedures to 2003 Appendix 3 - Individual Voluntary Arrangement (IVA) - basic procedures to 2003 Appendix 4 - Individual Bankruptcy proceedings - basic procedures to 2003 ## Introduction 1 Authority 1.1 In 1998 the Public Record Office (hereafter to be referred to as The National Archives) published its first Acquisition Policy. This set out the principles that are to guide the selection of records for permanent preservation in The National Archives. The following year the Archives produced a complementary Disposition Policy dealing with the selection of public records to be held in places of deposit other than The National Archives. 1.2 Both acquisition and disposition policies are being implemented through the production of Operational Selection Policies. These are detailed statements of appraisal plans as they apply to categories of records found in one or more government departments. They are developed by The National Archives in partnership with other government departments and in consultation with other repositories appointed by the Lord Chancellor as places of deposit. They are subject to public consultation. 1.3 Operational selection policies are intended to be working tools for those involved in the selection of public records for permanent preservation. They may be reviewed and revised at any time in the light of comments from record producers, reviewers or users of the records or as a result of newly discovered information. The extent of any review or revision exercise will be determined according to the nature of the comments received. 1.4 1.5 Operational Selection Policies do not provide guidance on public access to selected records. If you have any comments upon this policy, please email records-management@nationalarchives.gov.uk Or write to: Acquisition and Disposition Policy Manager Records Management Department The National Archives Kew Richmond Surrey TW9 4DU ## 2 Scope 2.1 This policy concerns the case file records of the - Supreme Court of Judicature: High Court of Justice, Bankruptcy Court of the Chancery Division - Court of Appeal on Bankruptcy, London - Court of Appeal, Civil Division - Bankruptcy jurisdiction - County Courts - Bankruptcy jurisdiction files ## 3 Background And Functions - The Bankruptcy Court 3.1 Origins The organisation of modern judicial bankruptcy proceedings dates from the Judicature Act of 1873 which created the High Court in 1875: replacing the Ancient Court of the Queens Bench, Court of Common Pleas, Court of the Exchequer, Chancery Court and Probate, Divorce and Admiralty Court with new judicial bodies. The Chancery Division of the High Court comprised one of these new organisations. Part of the responsibility of the Chancery Division was to hear personal insolvency disputes. The High Court became part of the Supreme Court of England and Wales under the Supreme Court Act 1981, which articulates its current jurisdiction. ## 4 Courts Within The Chancery Division With Responsibility For Individual Bankruptcy 4.1 Individual bankruptcy The Bankruptcy Court of the High Court has jurisdiction over individual insolvency disputes and disposing of proceedings (e.g. selecting the Court that will hear the case), most recently arising under Parts VIII to XI of the Insolvency Act 1986 and related legislation. Such court actions include applications for interim orders to support an Individual Voluntary Arrangement (IVA), applications to set aside a statutory demand, bankruptcy petitions and various applications concerned with the realisation and distribution of assets of individuals who have been adjudged bankrupt, as well as proceedings concerning the administration in bankruptcy of the insolvent estate of a deceased person. Proceedings in the Bankruptcy Court are issued in the Bankruptcy Issue Room and are dealt with by the Registrars in Bankruptcy, and not the Masters of the Chancery Division. 4.2 The High Court is based at the Royal Courts of Justice, on the Strand, London but also sits at 26 Crown Court centres throughout England and Wales throughout the following legal circuits: Midland & Oxford; North Eastern; Northern; South Eastern (comprising London and Greater London); Wales & Chester and Western. Under the Courts and Legal Services Act 1990, s.61, Sch. 1, any case that does not require to be heard by a High Court Judge and falls within the jurisdiction of the County Courts may be transferred to and heard by the latter. 4.3 This Operational Selection Policy covers individual insolvency court records created from 1973 to 2003. The Enterprise Act 2002 was enacted from September 2003 and changed some of the procedures that had been in place previously. Notably, these introduce new features such as, where appeals are to be filed in the High Court, Fast Track Voluntary Arrangements and bankruptcy discharge after 1 year (instead of three years). As these were introduced late in the period under discussion this Operational Selection Policy focuses on the records produced by the earlier procedures that were in place for the majority of the period from 1973 to 2003. ## 5 Hearings Of Individual Bankruptcies In The English And Welsh Regions 5.1 The County Courts were established under the County Courts Act 1846. As the main civil courts in the regions, part of their jurisdiction covers hearings for individual bankruptcies. County Courts have exclusive jurisdiction in bankruptcy cases outside London. Proceedings are, therefore, brought in the relevant County Court. If the County Court judge decides the case is to be heard by a higher court (The High Court) he will lodge the petition with the local District Registry. If staffs of the District Registry are content, the case will be forwarded to the High Court in London. Usually, for both individual and corporate insolvency cases, a District Judge at a local court hears the case close to where the debtor resides. However, when the Crown is the main creditor (e.g. where the bankrupt / company has incurred tax arrears) then the High Court may choose to hear the case in London. ## 6 Appeals Against Individual Bankruptcy Decisions 6.1 To 2003, appeals against County Court (Circuit or District Judge) decisions concerning individual insolvency cases were directed to the Bankruptcy Court in London and heard by a Chancery Judge. From 2004, appeals are lodged with the High Court of Appeal Office. The Court of Appeal only hears appeals concerning orders made by a High Court Chancery Judge. Every such appeal is limited to a review of the decision of the lower court. The appeal will be allowed if the decision of the lower court was incorrect or if it was unjust because of a serious procedural or other irregularity in the proceedings in the lower court. ## 7 Acquisition Policy Collection Themes 7.1 The Acquisition Policy Statement outlines certain themes, which form the basis of The National Archives' appraisal and selection decisions. Of these themes, the following are of potential relevance in considering Court case records relating to individual bankruptcy cases. 2.1.4. Policy and administrative processes of the state: administration of justice and maintenance of security. 2.2.1. The economic, social and demographic condition of the UK, as documented with the state's dealings with individuals, communities and organisations outside its own formal boundaries. 7.2 This Operational Selection Policy considers records relating to individual insolvency cases. The paper is organised as follows: - A brief outline of the procedural options and activities that can take place during each bankruptcy case. - Records selected for permanent preservation in The National Archives to date: including criteria for preservation (if any). - Records deposited locally to date by The Court Service: including any available criteria for disposal (if any). - Proposals for the future permanent preservation and disposal of records. ## Individual Insolvency 8 Individual Insolvency Procedures 8.1 Overview of three formal individual insolvency procedures Apart from informal arrangements, there are three (formal) legal regimes in which an individual deals with their debt problems. - County Court Administration Order - Individual Voluntary Arrangement (IVA) - Debtor's Bankruptcy Petition 8.2 County Court Administration Order This can be pursued where the degree of indebtedness has a £5000 upper limit. Only County Courts use this procedure: not the Bankruptcy Court in London. An overview of the basic procedure is provided in **Appendix 2**. When a County Court Administration Order is made: - The court takes control of the debtor's assets - The court divides the assets among the creditors - Individual creditors are prohibited from taking any further court action against the debtor - The debtor pays relatively low court fees - The Order is a public record - Failure to keep up agreed payments will lead to a review by the court whereby the District Judge or Registrar can revoke the Order 8.3 Individual Voluntary Arrangement (IVA) An IVA is legally binding agreement between a debtor and his creditors and the regime is contained in Part VIII of the Insolvency Act 1986. The debtor approaches a licensed **Insolvency Practitioner (IP)** and a 'Proposal' is drawn up setting out how the debtor proposes to deal with his/her debts. At this stage the IP acts as the Nominee. The proposal is then put to the creditors who vote on whether to accept or reject the proposal at a formal meeting. If the proposal is approved generally the IP who was the Nominee is appointed as the Supervisor of the IVA and it forms a legally binding agreement. In some IVAs an application is made to the court for an Interim Order to stay or freeze all bankruptcy and other court proceedings against the debtor. If an IVA is approved by the creditors: - The Supervisor takes control of the debtor's assets included in the proposal - The Supervisor realises the assets contained in the proposal and divides the proceeds amongst the creditors - The debtor can continue to run his business - Individual creditors are prohibited from taking any further court action against the debtor - The IVA is a matter of public record and details of IVAs can be accessed the Individual Insolvency Register which is displayed on the Insolvency Service website (www.insolvency.gov.uk) 8.4 Bankruptcy Petition by Creditor or Debtor A person can be subject to a creditor's bankruptcy petition if s/he owes more that £750. A debtor can also present his/her own bankruptcy petition to the court. The bankruptcy regime is contained in Part IX of the Insolvency Act 1986. 8.4.1 Bankruptcy should always be the option of the last resort because: - Assets are liable to be sold to repay outstanding debts - The bankrupt risks losing his/her home and possessions - The bankrupt faces severe restrictions on his/her finances, such as getting a mortgage, bank account and future credit - Details of the bankruptcy will be advertised in a local newspaper and recorded on a register that anyone can search - If the bankrupt is in employment, he/she will probably have to make payments to creditors for 3 years. The bankrupt will only be able to avoid these payments if he/she is on a very low income - The Official Receiver will look at the facts in every case and will identify dishonest people, who may be prosecuted - An undischarged bankrupt has a number of restrictions placed upon them, these include not being able to act in the management of a limited company - The Official Receiver will also consider whether to apply for a Bankruptcy Restrictions Orders (BRO). This protects the public and business community against bankrupts whose conduct may not have been dishonest but was irresponsible or reckless - In the most serious cases, a BRO could last for 15 years For all these reasons, if practical, an IVA is the preferred option for a debtor. 8.5 Bankruptcy procedures The summary of procedures for proceedings in bankruptcy is provided in **Appendix 4**. When a creditor commences the bankruptcy proceedings, the process begins with a creditors petition (properly served on the debtor) relating to an unpaid debt. The unpaid debt is usually evidenced through a **Statutory Demand** or on unsatisfied judgment. Subsequently there will be a hearing for a bankruptcy order. A debtor can present his/her own petition for bankruptcy, this will be accompanied by a Statement of Affairs which sets out the debtor's assets and liabilities the debtor's petition will also lead to a hearing for a bankruptcy order. If at the bankruptcy hearing (creditor's or debtor's petition) the court does make a Bankruptcy Order the **Official Receiver** (OR), (employed by the Insolvency Service an Executive Agency of the Department of Trade and Industry) is appointed as receiver and manager of the bankruptcy estate. On the making of the bankruptcy Order the OR is automatically appointed as receiver and manager of the bankruptcy estate and his/her main duty is to protect the bankruptcy assets pending the appointment of the trustee in bankruptcy (in whom the bankruptcy assets vest). The trustee may be the OR alternatively, if there are significant assets, a meeting of creditors will be called and the creditors will generally vote for an IP to be appointed as trustee. Whether or not he is appointed as trustee the OR also has the duty to investigate the bankrupt's conduct and financial affairs, which may result in an application for a BRO or in serious cases a prosecution. The OR will advertise the bankruptcy and invite creditors to 'prove' their debts (i.e. submit claims). If the bankrupt does not co-operate with the Official Receiver (or, if appointed IP trustee) he/she can be publicly examined in court as to his/her financial affairs and the causes of the bankruptcy. Alternatively an application can be made to the court to suspend the bankrupt's discharge. 8.5.1 To summarise, when a bankruptcy order is made by the Court - The OR will investigate the bankrupt's conduct and affairs - A *Trustee* is appointed to deal with the bankrupt's assets. - The Trustee divides the assets among the creditors - Individual creditors are prohibited from taking any further court action against the debtor unless they obtain leave from the bankruptcy court - The bankruptcy order is advertised in a local newspaper and details of undischarged bankrupt's can be found on the Individual Insolvency Register which is displayed on the Insolvency Service website (www.insolvency.gov.uk) - If he/she co-operates with the OR (and IP trustee) he/she is automatically discharged one year after the bankruptcy order was made. Prior to 15 September 2003 a bankrupt was discharged only after 3 years had elapsed after the order ## 9 Court Records Preserved In The National Archives To Date Relating To Cases Of Individual Bankruptcy 9.1 High Court cases The Report of the Committee on Legal Records (Cmnd 3084) (known as the *Denning Report*), August 1966, recommended the following preservation decisions for individual bankruptcy public records of the High Court (only) in London. B 9 - Bankruptcy case files - to be destroyed 60 years after the opening of the file - selected files of historical or legal precedent interest to be preserved permanently. B 11 - Registers of Bankruptcy Petitions to the High Court - preserve permanently. B 12 - Registers of Receiving / Bankruptcy Orders - preserve permanently. 9.2 The latest Supreme Court of Judicature - Bankruptcy Court - Records Schedule (dated 25 June 2003) continues this High Court preservation decision but makes the following amendments: B 9 - Bankruptcy case files - Destroy after 20 years but make a random 1% selection for preservation. The High Court files accessioned at The National Archives contain some files of notable persons and celebrities. B 11 - Registers of Bankruptcy Petitions to the High Court - the Bacchus computer system is used for the production of Registers of Petitions from 1994. The WIPETS system was used from 1986 to 1994 - printouts of all petitions to be preserved when they are 20 years old. B 12 - Registers of Receiving / Bankruptcy Orders - no computer output - these registers were obsolete after 1991: they do not exist after this date. All registers up to 1991 to be permanently preserved when they are 20 years old. 10 County Court bankruptcy records - current selection and ## Disposal 10.1 The Denning Report of 1966 noted that many case files (which would include those of individual bankruptcies / insolvencies) had been held for long periods (e.g. over 30 years) at the courts where they were created without being deposited under s.4(1) of the Public Records Act 1958. Further, only the County Court Registers of Petitions and Receiving Orders in Bankruptcy were designated for permanent preservation in this report. These were to be preserved in the local place of deposit. 10.2 The latest Revised High Court (District Registry) and County Court Record Schedules makes reference only to 'Bankruptcy Files' and recommends that they all be destroyed 20 years after the date of the adjudication. There is no reference to Registers of Receiving / Bankruptcy Orders as these were obsolete after 1991: Registers prior to 1991 should have been preserved permanently in the local record office. 10.2.1 'Files of proceedings under specified Acts' The schedule also refers to "Files of local or historical interest [that] must be retained for 30 years and then sent to the local record office". "Files under specified acts" cited under this schedule refer to case files that were unusual: e.g. where points of law were established by the case. These were also to be preserved. ## 11 Bankruptcy Appeal Case Files 11.1 The Denning Report of 1966 makes no reference to Civil Court of Appeal records. The Civil Court of Appeal was created In 1966 and so was missed by this publication. Further, the latest Court Service Supreme Court of Justice Civil Appeals Office Records Schedule refers only to the preservation of selected papers for J 157 - Supreme Court of Judicature: Court of Appeal (Civil Division) Office. A search of J 157 identified no case files specifically concerning bankruptcy cases: although this may because the subject of the appeal (bankruptcy / insolvency) is not specified in the file descriptions. The Judicial Statistics Annual Report 2001 indicates that bankruptcy appeal cases to this Court comprise 6.5% of the total civil appeals for that year - see Appendix 1, Table 5. 11.2 The High Court of Appeal on Bankruptcy deals with appeals concerning District Judge / Registrar decisions on individual insolvency cases made in the regions. There is no National Archives file series for the Court of Appeal on Bankruptcy and none of these appeal files have been preserved in The National Archives to date. 11.3 The record series J 157 covers the Court of Appeal (Civil Division) only. Concerning bankruptcy cases, the Court of Appeal (Civil Division) only hears appeals on Orders made by the Court of Appeal on Bankruptcy: those made by Chancery Judges from the latter court. 11.3.1 Every such appeal is limited to a review of the lower court. The appeal will be allowed if the decision of the lower court was incorrect or if it was unjust because of a serious procedural irregularity in the lower court. Where such decisions are found for the appellant and they raise precedents, these are reported in the Law Reports, therefore there is little reason to preserve the case files which only contain the applications for appeal and the Appeal Court Judge's order: the bundles of evidence and other papers are returned to the appellants and their legal representatives. 12 The National Archives policy on the preservation of Department of Trade and Industry and Agencies individual bankruptcy case file records 12.1 The National Archives Operational Selection Policy does not yet exist for individual insolvency case records: official receivership is the responsibility of the DTI. Consequently, the selection of files concerning the activities of the Official Receiver in individual insolvency cases does not exist to inform the selection and preservation of Court case files. 12.2 Appendix 1 Tables 1,2,4 and 5 provides summary details of the volume of business passing through the High Court and the County Courts concerning individual bankruptcy proceedings for the year 2001. 13 Proposals for the future permanent preservation and disposal of records of individual bankruptcy cases 13.1 Records relating to individual bankruptcy that provide a national context 13.1.1 Annual Judicial Statistics concerning national trends in individual bankruptcy court actions created by the Department for Constitutional Affairs to be preserved at the UK National Digital Archive of Datasets (NDAD) every year. These tables are to be contained in the UK National Digital Archive of Datasets (NDAD) series CRDA/8 and The National Archives reference LE 1: Monthly Civil Business Returns. 13.2 Bankruptcies concerning the case files of individuals 13.2.1 Cause célèbre case files of historical or legal significance are to be selected. Such files are to comprise: files that concern famous or infamous individuals; cases that created prolonged interest in the media; cases that contributed to the rise of pressure groups or Parliamentary action; cases that set a legal precedent. High Court cases to be preserved in the B 9 TNA series. County Court cases to be preserved in the appropriate local place of deposit for public records. 13.2.2 Records that demonstrate developments and changes in the way bankruptcy was dealt with by the High Court and the County Courts are to be selected: in policy and the process / procedures of law. Each county / region to select illustrative example files that demonstrate changes in procedures and the application of new policies concerning individual bankruptcies in their region. Only a small number of files need to be selected: e.g. under 10 files. Initially these should cover existing arrangements: - County Court Administration Orders - Individual Voluntary Arrangements - Debtor or Creditor bankruptcy petition resulting in an Order being made High Court files are to be preserved in The National Archives series B 9 and County Court files to be preserved in local places of deposit for public records. ## 13.3 Bankruptcy Registers 13.3.1 Registers of Bankruptcy Petitions from the High Court (London) (to be preserved in The National Archives series B 11) and the County Courts to be permanently preserved in their entirety. County Court Registers to be deposited in local places of deposit for their permanent preservation. 13.3.2 Series B11 'WIPETS' (to 1994) and 'Bacchus' systems (from 1994) Register printouts to continue to be preserved, as there is no electronic archiving provision from these systems that would enable their transfer to the UK National Digital Archive of Datasets. 13.3.3 Registers of Receiving / Bankruptcy Orders (The National Archives series B 12) to be preserved to 1991 after which date they are obsolete. Bankruptcy Order dates are preserved on the Bacchus system from 1994. ## 13.4 Bankruptcy Court Appeal Case Files 13.4.1 Bankruptcy appeals from the Court of Appeal on Bankruptcy and the Court of Appeal (Civil Division) are not to be permanently preserved at The National Archives. The files are incomplete as the bundles are returned to the appellants and the their legal representatives. Further, the files only contain, in the main, applications for appeals and the Judge's order and do not provide a great deal of valuable archival information that cannot be drawn from other sources. For example, the Law Reports always report on precedent cases in appeal actions. Implementation of the Policy Concerning individual insolvency court case files, implementation of this policy will fall largely to the Records Management Service of The Court Service with the cooperation of the District Registries, County Courts in the regions and the Supreme Court of Judicature, Bankruptcy Court in London. ## Appendix 1 Summary individual and corporate insolvency statistics for the High Court (including District Registries) and the County Courts 2001 Table 1 High Court - Chancery Division: Summary of bankruptcy proceedings before registrars' under the Insolvency Act 1986, for 2001 Bankruptcy petitions by creditors 8,624 699 Bankruptcy petitions by debtors and legal representatives of deceased debtors 11,415 Other applications and summonses (e.g. Individual Voluntary Arrangements and Administrative Orders etc…) Total applications 20,738 * The High Court transferred 3,496 petitions to the County Courts during 2001. Table 2 High Court - Chancery Division: Individual bankruptcy orders made, 2001 Orders made Bankruptcy Orders on creditors' petitions 4,380 Bankruptcy Orders on debtors petitions 697 Total orders 5,077 Table 3 Individual bankruptcy - summary of proceedings started in the County Courts, 2001 Bankruptcy petitions 21,232 Administrative Orders 7,548 Total Allowed Dismissed Withdrawn or struck out Table 4 High Court - Chancery Division: Appeals concerning bankruptcy cases from inferior Courts, 2001 Set down for hearing County Courts 51 9 25 4 38 High Court Registrars 56 3 24 6 33 107 12 49 10 71 A total of 1,071 civil appeals were filed during 2001. ## Appendix 2 County Court Administration Order Procedure To 2003 Administrative Order made final becomes a public record. Failure of the debtor to keep up payments will lead to a review hearing whereupon a Judge may revoke the Order. If the judge dismisses the Administration Order, Bankruptcy proceedings may follow - see Appendix 4 ## Appendix 3 Individual Voluntary Arrangements (Iva) Procedures To 2003 Appendix 4 Bankruptcy procedures to 2003
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To: Customer and Business Support; Keeley John Subject: 15140_Longshaw Offices/Substation_NP/DDD/0517/0453_Planning_email 1 of 2 Attachments: 401E_Phase 1_Proposed Offices_edited-1.jpg; 400D_15140_proposed site plan.pdf; 410C_15140_proposed detailed site plan.pdf; EW_2342- 01 landscape proposals_rev02.pdf Categories: Julie Re : Longshaw Offices/Substation_NP/DDD/0517/0453_Planning & NP/DDD/0517/0455_Listed Building Consent Dear John, I spoke to Karen Zuberkowski this afternoon and she suggested I send this info to PDNPA customer services with copy to you. I attach the following additional information for the Planning application and Listed Building Consent for Longshaw. * Tree Report _ File : JC.081.170511_Longshaw_Tree_Report_JonCoeTreeServices - NOTE : separate email 2 of 2 Due to size * Landscape proposals _ File : EW_2342-01 landscape proposals_rev02 along with amended drawings to be substituted for the drawings with the same numbers : 401 / 400 & 410. * Revised drawing _ File : 401E_Phase 1_Proposed Offices * Revised drawing _ File : 400D_15140_proposed site plan * Revised drawing _ File : 410C_15140_proposed detailed site plan This info includes a tree report and landscape proposals and shows some minor amends to the plan layout at the entrance to the proposed offices which are duplicated on three plan drawings. If you have any queries please let me know, otherwise I look forward to seeing you at the site visit. Regards Simon Simon Gedye RIBA Architect architect_Studio Gedye Ltd RIBA Accredited Conservation Architect The Studio 2 Bank View Main Road Hathersage S32 1BB 01433 659461 07912534372
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## Published 15 February 2018 Criminal Justice Statistics Quarterly, England And Wales, September 2016 To September 2017 (Provisional) Main Points 1.65 million individuals dealt with by the CJS The total number of individuals formally dealt with by the criminal justice system (CJS) in England and Wales has declined since 2007 and fell 7% in the latest year to a record low, with 1.65 million individuals dealt with in the year ending September 2017. 1.40 million defendants were prosecuted The number prosecuted at magistrates' courts fell by 5% in the latest year, driven by decreases in prosecutions for indictable and summary non-motoring offences. The overall conviction ratio increased by one percentage point in the latest year to 86%, the highest in the decade. The conviction ratio was 86% The custody rate for indictable offences has increased since September 2010, from 24% to 32%. Custody rate for indictable offences rose to 32% Average custodial sentence length (ACSL) has steadily increased since September 2007, when it was 12.4 months overall and 15.2 months for indictable offences. ACSL increased to 19.7 months for indictable offences and stabilised at 16.7 months overall This publication gives criminal justice statistics for the latest 12 month period. These are presented alongside the same rolling 12 month periods for the previous 10 years, giving longer-term trends across comparable periods. Trends should be interpreted with caution as the data presented are provisional and subject to change for the 2017 Criminal Justice Statistics annual bulletin, scheduled to be published on 17 May 2018. For full and detailed commentary, please refer to the annual publication. For technical detail please refer to the accompanying guide to criminal justice statistics. Alongside this publication, we will be publishing a new analytical paper on prolific offenders and an interactive Sankey diagram for offending histories which can be found at: moj-analytical-services.github.io/criminal_history_sankey/index.html We have changed how our quarterly bulletins look, and would welcome any feedback to commentary.champions@justice.gsi.gov.uk For other feedback related to the content of this publication, please contact us at CJS_Statistics@justice.gsi.gov.uk ## 1. Overview Of The Criminal Justice System 1.65 Million Individuals Were Dealt With By The Cjs In The Latest Year The total number of individuals1 formally dealt with by the criminal justice system (CJS)2 in England and Wales has declined since 2007 and fell 7% in the latest year to a record low, with 1.65 million individuals dealt with in the year ending September 2017 (see Figure 1). The number of individuals formally dealt with by the CJS fell by 7% in the latest year. The number of individuals prosecuted at all courts fell by around 5%, which is broadly in line with the latest crime outcomes statistics published by the Home Office4. These show that the number of suspects issued a charge/summons fell by 4% in the latest year. This is despite a 15% increase in overall police-recorded crime5 (to 4.7million offences excluding fraud), believed to be associated with improved recording among police forces and victims' greater willingness to report crimes. The Crime Survey for England and Wales (CSEW), estimated 10.6 million incidents of crime in the latest year (including fraud and computer misuse)6, a reduction of 10% compared with the previous year (or a reduction of 6% if excluding fraud and computer misuse offences). ## 2. Out Of Court Disposals The use of out of court disposals (OOCDs) decreased by 43,700 (15%) in the year ending September 2017, when 253,200 individuals were issued an OOCD. This reduction can be seen across all OOCD types and continues the steady decline in the use of OOCDs over the last ten years (excluding Community Resolutions7, see Figure 2). The decrease in the number of OOCDs issued followed a number of policy changes relating to police practice and OOCD availability8. The number of Penalty Notices for Disorder (PNDs) administered was 28,200, falling 27% from the previous year. The most common offences that resulted in a PND were 'drunk and disorderly', theft (under £100), possession of cannabis, and causing harassment, alarm or distress, and together these accounted for 91% of all PNDs. The total number of cautions administered was 88,600, falling 18% from the previous year. Drug offences, theft and violence against the person were the most common indictable offences9 for which an offender received a caution (accounting for 80% of all cautions for indictable offences). The overall cautioning rate10 (among those cautioned or convicted excluding summary motoring offences) fell in the latest year from 13% to 11%. The number of Community Resolutions administered was 104,850, decreasing 8% since the previous year. ## 3. Court Prosecutions And Convictions Overall, The Number Of Defendants Prosecuted Fell To 1.40 Million In the 12 months ending September 2017, 1.40 million defendants were prosecuted at magistrates' courts, down from 1.48 million in the previous year. This was an overall fall of 5%, driven by falls in indictable and summary non-motoring offences. ## The Conviction Ratio Increased To 86% Although the total number of offenders convicted fell, the overall conviction ratio11 increased from 85% to 86% in the latest year, the highest in the decade. When compared to the previous year, the conviction ratio for indictable offences has decreased by one percentage point to 83%. The decline in overall prosecutions since the year ending September 2016 is primarily driven by a decline in defendants prosecuted for summary non-motoring and indictable offences. Following a gradual increase since 2012, prosecutions for summary motoring offences have been relatively stable since September 2015. Prosecutions for indictable offences have steadily declined since 2010 and decreased by 8% in the last year, whereas prosecutions for summary non-motoring offences have decreased 8% in the last year, reversing the upward trend seen since September 2014. There were 1.2 million offenders convicted in the year ending September 2017, down 3% on the previous year. As with prosecutions, this decrease is driven by a fall in convictions for indictable and summary non-motoring offences (down 10% and 5% respectively), however there was an increase of 1% in convictions for summary motoring offences - these offences account for 43% of all offenders found guilty. ## 4. Remands The Overall Trends Of Remands Have Remained Stable. In the latest year, there was a slight decrease in the number of defendants remanded on bail and in custody, and a slight increase in those summonsed and not remanded. In the year ending September 2017, there were 1.47 million defendants directed to appear at magistrates' courts (including those who failed to appear). The proportion of defendants being summonsed increased from 67% to 70%, the proportion remanded in custody by the police remained stable at 10% and the proportion arrested and bailed by police decreased from 23% to 21%. Bail was granted to 16% of defendants prosecuted at magistrates' courts, falling from 18% in the previous year. The proportion of defendants remanded in custody remained stable at 4%, while 80% had their case concluded at magistrates' courts without being remanded, increasing from 78% in the previous year. In the Crown Court, the proportion of defendants not remanded increased from 17% to 20% between September 2016 and September 2017. In contrast, a falling proportion of defendants were remanded in custody (from 35% to 34%) and on bail (from 48% to 46%), bringing remand status figures for Crown Court back in line with proportions seen in 2013. Defendants are more likely to be remanded in custody for indictable offences than summary offences, so the proportion of defendants remanded in custody at the Crown Court is higher than at magistrates' courts. Of those remanded in custody at the Crown Court, 73% were sentenced to immediate custody in the year ending September 2017. Half (50%) of all defendants who were not remanded at the Crown Court received an immediate custodial sentence, and 16% of defendants remanded in custody by magistrates' courts were sentenced there to immediate custody. A further 59% of defendants remanded in custody in magistrates' courts were committed for trial or sentencing at the Crown Court. ## 5. Sentencing Custody Rate12 For Indictable Offences Rose To 32% The overall custody rate, at 7%, is the same as in September 2015 and 2016, while the custody rate for indictable offences has increased since September 2010, from 24% to 32%. Average custodial sentence length (ACSL) increased to 19.7 months for indictable offences and was 16.7 months overall. ACSL has steadily increased since September 2007, when it was 12.4 months overall (now 16.7 months) and 15.2 months for indictable offences (now 19.7 months). Overall, the number of offenders sentenced at all courts has fallen by 42,700 (3%) since 2016. Similar to prosecutions and convictions, this is driven by a decline in indictable and summary non-motoring offences, which have seen decreases of 10% and 5% respectively. The most common sentence given for all offence groups was a fine, accounting for 75% of offenders sentenced in the latest year, following a steady increase of 10 percentage points since 2011. In the year ending September 2017, a greater proportion of offenders (32%) received immediate custody for indictable offences than any other type of sentence, up by 2 percentage points since 2016. Since 2007, the proportion of offenders receiving a community sentence has declined by 14 percentage points, and the proportion of offenders receiving a suspended sentence for indictable offences increased by 8 percentage points. The number of persons sentenced to custody for sexual offences increased in the last decade (from 2,800 to 4,200), which has contributed to the increase in the overall ACSL, as custodial sentences for sexual offences are generally longer. However, in the last year there has been a 3% decrease in the number of persons sentenced to custody for sexual offences and the ACSL stabilised at 60.6 months. ## 6. Offending Histories Adult Offenders Convicted For Indictable Offences Are Now More Likely To Receive Some Form Of Custody, Irrespective Of Their Criminal History Adult offenders convicted for indictable offences are now more likely to receive some form of custody (52%), i.e. immediate custody or a suspended sentence, than they are to receive a non-custodial sentence, irrespective of their criminal history. 41% of adult offenders received some form of custody when convicted 10 years ago. ## Repeat Offenders Proportion Of Adults With Long Criminal Careers Continues To Rise Just under two fifths (39%) of adult offenders convicted for an indictable offence in the last 12 months had a long criminal career (on average 34 previous sanctions), an increase from 30% 10 years ago. Over half (59%) of adult offenders with a long criminal career received some form of custodial sentence. Whilst the overall number of juvenile offenders has decreased every year since 2007, the proportion that are first time offenders has been increasing since 2011. In the last 12 months 45% of juvenile offenders cautioned or convicted were first time offenders, a 7 percentage point increase since 2011, with a commensurate decline in further offending. 56% of juvenile first-time offenders received a caution in the last 12 months and the most common offence committed by this group of offenders was a theft offence There were around 121,000 persistent offenders14 in the 12 months ending September 2017 who have been responsible for around 2.7 million crimes through their criminal careers. Of these, 39% were given their first official sanction for a theft offence. The first in a new analytical series, published alongside this bulletin on "Prolific Offenders"15 16 shows for the period 2000 to 2016, around 492,000 individuals met the criteria to be considered prolific. ## Further Information The data presented in this publication are provisional. Final data for each calendar year is published in May each year in our Criminal Justice Statistics annual bulletin, following further data cleaning and the incorporation of additional cases not available in our original extracts of administrative data. ## Accompanying Files As well as this bulletin, the following products are published as part of this release: - A technical guide providing further information on how the data is collected and processed, as well as information on the revisions policy and legislation relevant to sentencing trends and background on the functioning of the criminal justice system. - A set of overview tables, covering each section of this bulletin. - A set of offending histories tables, including a data tool. - An analytical paper on prolific offenders. ## National Statistics Status National Statistics status means that official statistics meet the highest standards of trustworthiness, quality and public value. All official statistics should comply with all aspects of the Code of Practice for Official Statistics. They are awarded National Statistics status following an assessment by the Authority's regulatory arm. The Authority considers whether the statistics meet the highest standards of Code compliance, including the value they add to public decisions and debate. It is the Ministry of Justice's responsibility to maintain compliance with the standards expected for National Statistics. If we become concerned about whether these statistics are still meeting the appropriate standards, we will discuss any concerns with the Authority promptly. National Statistics status can be removed at any point when the highest standards are not maintained, and reinstated when standards are restored. ## Contact Press enquiries should be directed to the Ministry of Justice press office: Tel: 020 3334 3536 Email: newsdesk@justice.gsi.gov.uk Other enquiries about these statistics should be directed to the Justice Statistics Analytical Services division of the Ministry of Justice: Damon Wingfield, Responsible Statistician and Head of Criminal Justice Statistics Ministry of Justice, 7th Floor, 102 Petty France, London, SW1H 9AJ Email: CJS_Statistics@justice.gsi.gov.uk ## Next Update: 17 May 2018 URL: www.gov.uk/government/statistics/criminal-justice-statistics-quarterly-september-2017 © Crown copyright Produced by the Ministry of Justice Alternative formats are available on request from statistics.enquiries@justice.gsi.gov.uk
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# Follow Up Of Agreed Actions From The Previous Better Care Fund (Bcf) Audit City Of York Council ## 2016/17 # Memorandum Responsible Officer: Director of Adult Social Care Status: Final Date Issued: 24/3/2017 Where information resulting from investigation and/or audit work is made public or is provided to a third party by the client or by Veritau then this must be done on the understanding that any third party will rely on the information at its own risk. Veritau will not owe a duty of care or assume any responsibility towards anyone other than the client in relation to the information supplied. Equally, no third party may assert any rights or bring any claims against Veritau in connection with the information. Where information is provided to a named third party, the third party will keep the information confidential. ## 1 Introduction 1.1 The Better Care Fund (BCF) was established in 2013 with the aim of integrating health and social care to improve outcomes for patients and use resources more efficiently. It requires Clinical Commissioning Groups (CCG) and local authorities to pool budgets and agree spending plans for how they will use their BCF allocation. The BCF budget shared between City of York Council and Vale of York CCG is around £12.2m for 2016/17. There is an additional risk-share of around £1.2m that is split equally between the Council and the CCG. 1.2 The previous audit in 2015/16 reviewed reporting and performance monitoring arrangements, as well as risk management. Four actions were raised as a result of the audit and these have been followed up as part of this audit. 1.3 More recently, Mazars have carried out a review into the BCF and made several recommendations regarding performance reporting, governance and oversight arrangements at strategic and implementation levels, as well as the need to liaise with NHS England's (NHSE) Better Care Support Team and Managers. These findings were reported to the Audit and Governance Committee in December 2016 and are broadly in line with the findings of the 2015/16 Veritau audit. ## Scope And Objectives 1.4 The primary objective of this audit was to establish the progress made towards resolving the four actions agreed with management as part of the 2015/16 audit. 1.5 The secondary objective of this audit was to agree further actions where necessary to address outstanding issues. ## Key Findings 1.6 It was found that good progress had been made towards achieving the actions agreed as part of the previous audit. These actions can now be considered complete. However, there remains progress to be made in some areas and a detailed discussion of the findings is set out below. 1.7 The Council feels that financial pressures and legal directions imposed on the CCG have led to the BCF receiving less attention than required from the CCG. The challenges facing the CCG have been noted in the Integration and Transformation Board (ITB) report presented to the Health and Wellbeing Board (HWB) on the 18th January 2017 and have also been recorded in the minutes of the ITB.1 The CCG has acknowledged that its contribution was not as effective as it should have been in 2016, but made a public commitment at the 18th January HWB meeting to rectify this.2 ## 2 Findings Area Reviewed: Reporting Lines And Monitoring Arrangements 2.1 The 2015/16 audit found that the overall responsibilities and reporting lines for delivery of the BCF programme were under review, but had not been formally agreed at the time of the audit. 2.2 Formal reporting lines and monitoring arrangements have been set out in the narrative submission to NHSE and in the Section 75 agreement. Responsibility for BCF lies with the HWB, which provides strategic oversight and ensures compliance. It is supported in this by the inter-agency ITB, which reports to HWB on a quarterly basis. The ITB is in turn supported by the Performance and Delivery Group (PDG), which is made up of representatives from the Council, CCG, and other bodies. 2.3 Schedule 2 of the Section 75 agreement sets out the role and governance arrangements of the ITB. It is responsible for reviewing and performance managing various areas related to the scheme, such as approving individual schemes and financial management. The delegated authority of the members of the ITB is set out in the Schedule. The ITB initially had an independent chair, but it was agreed at the September 2016 meeting that the chair should be shared between the partners. 2.4 There are also Terms of Reference (TOR) for the ITB that were agreed in May 2016. It was agreed at the December ITB meeting that these need reviewing as its role and geographical remit is changing. Some discussion was had at the January 2017 ITB workshop and the Director of Adult Social Care has agreed to review them. 2.5 Schedule 4 of the Section 75 agreement sets out the role of the PDG. It states that the PDG has been established to support the delivery of the BCF plan and report on operational issues and key performance metrics to the ITB on an 'exception' basis. The inaugural meeting of the PDG in August 2016 set out the values and purpose of the group and these have now been turned into formal TOR. 2.6 Discussion with officers found that the chair of the PDG is shared between the Council and the CCG. The Senior Strategic Commissioning Lead for the Council and the BCF Programme Manager, who chair the PDG, provide updates to the ITB on the performance of BCF.3 The responsible officers for each programme are accountable to the BCF Programme Manager for the performance of each scheme. Currently, the PDG is asking one responsible officer to report at each PDG meeting on the performance of their scheme. These reporting arrangements have evolved since the BCF plan was submitted to NHSE and since the Section 75 agreement was finalised. These documents require amending in future versions to reflect these developments. 2.7 The responsibilities and reporting lines for the delivery of the BCF programme have evolved considerably since the previous audit, with more formal monitoring and reporting arrangements now in place. Nevertheless, there is still progress to be made in clarifying the reporting lines between the individual schemes, the PDG and the ITB. ## Area Reviewed: Agreement On Council-Specific Risks, Including Risk Owners And Action Plans 2.8 The 2015/16 audit found that there was no overall risk register within the Council for BCF. 2.9 There is a risk register for Health, Housing and Adult Social Care that deals with nine risks to the directorate, some of which are related to BCF. These have all been given risk ratings and risk owners, as well as action plans and due dates. 2.10 Furthermore, the Section 75 agreement sets out financial risk-share principles. Minutes of the PDG and ITB meetings show that financial risks and risks to meeting the national metrics are being discussed. The financial risks to the Council were reported at the January meeting of HWB and Members raised concerns about the impact on the Council's budget. 2.11 A risk log has been included in the narrative submission to NHSE, based on risks identified by the Council and CCG. Elements of the action plans have been carried out, such as agreeing a Joint Commissioning Strategy, but actions to address the key risks need to be recorded systematically to provide the necessary level of assurance. ## Area Reviewed: Section 75 Agreement 2.12 The 2015/16 audit found that the Section 75 agreement had not been agreed at the time of the audit. 2.13 The latest Section 75 agreement is now in place between the Council and the CCG. The agreement was finalised on 12th October 2016 and signed by representatives of both parties. The agreement sets out pooled funding arrangements and the responsibilities of each Partner regarding over- or under-spends. Schedule 3 sets out the financial risk-share principles for BCF. 2.14 As the Section 75 agreement is now in place, the action can be considered complete. ## Area Reviewed: Agreement On And Monitoring Of Timescales And Actions For Specific Elements Of The Bcf Plan 2.15 The 2015/16 audit found that targets for the implementation of elements of the BCF plan had been missed. Most of these schemes were rolled over into the 2016/17 plan due to time constraints that prevented new schemes being developed. 2.16 All of the BCF schemes should be laid out in 'plans on a page' documents. These summarise the purpose, intended outcomes, metrics, finances, benefits and risks to each individual scheme. The intention was for the Council and CCG to share their respective plans at the November 2016 meeting of the PDG. However, the CCG's plans were not presented and were still not available at the time of this audit. 2.17 The PDG has developed a local performance dashboard, which shows performance against national and local metrics on a monthly and quarterly basis. Discussion with officers found that the initial intention was for this dashboard to show the RAG rating of individual schemes and which required an exception report to ITB. This is no longer the case because it was found that this format did not focus on the highest risks, nor did it demonstrate whether the national targets were being met. There is now a focus on collating all the data from partners for analysis and challenge, as well as receiving an in-depth report on a single scheme each month. 2.18 Minutes for the PDG and ITB meetings show that the plans are being monitored and discussed. Responsible officers are also providing updates at the PDG meetings. Furthermore, performance is being reported in the quarterly report to HWB by the ITB and back to NHSE in the quarterly submission by the PDG. However, discussion with officers found that NHSE has not commented on the submissions even when performance against national metrics was off-track and deteriorating. 2.19 The most recent report by the ITB to the HWB stated that it was unlikely that the BCF schemes would meet their targets for 2016/17, which reflects the performance of BCF schemes nationally, and that guidance for preparing a BCF plan for 2017/18 had been delayed. Nevertheless, progress has been made since the previous audit in agreeing and monitoring timescales and actions for elements of the BCF plan. ## 3 Conclusion 3.1 The Section 75 agreement has been signed off and reporting and performance monitoring arrangements have developed considerably. Nevertheless, changes to the responsibilities and reporting arrangements between the responsible officers for individual schemes, the PDG and ITB need to be reflected in the Section 75 agreement as arrangements evolve. 3.2 Performance and risk monitoring has improved since the previous audit. The PDG has developed a dashboard that sets out performance against national and local metrics and is working on compiling data and agreeing a reporting format for the individual schemes. 3.3 Risks are now documented on several levels: to the individual schemes; to the BCF plan as a whole; to the financing of BCF; and to the national metrics set by NHSE. Nevertheless, although Council-specific risks have been incorporated into the BCF plan and are reported on an exception basis, evidence of systematic reviews of the risks should be documented in the records of PDG and ITB meetings. 3.4 Although governance arrangements have evolved significantly since the previous audit, there is still progress to be made to ensure that the BCF plan has robust governance, performance and risk monitoring arrangements.
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Distributed Ledger T echnology: beyond block chain A report by the UK Government Chief Scientific Adviser ## Contents | Foreword. | 4 | |------------------------------------------------------|------| | Executive Summary and Recommendations 5 | | | Definitions. | 17 | | Chapter 1: Vision. | 21 | | Chapter 2: Technology 33 | | | Case study - Research and horizon scanning 37 | | | Chapter 3: Governance and Regulation. | 41 | | Chapter 4: Security and Privacy. | 47 | | Chapter 5: Disruptive Potential 53 | | | Case study - Diamonds 56 | | | Case study - Corporate actions. | 58 | | Case study - SETLing transactions. | 60 | | Chapter 6: Applications in Government 65 | | | Chapter 7: Global Perspectives. | 73 | | Case study - European energy retail market 76 | | | Case study - Estonian block chains transform paying, | | | trading and signing. | 80 | | References. | 84 | | Acknowledgements. | 87 | A short video has been made to accompany this report which can be viewed at: https://youtu.be/4sm5LNqL5j0 ## Foreword The progress of mankind is marked by the rise of new technologies and the human ingenuity they unlock. In distributed ledger technology, we may be witnessing one of those potential explosions of creative potential that catalyse exceptional levels of innovation. The technology could prove to have the capacity to deliver a new kind of trust to a wide range of services. As we have seen open data revolutionise the citizen's relationship with the state, so may the visibility in these technologies reform our financial markets, supply chains, consumer and business-to-business services, and publicly-held registers. We know there will be challenges as Distributed Ledgers mature and disrupt how we think about and store data. The UK is in a unique position to explore those challenges and help maximise the benefits to our public services and our economy. We already have world-class digital capability, innovative financial services, a strong research community and growing private sector expertise. It is vital that our key assets - including the Alan Turing Institute, Open Data Institute and the Digital Catapult - work together with the private sector and with international partners to unlock the full potential of this technology. We are both, therefore, delighted to be jointly leading efforts in this area, and look forward to working with other departments on seizing the opportunity as well as understanding how its use can be implemented for the benefit of UK citizens and the economy.Picture of Matthew HancockSignature of Matthew Hancock ## Executive Summary And Recommendations Introduction Algorithms that enable the creation of distributed ledgers are powerful, disruptive innovations that could transform the delivery of public and private services and enhance productivity through a wide range of applications. Ledgers have been at the heart of commerce since ancient times and are used to record many things, most commonly assets such as money and property. They have moved from being recorded on clay tablets to papyrus, vellum and paper. However, in all this time the only notable innovation has been computerisation, which initially was simply a transfer from paper to bytes. Now, for the first time algorithms enable the collaborative creation of digital distributed ledgers with properties and capabilities that go far beyond traditional paper-based ledgers. A distributed ledger is essentially an asset database that can be shared across a network of multiple sites, geographies or institutions. All participants within a network can have their own identical copy of the ledger. Any changes to the ledger are reflected in all copies in minutes, or in some cases, seconds. The assets can be financial, legal, physical or electronic. The security and accuracy of the assets stored in the ledger are maintained cryptographically through the use of 'keys' and signatures to control who can do what within the shared ledger. Entries can also be updated by one, some or all of the participants, according to rules agreed by the network. Underlying this technology is the 'block chain', which was invented to create the peer-to-peer digital cash Bitcoin in 2008. Block chain algorithms enable Bitcoin transactions to be aggregated in 'blocks' and these are added to a 'chain' of existing blocks using a cryptographic signature. The Bitcoin ledger is constructed in a distributed and 'permissionless' fashion, so that anyone can add a block of transactions if they can solve a new cryptographic puzzle to add each new block. The incentive for doing this is that there is currently a reward in the form of twenty five Bitcoins awarded to the solver of the puzzle for each 'block'. Anyone with access to the internet and the computing power to solve the cryptographic puzzles can add to the ledger and they are known as 'Bitcoin miners'. The mining analogy is apt because the process of mining Bitcoin is energy intensive as it requires very large computing power. It has been estimated that the energy requirements to run Bitcoin are in excess of 1GW and may be comparable to the electricity usage of Ireland. Bitcoin is an online equivalent of cash. Cash is authenticated by its physical appearance and characteristics, and in the case of banknotes by serial numbers and other security devices. But in the case of cash there is no ledger that records transactions and there is a problem with forgeries of both coins and notes. In the case of Bitcoins, the ledger of transactions ensures their authenticity. Both coins and Bitcoins need to be stored securely in real or virtual wallets respectively - and if these are not looked after properly, both coins and Bitcoins can be stolen. A fundamental difference between conventional currency and Bitcoins is that the former are issued by central banks, and the latter are issued in agreed amounts by the global 'collaborative' endeavour that is Bitcoin. Cash as a means of exchange and commerce dates back millennia and in that respect there is a lineage that links cowrie shells, hammered pennies and Bitcoin. But this report is not about Bitcoin. It is about the algorithmic technologies that enable Bitcoin and their power to transform ledgers as tools to record, enable and secure an enormous range of transactions. So the basic block chain approach can be modified to incorporate rules, smart contracts, digital signatures and an array of other new tools. Distributed ledger technologies have the potential to help governments to collect taxes, deliver benefits, issue passports, record land registries, assure the supply chain of goods and generally ensure the integrity of government records and services. In the NHS, the technology offers the potential to improve health care by improving and authenticating the delivery of services and by sharing records securely according to exact rules. For the consumer of all of these services, the technology offers the potential, according to the circumstances, for individual consumers to control access to personal records and to know who has accessed them. Existing methods of data management, especially of personal data, typically involve large legacy IT systems located within a single institution. To these are added an array of networking and messaging systems to communicate with the outside world, which adds cost and complexity. Highly centralised systems present a high cost single point of failure. They may be vulnerable to cyberattack and the data is often out of sync, out of date or simply inaccurate. In contrast, distributed ledgers are inherently harder to attack because instead of a single database, there are multiple shared copies of the same database, so a cyber-attack would have to attack all the copies simultaneously to be successful. The technology is also resistant to unauthorised change or malicious tampering, in that the participants in the network will immediately spot a change to one part of the ledger. Added to this, the methods by which information is secured and updated mean that participants can share data and be confident that all copies of the ledger at any one time match each other. But this is not to say that distributed ledgers are invulnerable to cyber-attack, because in principle anyone who can find a way to 'legitimately' modify one copy will modify all copies of the ledger. So ensuring the security of distributed ledgers is an important task and part of the general challenge of ensuring the security of the digital infrastructure on which modern societies now depend. Governments are starting to apply distributed ledger technologies to conduct their business. The Estonian government has been experimenting with distributed ledger technology for a number of years using a form of distributed ledger technology known as Keyless Signature Infrastructure (KSI), developed by an Estonian company, Guardtime. KSI allows citizens to verify the integrity of their records on government databases. It also appears to make it impossible for privileged insiders to perform illegal acts inside the government networks. This ability to assure citizens that their data are held securely and accurately has helped Estonia to launch digital services such as e-Business Register and e-Tax. These reduce the administrative burden on the state and the citizen. Estonia is one of the 'Digital 5' or D5 group of nations, of which the other members are the UK, Israel, New Zealand and South Korea. There are opportunities for the UK to work with and learn from these and other like-minded governments in the implementation of block chain and related technologies. The business community has been quick to appreciate the possibilities. Distributed ledgers can provide new ways of assuring ownership and provenance for goods and intellectual property. For example, Everledger provides a distributed ledger that assures the identity of diamonds, from being mined and cut to being sold and insured. In a market with a relatively high level of paper forgery, it makes attribution more efficient, and has the potential to reduce fraud and prevent 'blood diamonds' from entering the market. An important challenge for this new set of technologies is communication of its significance to policymakers and to the public - this is one of the important purposes of this report. The first difficulty in communication is the strong association of block chain technology with Bitcoin. Bitcoin is a type of cryptocurrency, so called because cryptography underpins the supply and tracking of the currency. Bitcoin creates suspicion amongst citizens and government policymakers because of its association with criminal transactions and 'dark web' trading sites, such as the now defunct Silk Road. But digital cryptocurrencies are of interest to central banks and government finance departments around the world which are studying them with great interest. This is because the electronic distribution of digital cash offers potential efficiencies and, unlike physical cash, it brings with it a ledger of transactions that is absent from physical cash. The second difficulty in communication is the bewildering array of terminology. This terminology is clarified by Simon Taylor who has provided a set of definitions at the end of this summary. A particular term that can cause confusion is 'distributed', which can lead to the misconception that because something is distributed there is therefore no overall controlling authority or owner. This may or may not be the case - it depends on the design of the ledger. In practice, there is a broad spectrum of distributed ledger models, with different degrees of centralisation and different types of access control, to suit different business needs. These may be 'unpermissioned' ledgers that are open to everyone to contribute data to the ledger and cannot be owned; or 'permissioned' ledgers that may have one or many owners and only they can add records and verify the contents of the ledger. The key message is that, by fully understanding the technology, government and the private sector can choose the design that best fits a particular purpose, balancing security and central control with the convenience and opportunity of sharing data between institutions and individuals. As with most new technologies, the full extent of future uses and abuses is only visible dimly. And in the case of every new technology the question is not whether the technology is 'in and of itself' a good thing or a bad thing. The questions are: what application of the technology? for what purpose? and applied in what way and with what safeguards? To help answer these questions, the Government Office of Science established a senior group of experts from business, government and academia to assess the opportunities for distributed ledgers to be used within government and the private sector, and to determine what actions government and others need to take to facilitate the beneficial use of distributed ledger technology and to avoid possible harms. The aim was to decrypt the terminology behind the technology for policy audiences and provide policymakers with the vision and evidence to help them to decide where action is necessary, and how best to deploy it. In summary, distributed ledger technology provides the framework for government to reduce fraud, corruption, error and the cost of paper-intensive processes. It has the potential to redefine the relationship between government and the citizen in terms of data sharing, transparency and trust. It has similar possibilities for the private sector. This executive summary now sets out the eight main recommendations from our work. These are presented in the context of a summary of the key points from the seven chapters of evidence which cover vision, technology, governance, privacy and security, disruptive potential, applications and global perspective. The chapters have been written by experts in distributed ledger technology in a style that should be accessible to non-experts. I am extremely grateful to these experts for their guidance and thoughtful contributions. ## Mark Walport, Chief Scientific Adviser To Hm Government, December 2015 Vision Distributed ledgers offer a range of benefits to government and to other public and private sector organisations. As their name implies, they can be distributed extremely widely in a precisely controlled fashion. They are highly efficient because changes by any participant with the necessary permission to modify the ledger are immediately reflected in all copies of the ledger. They can be equally robust in rejecting unauthorised changes, so corrupting the ledger is extremely difficult. However, distributed ledgers should not be seen as an end in themselves. It is only when they have other applications - such as smart contracts - layered on top on them, that their full potential can be realised. The first role for government in supporting the development of distributed ledgers is to develop a clear vision of how this technology can improve the way government does its business and is able to deliver services to citizens. This needs to be followed by government acting as an expert customer to implement the technology - procuring distributed ledger solutions where they are applicable. In doing so, government can support and influence the development of economic activity in this sector, including new and growing businesses as well as larger incumbent businesses. The opportunity is for government to enable a future where the delivery of government services is more personal, immediate and efficient. Wherever appropriate, citizens should have the opportunity to signal their individual preferences and needs through participation in smart contracts. The implementation of distributed ledgers with embedded smart contracts should lead to substantial improvements in compliance, cost-efficiency and accountability. The UK Government Digital Service is developing a digital platform for government to deliver its services and distributed ledgers could be at the heart of this. Recommendation 1: We recommend that government should: • Provide ministerial leadership to ensure that government provides the vision, leadership and the platform for distributed ledger technology within government. Specifically, the Government Data Service should lead work in government as a user of distributed ledgers and the DCMS Digital Economy Unit should lead work on government as an enabler of distributed ledgers (working with the Department of Business, Innovation and Skills and with Innovate UK). • The Government Digital Service and the DCMS Digital Economy Unit should develop a high-level capability road map and a supporting outline plan based on the work of this report and very early stage activity already underway in departments, and deliver this in a timely fashion; and continue to oversee the recommendations made in the rest of this report, to maintain momentum and rapid action. In undertaking this work, they should work closely with other government departments and with industry and academia and should consider setting up a time-limited expert advisory group in support. ## Technology Distributed ledger technology is still at a very early stage of development. The development of block chain technology is but the first, though very important step towards a disruptive revolution in ledger technology that could transform the conduct of public and private sector organisations. The technology can be adopted so that 'legitimate' changes to ledgers can be made in principle by anyone (an 'unpermissioned' ledger), or by a limited number of individuals or even a single authorised person (in a 'permissioned' ledger). For government applications, 'permissioned' ledgers are likely to be more appealing than Bitcoin's unpermissioned model, because they allow the owner, or owners, of the data to enforce rules on who is and is not allowed to use the system. Distributed ledgers have the added advantage of moving a lot of the complexity of managing security into the background, making systems easier and cheaper to use. There are many unsolved problems to tackle before the full potential of this and related technologies can be realised, including the resolution of issues of privacy, security, performance and scalability. There is also an extraordinary array of opportunities to develop algorithms that will add sophistication to ledgers by supporting 'smart' contracts, signatures and other applications. These will enhance and diversify the value and range of uses of ledgers. This field is developing rapidly and many of these problems are already being investigated and, in some cases, solved. If government waits for 'perfect' solutions, it will miss the opportunity to shape and procure implementations of the technology that will provide maximum benefit to the public sector, and the UK may lose opportunities for economic benefit as well. As well as ensuring that the technology is robust and scalable, we need to understand the ethical and social implications of different potential uses and the financial costs and benefits of adoption. With respect to research and development, the UK is in a good position, though we cannot take this for granted as there is interest and competition in development of distributed ledger technology around the world. The research councils are playing an important role, led by the EPSRC and ESRC, supporting research in universities and in the newly-created Alan Turing Institute. There is also an important role for business to invest in research and development, and key opportunities for joint public and private investment to tackle generic problems around security, privacy and the development of standards - all areas where industrial advantage will be gained by co-operation rather than competition. Existing digital investments by the government and private sector include the Digital Catapult, Future Cities Catapult and Open Data Institute. Added to this are groupings such as the Whitechapel Think Tank which can provide a focal point for discussion and sharing ideas. This means that the UK is in a good position from which to build a solid distributed ledger research and testing capability. But there is a danger that we will not get the most from this potentially fragmented activity and there is a strong case that the research and development community in the public and private sectors should 'self-organise' in a way that encourages co-operation where appropriate and competition where it will stimulate the most creative research. Our next two recommendations are aimed at encouraging further research and establishing UK capability to trial and experiment with different distributed ledger solutions: Recommendation 2: The UK research community should invest in the research required to ensure that distributed ledgers are scalable, secure and provide proof of correctness of their contents. They need to provide high-performance, lowlatency operations, appropriate to the domain within which the technology is being deployed. They need to be energy efficient. The newly-created Alan Turing Institute, working with groupings such as the Whitechapel Think Tank, could play an important role in co-ordinating and 'self-organising' the public and private research and development sector interested in this and related technologies. The private sector should consider investing in the Alan Turing Institute to support the pre-competitive research that will ultimately facilitate new commercial applications that are robust and secure. This includes work on obvious areas such as cryptography and cybersecurity but also extends to the development of new types of algorithm. Recommendation 3: Government could support the creation of distributed ledger demonstrators for local government that will bring together all the elements necessary to test the technology and its application. A demonstrator at a city level could provide important opportunities for trialling and implementing distributed ledger technologies. Innovate UK could use its work with cities in the development of 'city deals' to implement the development of a city demonstrator. ## Governance Effective governance and regulation are key to the successful implementation of distributed ledgers. Governance comprises the rules set by the owners and participants of the ledger that safeguard their private interests. This needs to be supplemented by regulation and / or legislation, which comprises the framework of rules that are set by an outside authority to protect the broader interests of society. Government legislates and creates the framework for regulation, singly or in partnership with other governments, and usually creates or enlists a regulator accountable to government to undertake the work. In the case of the digital world, there are two sets of rules or codes that control the operation of digital technologies. The first is the classical set of rules provided by the legislative framework, the code of law and regulation. The second is the set of rules that determine the operation of the algorithms encoded by the software. This is the technical code, and there needs to be at least as much focus on ensuring the rigour of the technical code as on legislative code. Successful implementation of a distributed ledger will require a combination of governance to protect the participants and stakeholders and regulation to ensure the system is resilient to systemic risk or criminal activity. The challenge is to strike the balance between safeguarding the interests of participants in the system and the broader interests of society whilst avoiding the stifling of innovation by excessively rigid structures. There are also opportunities to take advantage of the potential interactions between legal and technical code. For example, public regulatory influence could be exerted through a combination of legal and technical code, rather than exclusively through legal code as at present. In essence technical code could be used to assure compliance with legal code, and, in doing so, reduce the costs of legal compliance. This could provide a 'use case' for the use of technology to enhance regulation, so-called RegTech, which formed one of the key recommendations of the FinTech report from the Government Office for Science1. Determining the optimum balance between governance and regulation, and between legal code and technical code, is going to require unusual mixes of skills, including the need for lawyers, mathematicians and computer experts to work together to resolve many of the key issues, which are outlined in Chapter 3. Recommendation 4: Government needs to consider how to put in place a regulatory framework for distributed ledger technology. Regulation will need to evolve in parallel with the development of new implementations and applications of the technology. As part of the consideration of regulation, government should also consider how regulatory goals could be achieved using technical code as well as legal code. The DCMS Digital Economy Unit could take ownership of this recommendation. ## Security And Privacy Criminals have moved away from cracking metal safes and bank vaults. The money is now in their digital equivalents and these are proving vulnerable to the hackers and crackers of the codes of the digital world. The cryptographic codes of the digital world are extremely hard to break, but however hard these may be, they can be vulnerable to being bypassed. Bypass mechanisms range from the human, who may give away the key accidentally or deliberately, to the presence of 'back doors' due to deficiencies in the software code. The hardware hosting distributed ledgers may provide additional vulnerabilities and equal attention should be paid to the resilience and security of hardware systems. In the case of Bitcoin, the 'wallets' that hold the currency have proved vulnerable to theft - but the ledger itself has remained resilient, though in principle it would be vulnerable if over 50% of the computer processing power for the Bitcoin ledger fell into the hands of a single malevolent individual or organisation. Indeed, a great strength of distributed ledgers is that they should be highly resilient to attack. However, it is not only the integrity of the ledger that matters. Privacy and confidentiality are also key issues. Depending on the nature of the ledger, it may hold personal confidential records that could range from financial to familial and health. The opportunity is for distributed ledger technologies to provide much greater security for these data than is available in current databases, but this is not a given. This is another area where much research and development is needed as part of the development of the technology. Security and privacy are areas where Government has an important role to play, so our next recommendation is: Recommendation 5: Government needs to work with academia and industry to ensure that standards are set for the integrity, security and privacy of distributed ledgers and their contents. These standards need to be reflected in both regulatory and software code. For each particular use of the technology, government and private sector users, as appropriate, should conduct a bespoke risk assessment to identify the relevant threats. The Centre for the Protection of National Infrastructure (CPNI) and CESG should keep a watching brief on distributed ledger technology and play a central role inside and outside government in providing expert advice on ensuring the integrity, security and privacy of distributed ledgers. As suggested in recommendation 2, the newly created Alan Turing Institute, working with groupings such as the Whitechapel Think Tank and with CESG could play an important role in co-ordinating and 'self-organising' the public and private research and development sector. It must not be overlooked that the software and hardware systems can become degraded over time, as better technology emerges and hostile agents learn 'new tricks'. So for systems intended to have a long lifetime, the initial design should make it straightforward to update hardware and software components during that lifetime. Additionally, as part of trialling new implementations of the technology, it is important to include penetration testing at both the system and user levels. ## Trust And Interoperability As set out in Chapter 7 on global perspectives, trust is a risk judgement between two or more people, organisations or nations. In cyberspace, trust is based on two key requirements: prove to me that you are who you say you are (authentication); and prove to me that you have the permissions necessary to do what you ask (authorisation). In return, I will prove to you that I am trustworthy by delivering services or products to you in a secure, efficient and reliable fashion. Authentication and identification are interlinked but they are not the same thing. Authentication does not require that I know your identity but it does require that you provide me a token that is inextricably linked to your identity, for example the pin number associated with a credit or debit card, or a fingerprint allied to a biometric passport or other document. Equally, when I provide my authentication token to you, I need assurance that I am providing it to the correct individual or organisation, ie that you are who you claim to be. So it is equally important that organisations can provide authentication to their users, be they individuals, other organisations or government. The opportunity in the digital environment is to use and create much more powerful and robust identity management tools that provide authentication whilst protecting privacy. One such system is public key infrastructure (PKI) relying on a cryptographic standard called X.509. Organisations using PKI can federate in order to provide, share and potentially simplify the secure delivery of services or products. Another important international standard is being developed for organisational identification, known as the Register of Legal Organisations (ROLO), and this may help to underpin the authentication of organisations as opposed to individuals. Another key enabler of secure authenticated interactions by individual users is the use of smartphones as the *de facto* trusted user device. The latest smart phones incorporate important security features such as a 'Trusted Platform Module', which secures digital certificates and cryptographic keys for authentication, encryption and signing, and a 'Trusted Execution Environment' and a 'Trusted User Interface', each of which are resistant to interference by 'malware'. This discussion of authentication shows that, in order to maximise the power of distributed ledgers, these may need to be interoperable with other ledgers. However, maximising the potential of interoperability goes far beyond interoperability of authentication - it requires agreements about data interoperability, policy interoperability and the effective implementation of international standards. Recommendation 6: This recommendation is linked to Recommendation 5. Government needs to work with academia and industry to ensure that the most effective and usable identification and authentication protocols are implemented for both individuals and organisations. This work needs to go hand in hand with the development and implementation of international standards. ## A Disruptive Future - Some Potential Use Cases For Government Distributed ledgers have the potential to be radically disruptive. Their processing capability is real time, near tamper-proof and increasingly low-cost. They can be applied to a wide range of industries and services, such as financial services, real estate, healthcare and identity management. They can underpin other softwareand hardware-based innovations such as smart contracts and the Internet of Things. Furthermore, their underlying philosophy of distributed consensus, open source, transparency and community could be highly disruptive to many of these sectors. Like any radical innovation, as well as providing opportunities distributed ledgers create threats to those who fail or are unable to respond. In particular, through their distributed consensual nature they may be perceived as threatening the role of trusted intermediaries in positions of control within traditionally hierarchical organisations such as banks and government departments. With its wide range of stakeholders, services and roles, the government has a multitude of different operations. Some distribute value rather than create it, and others create and maintain effective regulatory regimes. Many of these activities will be enhanced by innovations afforded by distributed ledgers, and others will be challenged. Ultimately, the best way to develop a technology is to use it in practice. The expert group that supported the development of this report has scoped some specific examples of potential uses by the UK government, and these are set out in five use case studies in Chapter 6 • protecting critical infrastructure against cyberattacks • reducing operational costs and tracking eligibility for welfare support, while offering greater financial inclusion • transparency and traceability of how aid money is spent • creating opportunities for economic growth, bolstering SMEs and increasing employment • reducing tax fraud Each of these case studies provides an overview of the distributed ledger proposition, its potential benefits and an assessment of the maturity level of the technology to deliver the application. Only a tiny fraction of the possible applications are identified in this report but we believe they provide a good starting point for government to start piloting the technology within departments. So our final set of recommendations are aimed at implementing trials of distributed ledger technology and developing government capability: Recommendation 7: Understanding the true potential of distributed ledgers requires not only research but also using the technology for real life applications. Government should establish trials of distributed ledgers in order to assess the technology's usability within the public sector. We suggest that the trials should be co-ordinated in a similar fashion to the way that clinical trials are implemented, reported and assessed, in order to ensure uniformity and maximize the rigour of the process. The outcome of these trials and the lessons learnt should feed into the road-map proposed in Recommendation 1. Areas where we believe work could be taken forward include the protection of national infrastructure, reducing market friction for SMEs and the distribution of funds from DWP and other government departments. During the development of this report, we found a small number of officials who are already thinking deeply about potential uses for distributed ledger technology by government. We recommend that these individuals be strongly supported and encouraged to move ahead in partnerships between government departments and GDS. Recommendation 8: As well as top-down leadership and coordination, there is also a need to build capability and skills within government. We recommend the establishment of a cross-government community of interest, bringing together the analytical and policy communities, to generate and develop potential 'use cases' and create a body of knowledge and expertise within the civil service. GDS and the Data Science Partnership between GDS, Office for National Statistics, Cabinet Office and the Government Office for Science could act as the convenors of this community of interest. There are important opportunities for government to stimulate the business sector by acting as a smart customer in procuring distributed ledger applications. ## Conclusion - Taking A Global Perspective The UK is not alone in recognising the importance of distributed ledger technologies. Other countries, large and small, are already moving quickly to adopt distributed ledgers - and the case study of Estonia shows how quickly a small country with an effective digitally-aware leadership can progress. However, there is still time for the UK to position itself within this leading group - indeed, it is essential for it to do so, given the importance of the financial and services sector to the UK economy. Patrick Curry, Christopher Sier and Mike Halsall have considered in Chapter 7 the features of advancing digital nations and argue that the hallmarks of these include: • A digitally-informed leadership • An empowered focused government department for all national digital transformation, which is internationally minded and collaborates closely with all industry sectors • A living, collaborative national plan, which is industry-led with government investment • Technologically aware, qualified and experienced senior political officials in every government organisation • Engineers and digital business leaders as politicians We are still at the early stages of an extraordinary post-industrial revolution driven by information technology. It is a revolution is bringing important new benefits and risks. It is already clear that, within this revolution, the advent of distributed ledger technologies is starting to disrupt many of the existing ways of doing business. The earliest accounting records of humans date back to Babylon, Assyria and Sumer, over 5000 years ago. Many clay tablets have survived as a record of the early technological revolutions in the development of writing, counting and money. It is less clear whether digital records will have the same longevity as clay tablets. But, leaving that aside, it is clear that there is a huge opportunity for the UK to develop and use distributed ledger technology for the benefit of citizens and the economy. There are a series of 'grand challenges' to tackle to maximise the benefits and minimise the harms of the extraordinary developments in information technology. This report sets out some key recommendations for the government, based on expert evidence. The most important of these is the need for close partnership between the public and private sector, within the UK and between the UK and other nations. ## Definitions The terminology of this new field is still evolving, with many using the terms block chain (or blockchain), distributed ledger and shared ledger interchangeably. Formal definitions are unlikely to satisfy all parties - but for the purposes of this report, the key terms are as follows: • A **block chain** is a type of database that takes a number of records and puts them in a block (rather like collating them on to a single sheet of paper). Each block is then 'chained' to the next block, using a cryptographic signature. This allows block chains to be used like a **ledger**, which can be shared and corroborated by anyone with the appropriate permissions. There are many ways to corroborate the accuracy of a ledger, but they are broadly known as **consensus** (the term 'mining' is used for a variant of this process in the cryptocurrency Bitcoin) - see below. If participants in that process are preselected, the ledger is **permissioned**. If the process is open to everyone, the ledger is **unpermissioned** - see below. The real novelty of block chain technology is that it is more than just a database - it can also set rules about a transaction (business logic) that are tied to the transaction itself. This contrasts with conventional databases, in which rules are often set at the entire database level, or in the application, but not in the transaction. • **Unpermissioned ledgers** such as Bitcoin have no single owner - indeed, they cannot be owned. The purpose of an unpermissioned ledger is to allow anyone to contribute data to the ledger and for everyone in possession of the ledger to have identical copies. This creates censorship resistance, which means that no actor can prevent a transaction from being added to the ledger. Participants maintain the integrity of the ledger by reaching a consensus about its state. Unpermissioned ledgers can be used as a global record that cannot be edited: for declaring a last will and testament, for example, or assigning property ownership. But they also pose a challenge to institutional power structures and existing industries, and this may warrant a policy response. • **Permissioned ledgers** may have one or many owners. When a new record is added, the ledger's integrity is checked by a limited consensus process. This is carried out by trusted actors - government departments or banks, for example - which makes maintaining a shared record much simpler that the consensus process used by unpermissioned ledgers. Permissioned block chains provide highly-verifiable data sets because the consensus process creates a digital signature, which can be seen by all parties. Requiring many government departments to validate a record could give a high degree of confidence in the record's security, for example, in contrast to the current situation where departments often have to share data using pieces of paper. A permissioned ledger is usually faster than an unpermissioned ledger. • **Distributed ledgers** are a type of database that is spread across multiple sites, countries or institutions, and is typically public. Records are stored one after the other in a continuous ledger, rather than sorted into blocks, but they can only be added when the participants reach a quorum. A distributed ledger requires greater trust in the validators or operators of the ledger. For example, the global financial transactions system Ripple selects a list of validators (known as Unique Node Validators) from up to 200 known, unknown or partially known validators who are trusted not to collude in defrauding the actors in a transaction. This process provides a digital signature that is considered less censorship resistant than Bitcoin's, but is significantly faster. • A **shared ledger** is a term coined by Richard Brown, formerly of IBM and now Chief Technology Officer of the Distributed Ledger Group, which typically refers to any database and application that is shared by an industry or private consortium, or that is open to the public. It is the most generic and catch-all term for this group of technologies. A shared ledger may use a distributed ledger or block chain as its underlying database, but will often layer on permissions for different types of users. As such, 'shared ledger' represents a spectrum of possible ledger or database designs that are permissioned at some level. An industry's shared ledger may have a limited number of fixed validators who are trusted to maintain the ledger, which can offer significant benefits. • **Smart contracts** are contracts whose terms are recorded in a computer language instead of legal language. Smart contracts can be automatically executed by a computing system, such as a suitable distributed ledger system. The potential benefits of smart contracts include low contracting, enforcement, and compliance costs; consequently it becomes economically viable to form contracts over numerous low-value transactions. The potential risks include a reliance on the computing system that executes the contract. At this stage, the risks and benefits are largely theoretical because the technology of smart contracts is still in its infancy, and some time away from widespread deployment. Digital currencies such as Bitcoin rely on an underlying technology called a block chain. This records every transaction made in identical copies of a digital ledger that is shared among users. This 'shared ledger' approach could streamline a plethora of different services, both in government and the wider economy. Author Simon Taylor, VP for Blockchain R+D, Barclays ## Chapter 1: Vision Introduction Digital currencies such as Bitcoin have pioneered a new approach to tracking financial transactions. Their underlying technology - commonly called a block chain - records every transaction made in that currency in identical copies of a digital ledger that is shared among the currency's users. Financial institutions, regulators, central banks and governments are now exploring the possibilities of using this 'shared ledger' approach to streamline a plethora of different services, both in government and the wider economy. Many of these potential applications are medium-term prospects, but the long development cycles for government and the private sector, and the early promise that significant efficiencies could be gained, suggest that ministers and civil servants must now begin to consider how this technology could benefit them. This chapter outlines those opportunities. ## What Is A Shared Ledger? A shared ledger is essentially a database that keeps track of who owns a financial, physical or electronic asset: a diamond, a unit of currency, or items inside a shipping container, for example. Crucially, every participant can keep a copy of the block chain, which is updated automatically every time a new transaction occurs. The security and accuracy of the information is maintained through mathematics - specifically by cryptography - to ensure that all copies of the ledger match each other. Almost anything that exists on paper today could exist on a shared ledger (see Chapter 2 for a more detailed discussion of shared ledger technology). Since its launch in 2008, Bitcoin has relied on block chain technology. Many clichés and misconceptions have grown up around the digital currency and its underlying principles. Its associations with Silk Road, the digital black market, have left some people with the impression that Bitcoin is intrinsically linked to money laundering and terrorists. That misconception continues to affect how people think about block chain technology. In fact, shared ledgers and databases may offer some major benefits to government and financial services, thanks to four important properties of block chain technologies. 1) **Reconciliation Through Cryptography**. Institutions such as businesses and governments currently send messages to each other to pass on details of transactions. Once the message is received, each institution then updates its own ledger. But today, there is no easy way to ensure that these copies match. Block chains can solve this in a number of ways: by simply sharing the same underlying data, for example, or by providing 'proof points' to verify the data. This approach could also be applicable to government data sets. The different actors (users) of the ledger come to a consensus about the state of the underlying data through a number of different consensus algorithms (eg Proof of Work, Proof of Stake, Practical Byzantine Fault Tolerance). 2) **Replicated to Many Institutions**. Many parties can have a copy of some or all of the data, making it less likely that there is a single point of failure. Replication is a significant challenge for current database technologies, creating cost and complexity in industry and government IT projects. An additional benefit of this technology is that if one ledger is compromised, the remainder are not. Many parties can also confirm that those records have been added by performing the reconciliation calculations themselves. 3) **Granular Access Control**. Distributed ledgers use 'keys' and signatures to control who can do what inside the shared ledger. These keys can be assigned specific capabilities only under certain conditions. For example, a regulator may have a 'view key' that allows it to see all of an institution's transactions, but only when a key owned by a court gives it permission (control) to do so. 4) **Granular Transparency and Privacy**. Because many parties have a copy of the ledger (point 1), and many parties can verify every record (point 2), a shared ledger has a high degree of transparency. This allows a regulator or an independent body such as the judiciary to see with confidence that the contents of a database had not been edited or modified in any fraudulent way. Given the right conditions, it also allows them to unlock records that would otherwise be completely private and un-viewable. This could be useful for businesses (eg banks) in their regulatory reporting, fraud prevention, and could even empower citizens to hold the government to account (see Chapter 5 for a more extensive discussion). Records are added with a unique cryptographic signature that proves the right participant has added the right record according to the right rules. When combined, these properties can solve challenges that were previously very expensive or challenging. ## What Is A Smart Contract? If a block chain is the database, then the smart contract is the application layer that makes much of the promise of block chain technology a reality. Most conventional contracts have no direct relationship with the computer code that executes them (see Chapter 3). In many cases the paper contract is archived, and the software will execute an approximation of the contract's terms written in computer code (see Fig. 1). Figure 1: Conventional contracts have no direct relationship with the computer code (app) that executes them. This is quite effective when signing up to use a service (eg video on demand), but highly challenging when delivering multiple complex services to one user (eg updating an address in multiple government department databases). This has resulted in ever more complex data protection and data privacy legislation to manage the confidentiality and privacy of the individual in an assured way. In addition, activities like data sharing or agreeing contracts have remained in paper form, rather than being automated in the wider economy. Combining the key attributes of a shared ledger (reconciliation through cryptography, replicated to many institutions, granular access control, Figure 3: Smart contracts can control which institutions access private data. and granular transparency and privacy) with smart contracts may create opportunities to address some of these challenges, by allowing data to either be replicated or shared under specific conditions. If two users sign a smart contract, it will then contain logic that operates on the data in all parts of the shared ledger (see Fig. 2). This could facilitate the automation or removal of manual process in government and private sector institutions, which may drive efficiencies in productivity and growth. Note there are other challenges like management of legacy databases and processes, but the "permissioning" across multiple systems is where Smart Contracts come into their own. In an alternative scenario (Fig. 3), User 1 opts in to a smart contract on a shared ledger to share their address with an institution that possesses a blue key (there may be many other institutions, with many different keys). But User 2 has opted out of sharing their address, so the institution only receives a copy of the latest address from User 1. This may be useful when an individual changes their address via their local council, because the change could be reflected on their passport, drivers licence and other key department databases. Services such as Onename.io use this concept today with social networks, and it could be extended to all institutions. Smart contracts are being considered for a wide variety of uses, particularly for regulatory compliance, product traceability and service management, and also to defeat counterfeit products and fraud in the following sectors: • Food • Financial Services • Energy • Pharmaceuticals • Health • Aerospace • Aviation • Telecommunications • IT and communications • Transport • Utilities • Agriculture • Oil and gas Some of these are discussed later in this chapter, and in Chapters 6 and 7. In summary, a smart contract is useful when machines, companies or people want to create a digital agreement, with cryptographic certainty that the agreement has been honoured in the ledgers, databases or accounts of all parties to the agreement. ## A Vision For The Future A key role of democratic government is the appropriate distribution of resource among its citizens, both individual and corporate. This goes beyond the distribution of monetary resource and includes social intangibles such as security, democracy, the conditions for the maintenance of the rule of law; and economic conditions such as the promotion of free markets, keeping inflation low and steady, protecting the rights of private property, and guaranteeing contracts. This distribution in turn is based on an agreement between the citizen and the government on how rules are set (through voting and manifestos). As that democratic model has developed, the machinery of government (ie the mechanism by which this distribution takes place) has become larger, more centralised and, arguably, more remote from the individual citizen. The collection of (monetary) resource through taxation of various kinds has become hugely complex and costly, as has its distribution through welfare support, grants and pensions. This complexity may in part derive from its centralised nature. The private sector has started to recognise that this centralised model delivers poor customer service, is no longer economic and also fails to take into account the full benefits of e-commerce and digital capability. Governments are beginning to recognise that citizens' expectations should be met in similar ways, with real time, personal and digital services offered for all government services. Application of shared ledgers and smart contracts offers the opportunity to put government in the lead in this area, ensuring that the benefits of the technology are enjoyed by those who need it most, not just those who can best afford them. This trend is also apparent in the growth of the less-formal 'sharing economy', and in popular, social-media led phenomena such as the Arab spring and the Occupy movement. These show a shift in how society communicates and organises itself. To date, however, there has been no successful way to embrace these in a secure way while continuing to promote free markets and guarantee contracts. It is often said that the reason we have never shifted democracy online is because there is no way to be sure who is voting for what without a highly costly and arguably non-libertarian centralised identity system. Assuming this is undesirable, the properties of block chain technology (reconciliation through cryptography, replicated to many institutions, granular access control, and granular transparency and privacy) could be turned to the benefit of citizens. In addition, the early involvement of government in the development and deployment of block chain technology offers an opportunity for reducing the complexity and cost of government. That would lead to a more personal, immediate and potentially more democratic basis for governance, with consequent increases in compliance, cost-efficiency and accountability. ## Steps Towards Embracing Block Chain Technology Shared ledger technology is being actively promoted and developed in key global economies such as the United States, China, Singapore and Latin America. The UK has an opportunity to compete in this race by understanding and supporting the growth of this nascent sector. The government's potential involvement in distributed ledger technology can be seen through three lenses: • Government: the civil service • Government: the legislator • Government: the steward of the economy ## Government: The Civil Service The civil service has a number of key duties that could be impacted by this technology, with strong use cases focusing on the nexus of privacy, data portability and the sensory capabilities of mobile technology (see Chapter 6 for more detailed case studies). ## Government: The Legislator Distributed ledger technology is still young, and likely to see several more cycles of development. As such, the government's actions can target three separate 'horizons' in the technology development process. Horizon 1: Supporting an Emerging Ecosystem There are already a number of digital currency exchanges, 'wallet' providers and other service providers both in the Bitcoin ecosystem and in other shared ledger systems. Recognising that the technology and businesses will continue to mature, Horizon 1 activities may include: • Requiring exchanges to verify the identities of their customers (known as KYC, or 'Know Your Customer' regulation). • Issuing guidance for the banking sector to demonstrate the difference between the types of companies in this space: (i) those who transfer value via block chain systems; (ii) those who provide software to industries that use block chains; (iii) those who provide block chain-based software to solve conventional business problems. • Establish security standards for wallet providers. • Creating challenges for academia and the start-up ecosystem to look at specific gaps in the block chain ecosystem, such as: (i) establishing the appropriate technical architectures; (ii) establishing how the technology could enhance efforts to improve customer identity verification, tackle money laundering, and prevent crime; (iii) establishing how the use of multi-signature wallets can create new government–citizen user experiences and empower citizens to control and audit their own data held by the government. • Leveraging partners to sustain a co-ordinated conversation between the government and industry. Horizon 2: Early Trials and Pilots Where the government has specific opportunities it may wish to begin performing local trials of use cases. Particular questions the government may want to consider are: • What key utilities could benefit from shared ledger / database technology? • Where might a trial support policy (eg pension reform, welfare reform)? • Where can a trial offer the greatest learning opportunity? Horizon 3: Position the UK as a Leader in the Global Race Much of the venture capital investment in distributed ledger technology has to date focused on Bitcoin, and the west coast of the United States. But the emerging opportunities for this technology lie in other applications. • The UK should recognise this nuance and create guidance to that effect through its regulatory bodies (see Chapter 3 for more on governance and regulation). • The UK could create a centre of excellence for these technologies and add this to the global FinTech / UK Trade and Investment agenda. ## Government: The Steward Of The Economy To understand how the government can best promote and realise the benefit of this technology, it will be helpful to look at use cases in two different areas: financial services; and insurance and other industries. Financial Services Examples of where the technology could be applied to the finance sector include: • Increased efficiency in capital markets • Reduced fraud and increased efficiency in trade finance ## 1. Increased Efficiency In Capital Markets Capital markets still rely on paper records to reconcile a trade between counterparties. While central utilities have been created in the past, the ability to reconcile ('clear') a transaction and be sure that the counterparty has agreed is significant because today it requires reliance. Many of the fines and much of the fixed cost base of banking is based on the concept of reliance. In essence, one bank must rely on the processes of another bank and has no way to verify the behaviour of that bank. A block chain technology can help by showing the chain of transactions (reconciliation through cryptography), and the actors involved, in a way that is transparent to a regulator. In addition, auditing this data is expensive and happens after the trade has taken place. The large banks are now finding appropriate vehicles to collaborate on this technology to unlock efficiencies. ## 2. Reduced Fraud And Increased Efficiency In Trade Finance Trade finance still operates in much the same way as it has for thousands of years. There are often at least 5 or 6 parties involved in the buying or selling of a particular item (eg the buyer, the buyer's bank, the shipping company, the courier, the seller and the seller's bank). There have been attempts to both standardise and create central utilities in trade finance. Shared ledgers offer some unique advantages. • A 'partially permissioned' system could enable the secure signing of a paper document (eg a bill of lading stating which products were in a container, how many, what colour etc). This could then be signed (provably and digitally) by each of the parties. (Key properties: High Transparency; Reconciliation Through Cryptography) • Rather than simply storing the documents, as is done today, a shared ledger system would record proof of the state of those documents. If adopted more widely, the documents could be distributed via the shared ledger, rather than printed and signed. (Key properties: **Highly Scalable and Replicable**) ## Industry And Institutions 1. Asset Tracking And Provenance Assurance Many items, such as fine art or consumer electronics, physically carry digital markers. There is, however, no global utility to track and trace these items that would offer control of the permissions that determine who can see which assets are being managed. Many organisations rely on paper documents to prove the origins of produce. But there is no way to verify these origins if the paper trail is forged. If parts of that supply chain used a shared ledger, and 'signed' the ledger digitally, it would be clear to all parties that the documents had not been amended or forged in any way. For example, Provenance.org is a start-up using block chain technology to give retailers confidence in the provenance and sustainability of garments. Retailers currently rely on paper documents to confirm the provenance of garments, but there is no way to ensure that the right person completed those documents, at the right time. Using block chain technology, the appropriate person could digitally sign a contract with their private key, giving a far higher confidence that the right person signed the document at an exact date and time. The nature of block chain technology means that this would be visible to all retailers who had the appropriate privileges. ## 2. Confidential Use Of Data With User Control Data accuracy and confidential data sharing are key challenges for institutions. Insurance companies can create more accurate products, prices and premiums if they have additional data that is validated as accurate by one or more trusted sources (eg governments or banks). The difficulty has been to do this in a secure way while ensuring that the citizen remains in control of their data. A block chain would provide proof of how every piece of data was accessed, perhaps using a solution such as Guardtime. Using trusted execution environments (TEEs) in mobile phones, such as ARM's TrustZone chip, any request to access data held in government would be recorded in a block chain. Unless the citizen had granted permission to the insurance company, this data would not move. If any attempt to change or access the data is made, the citizen or relevant authorities would be made aware immediately. Shared ledger technology, when combined with simple mobile user interfaces, potentially moves a lot of the complexity of managing security into the background. The institutions that choose to adopt this way forward will need to win the confidence of the public, and early trials and implementations will be helpful in achieving this. ## 3. Industrial Equipment (A Linked 'Internet Of Things') It can be difficult to gather accurate, real-time data about industrial equipment across many sectors, including transport, utilities and agriculture. With the advent of the Internet of Things (IoT), some of these difficulties are being addressed with low-cost commodity hardware, but this is potentially vulnerable to attack. According to a recent report2 from the IBM Institute for Business Value: "The result: a proliferation of hundreds of billions of devices that will be no more expensive than their dumb counterparts, yet able to operate and act as part of complex, integrated systems." "In a network of the scale of the IoT, trust can be very hard to engineer and expensive, if not impossible, to guarantee. For widespread adoption of the ever-expanding IoT, however, privacy and anonymity must be integrated into its design by giving users control of their own privacy. Current security models based on closed source approaches (often described as "security through obscurity") are obsolete and must be replaced by a newer approach - security through transparency." "In our vision of a decentralized IoT, the blockchain is the framework facilitating transaction processing and coordination among interacting devices. Each manages its own roles and behavior, resulting in an "Internet of Decentralized, Autonomous Things" - and thus the democratization of the digital world" If each device functions both as an autonomous agent, and a part of the whole, there is no central point of failure. In this use case, institutions would apply IoT devices and gain many of the benefits associated with real time data and connectivity outlined in the recent Government Office for Science report on the IoT3. Shared ledger and block chain technology provide new business and technology models for higher security implementation of IoT. Example 1: A tractor that operates as an autonomous unit can authorise access to multiple farmers in an area, enabling a pay per use model. It has the ability to discover and pay for climate data, and communicate with its manufacturer for maintenance and repairs. Example 2: Industrial equipment can be empowered to order new parts, as long as there is certainty that that device is genuine and has the authority to do so. This may also lead to new ways of financing such equipment, and new marketplaces based on the equipment's performance or efficiency. ## Conclusion It is possible to envision a future where this technology creates a form of 'glass government' that is more accountable to the citizen. There are a number of use cases, and as the technology progresses it is almost certain more will emerge. This may help to achieve policy objectives. The key points for ministers and the civil service are: The technology is in its early stages but shows significant promise. To unlock the promise of block chain technology, it is essential to understand how the combination of: • Reconciliation through cryptography • Large scale, secure replication of data • Provable Transparency can be used over three horizons: • Supporting the emerging ecosystem • Early trials and pilots • Positioning the UK as a global leader ## Technology Physical cash is unlike any other form of money. It can be transferred between two people without the involvement or permission of any third parties such as banks or governments. Bitcoin and its block chain have shown us how to perform this trick electronically. But the implications and opportunities of this digital technology are much broader. Chief Technology Officer, R3 ## Chapter 2: T Echnology Introduction Bitcoin is a new form of **digital cash**. Rather than being issued by a central bank, such as the Bank of England, its issuance is controlled by a **decentralised** network of computers. This network relies on cryptography and other techniques to regulate the supply of Bitcoins and keep track of who owns them. Bitcoin is consequently known as a **cryptocurrency**. Banks keep track of customer balances on a **ledger**. Bitcoin also uses a ledger, but it is maintained collaboratively by the decentralised network of computers, and is known as a **distributed ledger**. As new batches of entries are added to the distributed ledger, they include a reference back to the previous batch, so that all participants can verify for themselves the true provenance of everything on the ledger. These batches are called **blocks**, and the whole collection is a **block chain**. This chapter will explain more about these concepts, why they are important, and how they might form the basis of a much broader suite of applications. ## What Is Money? A £20 note is an extraordinary thing. Simply handing the note to someone instantly transfers £20 of value to them, without requiring a third party to verify the transaction. If the two people were alone, nobody else in the entire world need know it had happened, and nobody could have stopped the transfer. But this peer-to-peer transfer only works at close distance. To transfer £20 of value to somebody in a different town or country, we need to trust other people and cede some degree of control to them: the postal worker who handles an envelope containing the cash, or the bank that carries out an electronic funds transfer. Indeed, if the bank believes that the money is connected to illegal activities, it can block the electronic transaction or seize electronic funds. The world's financial plumbing - payments systems, the working relationships between banks, electronic communication networks such as SWIFT (the Society for Worldwide Interbank Financial Telecommunication) - are a direct consequence of the fact that physical cash really is fundamentally different to every other form of money. Only physical cash is a bearer instrument. And only physical cash can be transferred without someone else's permission - it is 'censorship resistant'. Or so we thought until late 2008, when Bitcoin was announced. Its creator claimed that it was a system of "purely peer-to-peer electronic cash", which could be controlled outright by the holder, and sent to anybody without needing a bank's permission or running the risk of confiscation. Every full participant in the Bitcoin system has a copy of every transaction, arranged in 'blocks', going all the way back to the start of the system. Each block is cryptographically linked to the previous block, forming a block chain that maintains a full history of transactions, and therefore acts as a distributed ledger. Users can access the ledger with a variety of different applications (such as Coinbase or Blockchain - not to be confused with the underlying technical concept), and every copy of the ledger is synchronised by algorithms set up to reach 'consensus' about the state of the ledger. Bitcoin did not appear out of nowhere in 2008. Research into digital currency systems goes back decades, and each of the components of the system already existed. Bitcoin's breakthrough was to combine existing techniques in an innovative way, and to do so at a time when the idea of open source development on the internet was mature, and when people were receptive to the idea of alternative monetary systems. The system is designed so that it becomes progressively harder - effectively impossible - for older blocks to be rewritten. Once a transaction is sufficiently confirmed, it can never be reversed, rendering it censorship resistant. In short, it truly is digital cash. ## Faq Little wonder, then, that governments and regulators around the world have viewed this invention with such caution. A censorship resistant, digital bearer asset would seem to be an ideal currency for criminal networks, and Bitcoin became the primary monetary unit of Silk Road, the now-defunct digital black market. What is 'the block chain'? A block is simply a list of payments. A block chain is a list of blocks, each one referring back to the one that went before. However, when people talk about the block chain, they tend to mean the collection of technologies and techniques that underpin the Bitcoin system, which other projects have used as inspiration because they solve unrelated problems in finance and elsewhere. Yet most regulators, including multiple agencies in the UK, have chosen not to ban Bitcoin, and many legitimate companies are investing heavily in this form of technology. Why? ## Opportunity Or Threat? Firstly, these systems are not as uncontrollable - or 'unpermissioned' - as one might expect. Contrary to public perception, the underlying architecture makes it relatively easy to track transactions and establish the identity of people who misuse the system. Regulators have also learned how to control the 'on-ramps' and 'off-ramps' where value flows in and out of the system. Platforms like Bitcoin may sound alarming at first, but users are not guaranteed anonymity and if they want to convert their bitcoins into pounds, dollars or euros then the exchange systems are expected to enforce relevant regulations regarding identity, money laundering and terrorist financing. Furthermore, and as will be argued shortly, many of the most interesting applications of this technology enforce rules about who is and is not allowed to use the system. The second emerging belief is that the technology underpinning Bitcoin could have valuable and benign uses, and could enable significant future innovation. Bitcoin's censorship resistance is problematic from a law-enforcement and regulation perspective, and it is therefore unlikely that major corporates or banks will engage closely with Bitcoin or related technologies in the short to medium term. But the distributed ledger technology behind cryptocurrencies offers an openness that could be immensely valuable. Open platforms, controlled by no one firm and with a thriving community of developers, have been shown time and again to be drivers of innovation. They can enable outsiders and new entrants to offer new products and services for previously marginalised users (see Chapter 5 for more on the technology's disruptive potential). ## Faq FAQ: What fundamentally differentiates Bitcoin from previous currencies? Bitcoins can be owned by any individual, without permission from any bank or government. They can be sent to anybody else in the world who knows how to operate a 'Bitcoin wallet'. It is this principle of 'censorship resistance' that captures Bitcoin's essential breakthrough - and which explains early concerns by lawmakers and regulators. Although distributed ledger technology was invented to satisfy one goal (digital cash), firms and other institutions are now actively exploring how it can be applied to a variety of other pressing problems. For example, businesses often find 'permissioned' block chains far more appealing than Bitcoin's unpermissioned model, because specific parties are authorised to verify transactions. This allows the businesses to create secured, private networks involving mutually trusting firms and individuals (for a more extensive discussion of permissioned and unpermissioned systems, see Chapter 3). Overall, it is clear that there could be a continuum of technologies in this space, which can be categorised by how 'decentralised' they are (ie to what extent are they truly permissionless) (see Fig. 1). But centralisation is just one dimension along which this domain can be analysed. Other categories under active exploration include the degree to which use of funds can be prescribed (eg funds that can only be spent by a child if a parent co-signs) and the possibility of representing assets other than money (eg securities or even title to property). ## Potential Applications Distributed ledger technology could solve business problems that can be summed up as cost, duplication and reconciliation. Take banking. Every bank has built or bought at least one (usually several) systems to track and manage the lifecycles of their financial transactions. Each of these systems cost money to build and even more to maintain. They must be connected to each other and synchronised, usually through a process known as reconciliation. This involves teams of people in each bank checking with their counterparts in other banks to make sure everything matches, and to deal with the problems when it does not. A common solution involves setting up a single, centralised ledger shared by all participants. The UK has had a number of successes that rely on this approach, especially in the Faster Payments Service. But centralised utilities are typically expensive and, as their data and processing is centralised, they often must be integrated with each participant's own systems. Alternatively, many decentralised databases can sit around the edges of a network while messages move between them (see Fig. 2). Bitcoin, in contrast, synchronises thousands of computers in a distributed network via the internet: if my computer thinks that I own a Bitcoin, then so does every other computer in the network. If a similar technique could be used in banking, all the banks' systems could stay in step with each other without requiring armies of people to reconcile and resolve the issues. Crucially, we do not need Bitcoin to achieve this - it is the underlying distributed ledger technology that offers a possible solution. This could help to tackle one of the biggest problems with financial services: the costs of using paper. In recent years, there have been many different initiatives intended to remove paper documents from the economy. However, in many cases the new technology has simply recreated old processes in a new way, or continues to rely on paper in other stages of the process. For example, providing finance to exporters remains an extremely manual process: an importer's bank often issues a letter of credit, against which the exporter's bank will advance funds. Although this process is usually electronic, the subsequent verifications rely on bundles of paper documents that are manually processed around the world. A shared ledger technology could, in contrast, replace certain aspects of paper-based banking with processes that operate in a much speedier and paper- ## Case Study Research And Horizon Scanning John G Baird, Lead for the RCUK Digital Economy Theme, EPSRC The Engineering and Physical Sciences Research Council (EPSRC) leads the Digital Economy (DE) Theme on behalf of Research Councils UK (RCUK). Since 2008, the DE Theme has invested over £170 million in applied multidisciplinary research, with a particular focus on societal challenges around the digitisation of the economy and its effects on social inclusion, rural economy, personal data, security, identity, trustworthiness and privacy. The DE Theme is leading on taking forward both the Digital Currencies and the Internet of Things activities announced in the March 2015 Budget. In the area of distributed ledger technologies, to date we have invested in the following activities: 1. Cryptocurrency Effects in Digital Transformations (CREDIT)1, an 18-month £0.4 million research project that aims to investigate the phenomena of cryptocurrencies and their associated underlying technology, the block chain, grouped around 4 main themes: digital transformations, privacy, community and institutions. The main outcomes of the research will be: - A step-by-step guide aimed at helping startups and incumbents understand the issues to consider for incorporating block chain technologies into their products and services - A number of small pilot studies with companies examining the potential impacts of cryptocurrencies - A community of academic researchers and professionals able to further develop this nascent research area less way. The Engineering and Physical Sciences Research Council (EPSRC) is already supporting exploratory research on such financial applications (see case study on research and horizon scanning, above). But the opportunities are not limited to banking. Applications are being explored in healthcare (patient records), government (land registries and benefit disbursement— see Chapter 6), electronics (including the 'Internet of Things' - 2. CREDIT builds on two previous scoping reviews that we supported: 'The disruptive role of crypto-currencies'2 and 'ICT and the Future of Financial Services'3. These both reviewed the current understanding of cryptocurrencies and revealed gaps in the understanding of social, ethical, legal, regulatory impacts of cryptocurrencies. As a result, we recently issued a £10 million call for research proposals on 'Trust, Identity, Privacy and Security in the Digital Economy'4, which features "Broad applications of distributed ledger technologies" as one of its six focal areas. This focal area seeks to support research that blends and balances the technological advancement in distributed ledger systems with an understanding of the societal, ethical, legal and business frameworks needed to build confidence, trust and adoption of such systems by individuals, communities, organisations and states. Ultimately, we hope this research will pave the way towards a 'smart' economy that can support diverse scenarios of monetary and non-monetary value exchange between individuals and organisations and, in the future, 'smart' objects. 3. Finally, we have also funded a £260,000 research project, 3rd Party Dematerialisation and Rematerialisation of Capital (3DaRoC)5, which explored how to design effective digital retail financial services based on case studies with two retail finance organisations: Zopa Limited, a peer-to-peer lender; and the Bristol Pound, a community currency. The project has produced an online toolkit to assist users and businesses interested in the key issues impacting the design and use of digital financial products6. see Chapter 1) and even the world of art and jewellery (tracking the provenance of diamonds - see Chapter 5). It is important to stress that these technologies are very early in their development, and there are many unsolved problems to tackle before these applications can be realised, including issues of privacy, performance, and scalability. Does the technology actually work well enough for the banks to trust? Who will build these platforms if they can't easily charge a fee when they are shared and mutualised? But the field is developing rapidly and many of the problems are already being resolved. It is now becoming possible to distinguish between those aspects of the technology that will change over time, and those that are innate and are unlikely to change. Already, we can see that distributed ledger technology could enable firms and governments to run more efficiently, without expensive reconciliation and duplication. And it could allow both incumbents and new entrants to compete on equal terms in offering new products and services to consumers based on open access to securely shared data. That could usher in a world-changing revolution that goes far beyond censorship-resistant digital cash. ## Governance And Regulation Both the legal and the digital spheres are governed by rules, but the nature of these rules is different. In a digital environment, both laws (legal code) and software/hardware (technical code) regulate activity. The impact of both must be considered in setting out regulations that cover distributed ledger systems. Author Vili Lehdonvirta, Oxford Internet Institute, University of Oxford; Robleh Ali, Manager - Digital Currencies, Bank of England ## Chapter 3: Governance And Regulation Introduction This chapter deals with rules and rulemaking in distributed ledger systems. We will distinguish between **legal code** (rules consisting of legal obligations) and **technical code** (software and protocols). We will also distinguish between governance (rule-making by the owners or participants of a system with the purpose of safeguarding their private interests) and **regulation** (rule-making by an outside authority tasked with representing the interests of the public). ## Legal Code Vs Technical Code: Two Types Of Rules The financial system is both a set of legal obligations between institutions and a set of digital records of these obligations. Both the legal and the digital spheres are governed by rules, but the nature of these rules is different. In a seminal text on the subject1, Lawrence Lessig of Harvard University addressed how these legal and digital rules interact to govern activity. Lessig argued that in a digital environment both laws (legal code) and software/hardware (computer code) regulate activity, and that the impact of both needs to be considered when constructing a theory of regulation. In this chapter we refer to technical code rather than computer code. This definition covers both software and protocols, as distributed ledgers rely on both to function. One fundamental difference between legal code and technical code is the mechanism by which each influences activity. Legal code is 'extrinsic': the rules can be broken, but consequences flow from that breach to ensure compliance. Technical code, in contrast, is 'intrinsic': if its rules are broken then an error is returned and no activity occurs, so compliance is ensured through the operation of the code itself. Another characteristic of software is that a machine will rigidly follow the rules even where that compliance produces unforeseen or undesirable outcomes. This leads to some striking differences in the operation of distributed ledger systems compared with the current financial system. ## 1. Current Financial System: Ruling Via Legal Code The modern financial system is already largely digital and heavily reliant on technical code. This technical code governs the creation and amendment of the digital records of the legal obligations between institutions. Financial regulation is aimed at the effects these legal obligations produce: for example, whether a bank has sufficient capital or liquidity. The financial system is already governed by this combination of technical code and legal code, but financial governance and regulation has traditionally focused on the latter. Enforcement of the public element of the legal code falls to a specialised group of financial regulators charged with ensuring compliance by participants in the system. Participants must provide the information that their regulator needs to assess whether they are in compliance with the system's rules. If an institution is not in compliance then the regulator can take action to bring them back into line. This is not to say technical code has no influence on the existing regulatory process - all the information provided to the regulators is digital, and the product of technical code - but governance and regulatory aims are pursued by producing legal code rather than by changing the technical code. ## 2. Distributed Ledger Systems: Ruling Via Technical Code Distributed ledger systems such as Bitcoin have shown that they can function without legal rules. Instead, the rules that each participant must follow are defined and enforced only by technical code. Each participant in the network runs the same or compatible software that defines what kinds of transactions are permissible. For example, the Bitcoin software allows participants to spend only balances that they can prove they own with cryptographic keys. The Bitcoin software also regulates how new currency is issued, and places an absolute cap on the size of the money pool. There are no bylaws or other legal documents stating these rules, and no humans to enforce them - distributed ledger systems are solely governed by their own technical code. To prevent participants from modifying their copy of the code to issue transactions that are against the rules, each transaction needs to be verified before it enters the ledger. In an 'unpermissioned' distributed ledger system like Bitcoin, verifiers (known as miners) are chosen by lottery. The system seeks to assure their integrity through a system of economic incentives, in a process governed by the software. In a 'permissioned' distributed ledger system, verifiers are appointed by the system's proprietor, and their integrity is assured through conventional means, such as a legal contract. In summary, distributed ledger systems differ from the conventional financial system in that they are ruled by technical code rather than legal code. One advantage of this is that compliance costs are low: participants need only use a compliant software package to issue transactions. It might seem that enforcement costs are lower, too, but this is not necessarily the case because the mining system that is used to verify transactions in all of the most popular distributed ledger systems consumes significant computational resources. That cost must eventually be borne by the system's users. ## Governance Vs Regulation: Two Types Of Rule-Making Because the current financial system and distributed ledgers are primarily governed by different types of rules, we must therefore ask the question: who makes the rules? ## 1. Current Financial System: A Mesh Of Private And Public Rule-Making There are many places where legal code is being produced in the current financial system, but these can be broadly divided into two categories: private rule-making (governance) and public rule-making (regulation). An example of private rulemaking is the Visa Core Rules promulgated by the financial services company Visa Inc. to govern the actions of all the participants in the Visa system. Such private rule-making is done by proprietors of private financial networks like Visa, as well as by private associations of financial institutions wishing to coordinate their activities to one another's benefit. An example of public rule-making is the statutory oversight of Visa Europe's payment system by the Bank of England. The design of the public legal code in the current financial system is the province of policymakers who have to consider the effect of regulations on the different institutions of the financial system (a 'microprudential' approach) as well as the impact on the system as a whole (a 'macroprudential' approach). As the financial system is global, international bodies such as the Basel Committee on Banking Supervision convene policymakers from around the world to reach voluntary accords that can then be translated into legislation in a specific jurisdiction. ## 2. Distributed Ledger Systems: Ad Hoc Private Rule-Making Unpermissioned distributed ledger systems are sometimes thought to exist independently of human rule-making, and governed only by mathematical algorithms. This is a misconception. Just like legal code, technical code needs to be produced and maintained by humans who define the rules that the code embodies. Using Bitcoin as an example, the initial version of the software was published by Satoshi Nakamoto (a pseudonym). In 2010, Nakamoto handed control of the project to Gavin Andresen, an Australian-born programmer living in the United States. Like any software, Bitcoin needs to be regularly updated to address bugs, security issues, and changes in the operating environment. Such an update can in principle change any aspect of the software, including accounting and ownership rules. Who gets to write the software and how that process is governed is therefore critically important to all participants in a distributed ledger system. In the case of Bitcoin, the software is governed by an ad hoc process involving a handful of informal institutions and power holders. Figure 1 shows who has written most of the current Bitcoin code. The software is open source and anyone can suggest changes to it, but technical authority to admit changes to the official version of the software is held by a team of five core developers appointed by Andresen. The core developers' power is constrained by an informal self-imposed charter, which states that significant changes to the rules require broad consensus from the community. Any update to the software must furthermore be installed by a majority of the miners (as measured by the computer processing power they contribute) for the changes to become effective. A handful of individuals who manage so-called mining pools are therefore very influential in determining whether or not miners ratify a software update in this way. This governance process worked well when the changes to the code were uncontroversial bug fixes, but it has started to show signs of breaking down recently, because some decisions require choosing which stakeholders' interests to prioritise over others'. Andresen and others have stated that the process needs to become more formal. The community is debating what such a formal governance system should look like, but this is complicated by the fact that Bitcoin was founded on an ethos of anti-institutionalism. This is an interesting conundrum, as it demonstrates the worth of legal code and shows that technical code alone does not produce an optimal outcome. In permissioned distributed ledger systems, governance of the software is made simpler by the fact that there is usually a proprietor with clear legal and technical authority over the code. It is up to the proprietor to determine how the code is modified, and up to the users (often customers of the service) to decide whether they are comfortable with having the proprietor exercise authority over the software. Service level contracts and other conventional means can be used to establish responsibilities and enforce them. Permissioned distributed ledger systems are in this respect not very different from conventional private financial networks like Visa or software-as-a-service (SaaS) systems. ## How Should We Regulate Distributed Ledger Systems? Governance in a distributed ledger system as described above is concerned with the system's stakeholders' interests, but there may also be broader social interests involved in how a distributed ledger functions. For example, regulators may wish to collect taxes, prosecute crimes, and limit the use of a distributed ledger for criminal purposes. If a system is adopted to the extent that it starts to have potential knock-on effects elsewhere in society, regulators may also wish to ensure that the system is resilient against systemic risks and market failure. This regulation can be applied through legal code or technical code. ## 1. Regulating Distributed Ledgers Via Legal Code Regulating a permissioned distributed ledger system is simply a matter of imposing legal obligations on its proprietor. Regulating an unpermissioned system like Bitcoin via legal code is more complicated, as there is no single legal entity in control of the system. It would be difficult to regulate what software people are allowed to install on their computers. Attempts to regulate Bitcoin via legal code have instead focused on regulating the businesses that deal with Bitcoin, such as exchanges and wallet providers. These businesses can be regulated in their own right (eg to prevent a wallet provider from disappearing with customers' money) or as a means to indirectly regulate what the ledger is used for (eg ensuring compliance with anti-money laundering regulations). A well-known example of regulating Bitcoin via legal code is the BitLicense, issued by the New York State Department of Financial Services to businesses offering digital currency services to New York residents2. The deadline for businesses to obtain the license was 8 August 2015, and unlicensed service providers can be penalised. ## 2. Regulating Distributed Ledgers Via Technical Code The technical code for distributed ledger systems like Bitcoin is currently produced by private actors in an ad hoc process. But technical code, comprising software and protocols, can also emerge from the public sector. For example, TCP/IP and some other core internet protocols were the result of governmentfunded research projects and are now maintained under the auspices of the Internet Society, an international non-profit organisation with an open membership structure based on geographic location and special interests. Other parts of internet infrastructure are maintained by international multi-stakeholder processes, and some parts remain under the oversight of US public regulators. While this patchwork is far from a perfect solution, it points to the possibility of public involvement and democratic representation in the production of technical code - public regulation via technical code as opposed to legal code. | Legal code | Protocol | |---------------------------|-----------------| | Visa Core Rules | | | Financial Information | | | eXchange (FIX) protocol | | | Privately | | | produced | | | Table 1 | | | Examples of | | | privately and | | | publicly produced | | | legal code and | | | computer code | | | Faster Payment | | | Service Rules | | | Bitcoin | | | Internet (TCP/IP) | European Market | | Infrastructure Regulation | | | Publicly | | | produced | | | World Wide Web (HTTP) | | | BitLicense | | Applied to distributed ledger systems, this could mean anything from instituting formal multi-stakeholder processes for maintaining the technical code, to developing public standards for the code. If this allowed governments or the public directly to attain legitimate regulatory goals by influencing the rules built into the computer code, it could lessen the need for a body of new legal code to regulate these systems. Alternatively, the public sector could develop a permissioned system that allows public regulatory influence to be exerted through a combination of legal and technical code, rather than exclusively through legal code as at present. Some of the core internet technologies have shown that it is possible for governments to successfully catalyse the creation of technical code that has become foundational to private sector activity. ## Conclusions In contrast to conventional private financial networks like Visa, unpermissioned distributed ledger systems like Bitcoin lack a central legal entity with formal responsibility over the system. Instead, they are governed by ad hoc processes, usually centring on a handful of software developers who produce the system's software code. If these systems are to grow in value and influence, they will most likely need to develop more robust internal governance processes. The lack of a central legal entity also makes it more challenging for public regulators to regulate distributed ledger systems via legal code. Governments should therefore also consider ways of regulating distributed ledger systems by influencing the technical code that defines their rules. In finding the right blend, the government should consider the strengths and weaknesses of both technical code and legal code, recognising that the two interact and should be designed accordingly. The emergence of Bitcoin and distributed ledger systems has brought the issue of technical code to the fore in the context of the current financial system as well. Distributed ledgers show that financial systems can be governed and regulated with technical code as well as legal code. Policymakers should recognise the influence of technical code on the financial system and consider how such influence could be made part of the regulatory system, with potential benefits such as lower compliance costs. ## Securit Y And Privacy There are many different types of distributed ledger systems, each offering various opportunities and threats regarding security and privacy. It is important to analyse the business and security requirements of any proposed implementation before deciding which type of ledger to use. Author M. Angela Sasse, University College London, with contributions from: George Danezis and Sarah Meiklejohn, UCL; Daniel Shiu, Government Communications Headquarters; Phil Godsiff, University of Surrey ## Chapter 4: Security And Privacy Introduction Security can be simply defined as: "Things that should happen, do; and things that shouldn't happen, don't." For any particular implementation of distributed ledger and block chain technology, the risks of desired and undesired outcomes depend on how the technology is designed, implemented and governed. Different stakeholders will face different risks. Threats to the systems include not only attacks by external entities, but also actions by internal stakeholders and failure of components (such as software). Prior to any implementation, detailed threat models need to be developed, and specific security requirements identified, to deliver the outcomes. Effective security provides a necessary but not sufficient foundation to deliver privacy for individual and organisational stakeholders. We must also consider how the information disclosed in a particular implementation might be combined with other available information to identify individuals or groups, or detect their activities. ## Innovation Advantages One of the main security features of Bitcoin and other cryptocurrencies is the decentralised control over the network. The system is governed by a global set of peers who operate based on consensus (see Definitions, p17), so there is no central point of trust or failure. This means that any malicious actor must put in considerable effort to attack the system. For individual users, the system can also achieve a high degree of security - in order to move the bitcoins held in a wallet, an attacker must know the private key associated with a given public key (which is where the bitcoins are held). Thus, the attacker must be able to subvert the security of an established cryptographic standard (the Elliptic Curve Digital Signature Algorithm, ECDSA) in order to steal someone's bitcoins. Bitcoin and associated 'altcoins' apply a much broader computer security infrastructure - namely distributed ledgers - that provides high-integrity and view consistency. Such ledgers use cryptographic techniques to ensure that anyone can check if a particular record is within the ledger, as long as they possess a small amount of crucial information. At the same time, complex consensus protocols are employed to ensure that everyone in the system gets a consistent view of the ledger. This is key to Bitcoin's ability to prevent double spending, but it could be equally important when using distributed ledgers for other applications, such as recording contracts or deeds. Distributed ledgers naturally lend themselves to implementing high-level services that involve notaries, time-stamping, and high-integrity archiving, and promise to lower the costs of these activities by increasing automation, enabling easy switching of service providers, and peer transactions. One of the main problems for secure on-line communications lies in establishing that a public key belongs to a service that a user wishes to access. The prevalent mechanism used since the 1990s is known as a Public Key Infrastructure (PKI) - essentially a set of trusted third parties that provide certificates attesting the link between keys and services. But these certificate authorities have been to shown to be fallible; when compromised, they may issue invalid certificates unnoticed. The Certificate Transparency1 (CT) system (recently initiated by Google, and now overseen by a working group) uses distributed ledger technology to mitigate this problem. All certificates are appended to a distributed ledger, and any user or services can check that the certificate they are about to use is the one in the ledger. Consequently, rogue certificates can be detected quickly - a significant disincentive to attackers seeking to compromise and abuse the PKI system. The problem of establishing authoritative bindings between keys and entities also exists when users want to protect personal communications. But current solutions (such as the PGP Web of Trust, or centralised solutions) are either unusable or have brittle security properties. One promising alternative is CONIKS2, which relies on a specially crafted distributed ledger to store and retrieve user public keys that can be used to encrypt or sign emails. Unlike CT - which relies on a network of third parties to maintain and audit the distributed ledger - CONIKS uses communication providers and their existing databases of users to build a high-integrity ledger. ## Security Challenges The security advantages of the decentralised systems identified above - specifically, resilience and robustness - only apply completely to unpermissioned ledgers that subscribe to a global trust theory. For permissioned ledgers, or examples with other centralised functions, there will be less resilience and robustness, but a better ability to assure central trust and/or functions. In fact, there is a broad spectrum of options (see Chapter 2) between totally decentralised systems (as in Bitcoin) and totally permissioned system (a private, dedicated network). An example of a middle-ground solution that uses the strength of both is the proposal from George Danezis and Sarah Meiklejohn of University College London for centrally-banked cryptocurrencies3 - relying on a centrally-controlled server to establish the block chain while using a distributed network of 'mintettes' to absorb transactions. Given this spectrum of solutions, it is important to analyse the business and security requirements of any proposed implementation before deciding which type of ledger to use. For example, the key priorities of a system to manage welfare support payments for the Department for Work and Pensions would include ensuring both the availability of the service and its resilience against network disruption (see Chapter 6). The greatest threats would probably come from opportunistic cybercriminals targeting individual users for monetary gain. Therefore: • The system should be designed to require minimum knowledge and effort from individual users ie there should only be a small number of choices and configurations, with clear feedback of consequences • If commodity devices such as smartphones are used, ensure that credentials and keys are securely accessed and not visible to other applications • The ledger itself should be maintained across a wide network of servers to allow for resilience against network outages • For wider deployments, the payment authorisation service should be centralised on dedicated hardware and hardened against attack Alternatively, a system that might be used for distributing foreign aid would need to ensure the integrity of transactions (to avoid funds being syphoned off for other purposes); and maintain the availability of the system during disaster relief situations, for example. Threats may come from nation states that could gain geopolitical advantage from disrupting transactions, or from dishonest agents within the states receiving aid. Therefore: • The system should run on a small, hardened and dedicated network of servers that establish government copies of the ledger with offline back-ups • Clients should be encouraged to set up their own networks of ledgers, with advice on secure design that allows regular updates or corrections from the government servers • Allow the system to be taken offline if a serious network attack is suspected Arguably, though, the most serious threat to any government-backed system is obsolescence. If it is too difficult to use, or does not offer the functionality required, it will not be adopted. Another threat that has recently emerged is that of a system being hijacked because a different software implementation creates a 'split' within an existing system. Cryptanalysis researcher Nicolas Courtois at UCL, who has followed Bitcoin closely, reported in August 2015 that: "There will be a possibility to mine blocks with a new version number and new rules. This is meant to make bitcoin more democratic: larger blocks, more transactions per second, lower fees, wider adoption. Current bitcoin has reached its capacity limits (not much more than 3 transactions per second) in the recent months and bitcoin developer community has FAILED to solve this problem." This shows that the governance of any government-backed implementation will require serious forethought of possible technical developments, and how to protect it from takeover by other entities - hostile or not. ## Security Recommendations For each particular use of the technology, the government should carefully identify the relevant threats. Although no nation state actor is interested in disrupting Bitcoin, they might be interested in attacking a UK national digital currency - and if there is any financial gain to be made from fraudulent ledger entries, it is likely that organised crime will target users with low security awareness. Given the threats identified, the government should decide on an appropriate level of security for the threat actor, and the lifetime of the proposed usage. If cyberattacks are anticipated then systems should be designed with secure usability in mind from the outset. For example, unpermissioned networks of ledgers allow actors to threaten network integrity either by adding their own servers or operating a denial-of-service attack on legitimate servers; to counter this, a long-term ledger of interest to nation states might need quantum resistant signature schemes. It is easier to build a new secure infrastructure than to adapt existing infrastructure to a new secure application. As such, a dedicated new set of permissioned servers would be easier to configure and accredit than reusing existing internet servers. Advice on building secure systems should be sought either from the UK Government Communications Headquarters (GCHQ) or reputable industry providers. For systems intended to have a long lifetime, the initial design should make it straightforward to update components during that lifetime (eg the ability to switch out nodes of the network with more modern hardware; the ability to upgrade cryptographic algorithms that can no longer be used securely). In any trial of the technology, it is also important to fund penetration testing of the experiment at both the system and user levels. Real-world attackers would not be interested in a small scale proof-of-concept, but could become a threat when an application is deployed at scale. ## Privacy Challenges The Bitcoin cryptocurrency was designed from the outset to provide a form of pseudonymity5 (its designer Satoshi Nakamoto referred to this property as "anonymity", but this is a misnomer). Users can create a number of wallets to hold bitcoins, and there is no restriction on the number of wallets they can own, nor any 'Know Your Customer' requirements to open a wallet. Coins are transferred from one wallet to another, and the obscured relationship between wallets and real-world persons provides a degree of privacy. The decision to allow pseudonymous identities, and to not link wallets to any real-world identifiers, is a pragmatic one for Bitcoin that has contributed to its wide adoption. Most jurisdictions do not have any strong way of linking realworld identities to online transactions, and thus a reliance on the existence of such mechanism would have prevented the deployment of Bitcoin at the time, and even today. Furthermore, given the international nature of the Bitcoin network, it is unclear which jurisdiction would have been entrusted with certifying identity information, and how one could establish whether a legal jurisdiction is entitled to identify a certain user. Finally, requiring identification as part of opening wallets potentially has an impact on the fungibility of bitcoin as a currency: if an identity provider has to be involved to authorise transactions then they may be able to block them, selectively denying the value stored in some user's bitcoins. Other parties could not be sure that value stored in bitcoins would be unconditionally available in the future. Thus Bitcoin pseudonymity allowed both rapid adoption (by avoiding dependencies on non-existent or fragmented identity infrastructures), and also preserves important aspects of Bitcoin as a currency (ie its status as an unconditional store of value). This pseudonymous relation between users and wallets is, however, not full or perfect anonymity. Chains of transactions in and out of wallets, and from wallet to wallet, are visible to all, and can be traced and tracked in public. UCL's Sarah Meiklejohn and colleagues have shown that chains of transactions may be traced throughout the Bitcoin block chain to link, for examples, instances of bitcoin theft with specific attempts to withdraw bitcoins through exchanges6. This approach could be used to enforce some Know Your Customer rules, because once a particular wallet address is identified and linked with a physical person, it is possible to uncover all of their transactions. This weak form of pseudonymity, combined with the transparency of transactions on the bitcoin block chain, actually represents a privacy challenge. Unlike traditional online payments, which are only visible to transacting parties and financial institutions, Bitcoin payments - including the wallets involved, the approximate time of the transaction, and the transaction values - are recorded in a publicly visible block chain. Anyone can process the block chain and draw inferences about, for example, the turnover of an on-line merchant, the buying profile of a particular user, or even the many transfers between private individuals - a capability that was restricted in the past to financial institutions and law enforcement. ## Privacy Recommendations A number of techniques, and alternative cryptocurrencies, have been proposed to alleviate the privacy problems of a fully transparent block chain. The first set of techniques involves 'mixing' systems. These take coins from a number of users, and output coins to different addresses that are not linked to the original users. By breaking the link between payer wallets and payee wallets, they provide some measure of anonymity. There are, however, two key challenges with engineering such systems. Firstly, the anonymity they provide is not perfect: although a coin may be traced to one of a number of addresses, is not perfectly hidden amongst all possible wallets in Bitcoin. This partial leakage of information allows the application of statistical attacks to de-anonymise repeated transaction through so-called Statistical Disclosure Attacks7. The extent to which these attacks are effective is an open question. Secondly, dishonest mixes have the potential to accept coins but never pay out, effectively stealing them. A number of bitcoin mix designs (such as Mixcoin8) attempt to alleviate this problem through making part of the mix operation transparent enough to ensure the integrity of its operation, without compromising its privacy. A second family of systems radically alters the way bitcoin payments are made, and what is recorded in the block chain, to provide stronger privacy. For example, Zerocoin9, Zerocash10, Pinocchio Coin11, or certain Sigma protocols12 adapt group signature algorithms to the setting of cryptocurrency transactions. A payer provides a zero-knowledge proof that they own some coins from a list, without revealing which, while also leaking enough information to prevent double spending. This allows them to pay a coin without being fully linked to previous transactions. As with mixing systems, these techniques may only hide payees within a limited list of potential users, not all, which opens the way to de-anonymising multiple transactions. They are, however, robust in terms of integrity, and do away with mixing as a third party operation that could pose a performance or trust bottleneck. ## Disruptive Potential Distributed ledger technologies (DLTs) represent a significant challenge to existing business and governance models. Technical innovations such as DLTs can enable revolutionary changes in those business structures, ultimately causing major changes in the way in which the economy and society itself is organised and governed. Such changes are more far reaching than normal innovations in products, services and operating systems. Phil Godsiff, Senior Research Fellow, Surrey Centre for the Digital Economy, Surrey Business School, University of Surrey ## Chapter 5: Disruptive Potential Introduction Technological innovations can have a huge impact on how businesses operate. New technology can enable businesses to offer new products and services, capture new revenue streams, introduce lower-cost operations, and streamline their organisational structures. If existing businesses are slow to adapt, or try to create barriers to entry, new entrants can take advantage of innovations to replace these incumbents. Sufficiently radical technical innovations can lead to revolutionary changes, not only in business models or industries, but eventually in the way in which society is organised and governed. For example, the steam engine led to the development of railways and enabled the movement of the population to urban centres. Distributed ledger technologies (DLTs) have disruptive potential beyond innovation in products, services, revenue streams and operating systems within existing industry frameworks. They have the potential to disrupt the whole economy, and society. Understanding this can help to frame the opportunities and threats afforded by distributed ledger technologies - and how they can inform changes in the role of the government, and the services it delivers. ## The Role Of Innovation Organisations constantly innovate to improve their competitive advantage. We tend to think of innovation in terms of new products and processes: the manufacturing industry focuses on product innovation, while the service industry develops through process innovation. Even small changes can affect the structure of an industry: many manufacturers of computer disk drives failed to adapt to the introduction of lighter and smaller drives, for example1. Innovation can also occur within business models, and often legitimise new relationships within an industry to create 'cooptetion', where firms both co-operate and compete2. ## Faq The digital revolution has led to an increasing awareness that innovation can also occur at the level of the business model3, and even at the level of whole industries - just think of how the Uber app, which enables customers to hire drivers in their vicinity, has disrupted the taxi industry. Changing an organisation's viewpoint from short-term profit to longterm wealth creation can lead to radically altered activities and views of the future, for example by using open source software to create a platform that others can modify and exploit4. Technology innovations, such as apps, now allow customers to act as resource What is the disruptive potential of DLTs? DLTs have the potential to be radically disruptive. This is partly because of the developments they have already helped to bring about (eg in cryptography and software engineering); the industries and services they could innovate (eg financial services, real estate, healthcare, identity management); and their processing capability (eg low cost, real time, immutability). But their disruptive potential also lies in their underlying philosophy of distributed consensus, open source, transparency and community. integrators, 'pulling' solutions rather than having them pushed by suppliers. This can challenge existing assumptions on value creation through, for instance, 'prosumption' (a model where the same actors are involved in both production and consumption, used by ridesharing service BlaBlaCar and the accommodation rental service Airbnb), peer-to-peer lending and crowd sourcing. This form of innovation impacts industry structure and has the potential to create new industries; it changes "who does what", and "who gets what"4. Developments in mobile payment systems introduced by new entrants are opening up new customer bases (eg by allowing small merchants to turn their phone into a bank card reader); previously unused data are being delivered to new stakeholders to create new revenue streams to capture value; and there is growing use of digital wallets and value transfer through different operating systems such as mobile phone providers (eg M-Pesa) rather than banks. But in many of these cases, the underlying transactions are still processed through established players using legacy systems (eg clearing banks and competing card schemes such as Visa and Mastercard). M-Pesa challenged the notion that value transfer for exchange transactions had to be done through banks, and leapfrogged several developmental stages. But these innovations still rely on an existing hierarchical structure, using proprietary technology and trusted intermediaries. Though the change improves customer convenience, and significantly reduces costs to users and customers, this is evolution rather than revolution. ## Technological Revolutions Innovation generally proceeds incrementally, but is punctuated by radical episodes, described by economist Joseph Schumpeter as "creative destruction", and by Carlota Perez as "technological revolutions"5. These innovations exist in a complex dynamic between technology, the economy and society, and sometimes an innovation can fundamentally alter the way in which a particular society or economy is organised. The past few centuries have seen a handful of these technological revolutions: the original Industrial Revolution, the Railway Revolution, and the Oil Revolution, for example. Each one changed industrial structure, brought new forms of energy, and impacted the way society could organise (see Table 1). Now we are in the Information and Telecommunications Revolution, typified by information intensity, connectivity, specialisation, and globalisation. There are typically three pillars to these revolutions: significantly lower costs, new communication methods, and changed infrastructure and logistics. Lowering the costs of pervasive inputs generates market tensions - and, often, financial bubbles and crashes - that ultimately lead to demands for an overhaul of existing institutions. According to Perez, the revolutionary innovations are characterised by a "set of inter-related radical breakthroughs, forming a constellation of interdependent technologies" and the "strong interconnectedness of the participating systems in their technologies and markets, and their capacity to profoundly transform the rest of the economy (and eventually society)"5. | Description | Year | |-----------------------|-------------------| | (approx) | | | Technologies | | | and Industries | | | 1st | | | Industrial Revolution | | | 1770 | | | Mechanised | | | industry | | | 2nd | | | Steam and Railways | | | 1830 | | | Steam engines, iron | | | machinery | | | 1875 | | | Cheap steel, heavy | | | 3rd | | | Steel, Electricity, | | | Heavy Engineering | chemistry | | 1910 | | | Cars, cheap oil, | | | 4th | | | Oil, Automobile, Mass | | | production | petrochemicals, | | home appliances | | | 1970 | | | Cheap | | | 5th | | | Information and | | | Telecommunications | microelectronics, | | computers, mobile | | | telephony | | Each technological revolution brings a different set of 'common sense principles' that change how businesses and society operate. These moved from mechanisation in factories; through economies of scale and vertical integration, mass production and standardisation; to functional specialisation, hierarchical pyramids and bureaucracy; and on to today's information intensity and decentralised networks, marked by "heterogeneity, diversity, adaptability and co-operation"5. These revolutions ultimately lead to a new techno-economic paradigm, with different cost structures, different opportunities for innovation, and organisations built on markedly different principles. In each paradigm, organisations develop along an 'S' curve, from disruptive innovation, through use and exploitation (and resistance), to maturity and eventual replacement5. Changing these existing mind sets and replacing them with a new one requires a transformational shift that requires new skills, abilities and knowledge, which fundamentally change the way business operates. Previous technological revolutions had little or no impact on pyramidal, hierarchical systems of organisation and governance. But some suggest that our new technological era enables a potentially emergent 'Collaborative Commons', in which society is motivated by collaborative interests rather than individual gain6. This could imply distributed, consensual community structures that do not depend on intermediaries organised in hierarchies (such as banks and governments). DLTs represent a challenge in precisely this way. | New | 'Common Sense | |----------------------------------|-------------| | Infrastructure | Principles' | | Canals and water | | | Factory production, | | | power | | | productivity, local networks | | | Railways, telegraph, | | | Economies of agglomeration, | | | ports | | | standardised parts, | | | urbanisation | | | Electrical networks, | | | Economies of scale and | | | global shipping | | | vertical integration, science as | | | productive force, efficiency | | | Road networks, | | | Mass production, horizontal | | | universal electricity | | | integration standardised | | | products, energy intensity, | | | suburbanisation | | | Worldwide digital | | | Information intensity, | | | communications | | | decentralised networks, | | | knowledge as capital, | | | economies of specialisation, | | | globalisation | | ## Distributed Ledger Technology DLTs are involved in potentially revolutionary innovations in a number of related areas: virtual currencies, distributed open and transparent record keeping, nonhierarchical networked systems, cryptography, and software engineering. DLTs represent an innovation towards the radical end of the change spectrum because of their potential to impact a broad extent of areas in the business model: from new products and services, through operating systems and organisational structures, to the sheer number of potential industries that could be affected. As such they form part of the interconnected and inter-related breakthroughs that form a technological revolution. DLTs offer significant benefits to operational costs. Not only are they intrinsically low-cost, they can also avoid duplication and inefficiencies in control and coordination by enabling a common, open ledger that could operate at an industry ## Case Study 1 Diamonds Leanne Kemp, Founder And Ceo, Everledger • Assign a digital passport to the diamond • Detect and guard against illegal activities or The diamond industry is highly susceptible to criminal activity. Gems are small and easy to transport in a covert manner, transactions tend to be confidential, and diamonds retain their value for many years. As such, diamonds are involved in money laundering and terrorist financing on a global scale. By using an immutable block chain to hold this data, the ledger could provide transparency around all diamonds, revealing their origin, trail of ownership, and the processes they might have undergone. This ledger can act as a single version of verifiable truth about diamonds for the industry, governments, consumer markets, border control and law enforcement agencies. Efforts to stem this illicit activity have included tracking diamonds with paper documents to certify their provenance. But document tampering is widespread - indeed, documents are sometimes created to cover up illegal transactions - and several countries with a major diamond trade still have insufficient legislation to guard against these crimes. To combat this, the diamond industry is beginning to implement a system called Everledger, based on block chain technology, which establishes a digital 'passport' for each diamond. This records its provenance, travel, and transactions with a unique cryptographic 'fingerprint'. This system has three stages: • Establish an e-ID (electronic identity) for each diamond, by digitising its attributes and a laser-inscribed serial number onto an authoritative block chain ledger The system also enables the use of smart contracts - terms and conditions relating to the sale and transport of the diamonds that can be carried out automatically. By using a block chain to create a distributed ledger, smart contracts can be tracked and used to verify business relationships and agreements. The block chain's transparency offers a way to enforce the contract, whether it is related to changes in ownership of the diamond, financing of the diamond, its insurance policy, registered rights title and so on. Authenticating the transaction, along with documentary proof of authenticity, provides a vital evidentiary trail for government and law enforcement. to record its travel, transaction history and provenance fraudulent behaviour level, thus reducing the systemic costs involved in processes such as cross checking between individually held ledgers and databases. The ability to digitise and securely store information on practically any asset, from diamonds to bags of rice, allows organisations to identify and track their ownership and location (see case study on diamond authentication, p56). New methods of recording obligations and transfer of value using programmable contracts are being developed using DLT: Ethereum, for example, is a decentralised platform for 'smart contracts' (see Chapter 1). Their potential for disruption may even extend to a new landscape in which trusted or necessary intermediaries operating in a hierarchical monopoly - a 'hub and spoke' model - are joined or replaced by a more open, flatter community-based consensual structure (see case study on corporate actions, p58). ## Faq The development of DLTs and associated technologies also offers the possibility of real time recording of transactions and access, making transactions quicker and cheaper (see SETL case study, p60). For example, motor insurance could be based on the state of both the car and its driver, with insurance provision changing between suppliers depending on behaviour, price and appetite for risk. This could lead to a 'programmable economy' involving smart contracts, relying on decentralised networks and agents that require less human involvement, and operating as distributed autonomous organisations that deliver a wide variety of products and services. What are the threats arising from DLT? Like any radical innovation, DLTs provide opportunities to incumbents, and also threats to those who are unable or fail to respond. Through their distributed consensual nature they also threaten the role of trusted intermediaries in positions of control within a hierarchy. Block chains that explicitly create a new currency, such as Bitcoin, challenge the current supremacy of governments in managing the national and international economic and monetary system. The best example of an operating DLT is the cryptocurrency Bitcoin, and the most obvious place for a new currency to innovate is in financial services. DLTs offer a lower cost of operation within existing structures and governance, but they also provide the chance to reduce system-wide costs and complexity. They could do this by removing the duplication and cost of many separate, proprietary systems, and by challenging those systems' centralised architectures. Money creation no longer becomes the sole responsibility or prerogative of national governments, for example. Instead, new forms of currency could emerge where identity, and connections between people, becomes the means of endorsing and underwriting transactions within a community7. A further development enabled by the technological advances is the possibility of adding specific attribute information (eg physical assets or contracts) to the basic bitcoin to produce 'coloured coins'. This opens up the possibility of money with more than just value: it could carry attributes such as necessary purpose, expiry date, or location of allowed use. For example, money may have restrictions on the kind of goods and service it can be used to purchase (see Chapter 6); or someone renting a flat through Airbnb may have their electronic access key revoked if they fail to pay on time, or if their contract has expired. ## Considerations For Government With its wide range of stakeholders, services and roles, the government obviously has a multitude of different operations. Some distribute value rather than create it, and others create and maintain effective regulatory regimes. Many of these activities will be enhanced by the innovations afforded by DLT, and others will be challenged. Change is possible at the product and service level, and at the operational and organisational level. ## Case Study 2 Corporate Actions Dominic Hobson, Founder, Cooconnect Listed companies must provide their annual accounts in a structured format, but any company announcements that may require action by investors or their representatives - known as corporate actions - are typically published as unstructured text, or in PDF format. Those relying on the information have to read and interpret the data manually before taking action. for the execution of instructions. A distributed ledger based on such a block chain would reassure parties at every point in the process that their information is accurate, up-to-date, and unchanged since it was published by the issuer. In theory, it could eliminate all intermediaries between the issuer and the fund manager, guaranteeing the accuracy and timeliness of the information. The important question is whether this can be organised in a fully-decentralised manner. Corporate action information differs from simpler contractual information (such as money changing hands) because investors and shareholders often need to use intermediaries with specialist knowledge to act on their behalf. Over 90 per cent of corporate actions are distributed by data vendors, and then processed on behalf of investors by an agent such as a custodian or fund manager. Information is manually extracted from the original, interpreted and re-keyed by vendors. Levels of automation are low, errors frequent, and the process highly inefficient. One estimate puts the global cost of corporate actions processing at up to $10 billion per year1. Custodians frequently reimburse clients for missed or incorrect execution of instructions. These intermediaries may need to be able to modify or augment the data before passing it on, and the original corporate action itself may change, through follow-up announcements that supersede earlier ones. This modified data could quickly lose its provenance as data vendors share it with clients or package it with other data, making the process difficult to automate. Block chain technology could make this process more efficient. Corporate actions represent contractual information and value, which can in principle be transferred directly between payers and payees without the need for intermediaries, provided the parties can trust the source data and have the necessary experience to act upon the information they receive. If a block chain was coupled to an application that captures and stores corporate action announcements in a structured format, it could be used to ensure that the data is from a verified source, and prove the time-stamped date that it was issued. This could be done in reverse On its own, block chain technology is currently too slow to cope with these constantly shifting packages of data. Bitcoin's block chain can handle about 20,000 transactions per hour, with up to an hour's latency before a transaction can be trusted. That would be very inconvenient in a corporate action process, which is subject to a final deadline that fund managers prefer to keep open as long as possible. For instance, the process of ensuring that financial transfers such as welfare payments go to the right person at the right time could be improved in a number of ways (see Chapter 6). A single ledger carrying the identity and entitlements of potential claimants, updated in real time, could be a radical innovation that is much more efficient, reducing both operating and development costs. Adding attributes to a particular payment could mean that as well as the amount, the purpose and timeline of expenditure could be both specified and tracked. This would, of course, involve extensive negotiations with stakeholders, and may The Monmouth-based company Codel, which handles corporate actions data, has overcome these limitations by combining a block chain system with its digital notary software. This system creates an immutable audit trail that parties along the chain can refer to in order to establish authenticity, offering valuable reassurance about the provenance of data. These run alongside Instant Actions, a new searchable central registry of corporate action information that is a collaborative venture between industry participants and Codel. The registry's data is stored in the ISO 15022 and ISO 20022 formats, which provide guidance for the distillation of financial information into machine-readable formats. This means the registry can be updated as corporate action information is modified or superseded. This guarantees the integrity and accuracy of the information, which can then be made available to all parties in the corporate actions chain via the SWIFT secure network. This overcomes the verification delays of using a block chain alone, and the information - effectively shared as a distributed ledger - can be updated, distributed and modified in real-time, guaranteeing that it is accurate and up to date. The government could help such systems to flourish by altering regulations to require companies to issue corporate actions information using a distributed ledger approach. require some management of this form of currency to ensure any desired parity with sterling. There are innovative possibilities in replacing hierarchical organisations with more distributed systems. The government and its agencies tend to have tiers of authority, both internally and within their respective systems: for instance, citizens are represented by elected officials in local, national and supranational institutions; financial matters involve clearing banks, clearing houses, central banks and governments. Rather than relying on periodic ballots based largely on paper records, democracy could be achieved through a voting block chain, with electors given a digital wallet and a 'vote-coin'. This has the potential to reduce fraud (because each voter can check that their vote was counted), but also to introduce a real-time democracy with a vote on any issue. This raises significant questions of social responsibility and willingness to partake, but could create more distributed forms of democracy. ## Threats The innovations enabled by DLTs may be attractive, but they are not without significant threats, including those involving the nature of money and the role of hierarchies and trust. ## Case Study 3 Setling Transactions Dominic Hobson, Founder, Cooconnect exchange infrastructure. SETL will be able to handle both the security and cash side of each transaction and will also allow for one-sided transfers of securities and cash, either as simple payments or to settle bespoke contracts, corporate actions, dividends and coupons. Clearing, settlement, custody and registration services all add a significant cost burden to issuing, trading and holding securities. There are a plethora of specialist agents and counterparties involved in moving securities and cash between investors. Not only are there specific charges for these services, there are also ancillary costs related to dealing with the myriad of different systems that need to be interfaced and integrated with business processes. In total, the global finance industry pays around $65 billion to $80 billion per year in post-trade costs. SETL will be designed to collapse the costly and risky clearing and settlement process into a realtime settlement process between counterparties. In addition, by establishing a golden ledger of ownership, SETL will substantially reduce the overhead of securities registration and custody. The SETL block chain will have the following characteristics: • Public keys used in the SETL block chain will Block chain technology offers a means of significantly reducing the complexity and cost of these post-trade services, enabling participants to operate a shared ledger that is stored on a large number of servers acting as nodes. The authority to execute transactions is conferred by publicprivate key cryptography. Transactions are added to the database in blocks, and each block is reviewed by the nodes. The block is only added to the database if the node reaches a consensus that the block only contains valid transactions. Apart from setting up and maintaining the nodes, this block chain network should be completely autonomous, and does not require a controlling or regulating entity. • It will have sufficient capacity to process ## The Setl Solution • It will be able to handle multiple asset classes, • It will allow multi-signature transactions, • It will allow 'atomic transactions' (ie either A privately funded venture called SETL intends to develop and deploy a specialist block chain that will allow financial market participants to settle securities transactions on a peer-to-peer basis, and to maintain a distributed 'golden' ledger of securities and cash balances. In particular, SETL aims to have central bank money available on the block chain. Its block chain will run on an autonomous basis, and will integrate with the current financial markets, payments and need to be signed by a certifying authority, making it apparent to users of the block chain who has certified each key. Certifying authorities will maintain details of the realworld identities of public key users, and complete anti-money laundering and Know Your Customer checks. SETL anticipates that the certifying authority will disclose that information when legally required to do so. thousands of transactions per second, commensurate with normal volumes in the financial markets. including cash and securities of all types. enabling authorization by a designated subset of users. all transactions occur, or none do), so that DLTs could disrupt conventional financial services, whose core business is money and value transfer. But money itself is already being disrupted in all its forms and uses through cryptocurrencies such as Bitcoin, an invented money with no government backing; and 'colored coins', which allow units of currency transactions will only be processed if all stages have been submitted and properly authorized. • It will contain specific functionality designed to facilitate the management of liquidity by the participants. • It will maintain a complete record of transactions and balances historically for the purpose of simplifying regulatory record keeping, transaction reporting and audit. ## Wider Benefits Balances of cash and other assets currently tend to be maintained on specific systems and can only be deployed for particular purposes: in other words, they are 'system specific.' Cash and assets held on a block chain are, in contrast, available to be deployed for any purpose. This will both reduce the amount that banks have to deploy in liquidity reserves, and will simplify their management of liquidity. SETL expects to be able to provide a solution that will run alongside the existing Bank of England Real Time Gross Settlement (RTGS) system, providing a safe and viable alternative should RTGS be unavailable at any time. SETL will be available at all times, reducing the interbank risk that currently accumulates when RTGS is not running eg overnight and at weekends. The SETL payment and settlement system will be simple, unified and immediate. If the UK is the first to deploy such a system, it will promote London and sterling as the location and currency of choice for financial services. It is likely that once established in London, the system would be adopted more widely, further consolidating London's position as the global leader in international finance. to carry different types of value. The management of money, and through that the economy, is seen by many to be a key role of government, so alternative currency systems may pose a threat to that role. DLTs pose a threat to any hierarchical structure through an ability to connect and operate in a distributed network, without trusted or necessary intermediaries, by replacing top-down control with consensus. Hierarchies can have serious disadvantages: duplication, added cost, potential abuse of power, and opportunities for financial mismanagement. But hierarchies do offer advantages whenever a neutral broker is needed; and, for example, in representative democracy. Representative democracy provides stability and an ongoing process of civil government that could be threatened by wider use of DLTs. Nation states are already facing threats caused by globalisation and increasingly fluid borders, yet some of the original developers and adherents of Bitcoin espouse extreme anti-government views. The challenge will be to ensure that DLT and its associated innovations are directed towards a connected, productive society, within a supportive infrastructure. ## Conclusions The convergence of creativity and technology can lead to radical changes in existing business models and the organisational structures they sit within. DLT is presently as much a series of challenges and questions to existing structures, as opposed to a set of answers and practical possibilities. But it appears to have at least some qualities, and to be in the appropriate context, to produce change at the more revolutionary end of the spectrum. DLTs offer significant challenges to established orthodoxy and assumptions of best practice, far beyond the recording of transactions and ledgers. These potentially revolutionary organisational structures and practices should be experimentally trialled - perhaps in the form of technical and non-technical demonstrator projects - so that practical, legal and policy implications can be explored. Radical innovation in business models, particularly in structures and operating systems, can occur through experimentation within a relaxed but effective regulatory environment. The government should consider how regulatory regimes can best encourage and exploit an environment in which these low-cost operating models and organisational structures could be explored, with new entrants able to participate freely. More research is needed, at a system-wide level, on the financial costs and benefits of adopting distributed ledger technology. This would enable the government to identify what existing frictional costs could be avoided, and where remaining cost savings and opportunities could be found. ## Chapter 6 Applications In Government Distributed ledger technology is already having a profound impact on how private companies manage data and interact with customers and suppliers. If applied within government it could reduce costs, increase transparency, improve citizens' financial inclusion and promote innovation and economic growth. This chapter considers five case studies that illustrate those benefits. Author Catherine Mulligan, Research Fellow, Imperial College London and Head of Digital Strategy and Economics, Future Cities Catapult. Additional contributions from Simon Taylor, VP for Blockchain R+D, Barclays; and Mike Halsall, Global Grand Challenges, Singularity University, NASA Research Park, California ## Chapter 6: Applications In Government Introduction Distributed ledger technologies (DLTs) can do far more than simply manage digital currencies such as Bitcoin. The concepts and structures developed for distributed ledgers and the block chains they use are extremely portable and extensible to other areas of economic and social activity. As such, they have a profound potential for application within government operations - indeed, the eventual impact of DLTs on British society may be as significant as foundational events such as the creation of Magna Carta1. If applied properly - and issues of privacy, security, identity and trust are addressed thoroughly (see Chapter 4) - distributed ledgers create genuine opportunities for the government and other local and regional authorities in the following ways: • Reduced cost of operations, including reducing fraud and error in payments • Greater transparency of transactions between government agencies and citizens • Greater financial inclusion of people currently on the fringes of the financial system • Reduced costs of protecting citizens' data while creating the possibility to share data between different entities, allowing for the creation of information marketplaces • Protection of critical infrastructure such as bridges, tunnels etc • Reduced market friction, making it easier for small and medium-sized enterprises (SMEs) to interact with local and national authorities • Promotion of innovation and economic growth possibilities for SMEs This very broad range of possible benefits are delivered through the application of DLTs in three different ways: • Within currency applications • To manage contracts and create new forms of contracts • To prompt new applications by third parties, and provide more efficient ways of structuring and carrying out activities Within this chapter, we illustrate each of these opportunities and its application to the different technical implementations through five separate case studies: • Protecting critical infrastructure against cyberattacks • Reducing operational costs and tracking eligibility for welfare support, while offering greater financial inclusion • Transparency and traceability of how aid money is spent • Creating opportunities for economic growth, bolstering SMEs and increasing employment • Reducing tax fraud ## Case 1: Protecting Critical Infrastructure Overview DLTs can enable the UK and its government to better protect critical civil infrastructure against cyberattacks. Background Digital technologies are increasingly embedded in countries' critical infrastructures, and many of these systems are also connected via the internet. This exposes them to the possibility of attacks from hackers or other nations that are able to go undetected by existing cybersecurity defences. It is, for example, possible to seize control of critical routers, allowing them to be monitored and manipulated. This would allow the data from all the companies and government organisations behind the routers to be captured. Moreover, as various other embedded technologies are adopted in civil infrastructure - including bridges, railways, tunnels, flood barriers and energy installations - the chance that such attacks could cause damage to property and human life increases. DLT proposition DLT may be applied to ensure that the operating system and firmware used in a piece of critical infrastructure has not been tampered with. A distributed ledger could monitor the state and integrity of the software for illicit changes, and assure that data transmitted from systems that apply Internet of Things (IoT) technologies has not been tampered with. Outcomes • Efficiency and effectiveness improvements to large-scale infrastructure, ensuring better protection to human life • Data integrity can be assured for transmissions to and from critical infrastructure ## Maturity Level Ready Case 2: Department For Work And Pensions Overview Novel payment models will enable HM Treasury (HMT) and the Department for Work and Pensions (DWP) to distribute welfare support more efficiently and improve policy delivery. By applying DLTs in the registration and payment processes for government grants and benefits, DWP will be better equipped to: • Prevent financial losses through fraud and error • Support the most vulnerable citizens by offering them the benefits of full financial inclusion • Support the achievement of the government's wider policy objectives, especially getting people out of poverty in a sustainable way • Offer good value for money and place public expenditure on a sustainable footing Background The DWP pays out roughly £166 billion of taxpayer's money in welfare support per year. Some £3.5 billion of that sum is overpaid through fraud (£1.2 billion), claimant error (£1.5 billion) and official error (£0.7 billion)2 of which £930 million is recovered. Adding in the fraud and error that exists in the current tax credit system, which will be moving to DWP over the next few years as an element of the new Universal Credit regime, there is a total baseline of over £5 billion per year in gross overpayments. Apart from the direct financial cost of overpaying money to those not entitled to it, the taxpayer also bears the cost of post-payment intervention (debt collection, investigation and prosecution, claimant queries and dispute resolution). A further, as yet unquantified, proportion of welfare support spending will fail to meet policy objectives in less identifiable ways. For example, it may effectively fund expenditure by claimants that arises from the way that welfare support is distributed, ultimately servicing non-bank debt and paying the 'poverty premium'3. DLT proposition A large number of welfare claimants are un- or under-banked4 and face barriers to greater financial inclusion such as credit checks, access to traditional financial products, and the costs of unauthorised transactions. DLTs offer a cheap and supportive means of getting these claimants into the benefits system. Digital identities could be confirmed through distributed ledgers running on securely-encoded devices - or even through software on a mobile device - which would allow end-users to receive benefits directly, at reduced transaction costs to banks or local authorities. This may allow them to become more fully included in the financial system through a secure distribution point that is more reliable than a bank account. Such a solution could also be linked with other systems to reduce the level of fraud and official error in the delivery of benefits, as identities would be more difficult to forge. Such activities may help to achieve one of the DWP's principal policy objectives: to lift people sustainably out of the cycle of poverty and state dependence. Through the innovative application of such technologies, it would be possible - with agreement from the benefit claimant in question - to set rules at both the recipient and merchant ends of welfare transactions. This may present the opportunity for ministers to consider options for achieving better policy outcomes from the distribution of welfare support by agreeing or setting rules around the use of benefits. Outcomes • Reduction of losses due to fraud and official error • Enable ministers to assure taxpayers that public funds are being used more effectively for the purposes of meeting genuine need Maturity level • Requires a lot of education for the recipients • Requires some integration of sterling onto a distributed ledger for benefits • May create a subset of the economy with a stigma attached to 'benefit coins' ## Case 3: Stregthening International Aid Systems Overview DLT could enable the government to better control the distribution of foreign aid, and to ensure that the funds reach the intended recipients. This will also help ministers help improve transparency and encourage effective financial management. The use of DLT could therefore help in honouring the UK's international commitments to achieve the Global Goals. Background In order to meet global obligations, countries must support Global Goal action plans that incorporate transparency, accountability and integrity measures5. International aid donors place significant emphasis on helping to develop more transparent and robust aid systems. Activities preventing fraud, theft and misappropriation of funds can be expensive. Technological advancements that could help strengthen prevention efforts would be beneficial for the wider aid system Fraud and corruption reduces opportunities for poverty alleviation, reduces inward investment, and is strongly linked to lower educational achievement. There is, therefore, a great opportunity to apply DLT in international aid in order to provide transparency and traceability of funds. Proving that money is being well spent could encourage nations to give more, and also all funders to target key outcomes more effectively. DLT proposition The key aspect of this proposition would be to use three main aspects of DLT. Firstly, it would allow international donors to issue coins that have a sterling value, without encountering many of the bureaucratic hurdles of traditional banking. Distributed ledgers achieve this through their lack of geographic boundaries - they operate in the same way in any jurisdiction in the world. There is an opportunity, therefore, to reduce the foreign exchange fees for international aid significantly below standard transaction costs. Moreover, it is possible to create smart contracts that can be used "to create self-enforcing contracts between strangers, offering citizens a framework for transactions independent of the domestic judicial and executive branch"6. Secondly, international donors could take advantage of DLT's ability to reduce the fungibility of cash, offering the possibility of reliable and irreversible transfers of digital goods - in this case aid funding. In addition, digital ledgers solve the double-spending problem: where digital currencies may allow end-users to spend the same unit of currency twice, digital ledgers prevent this because each 'coin' is unique. This makes payment without intermediation possible6. In cases where aid is meant to directly support end-users, it is possible to bypass the limitations and restrictions placed on currencies and banking services in some countries through peer-to-peer transfer of funds. Thirdly, the use of unique sterling-linked coins could prevent them from being spent on items not deemed appropriate within the international aid context. For example, money sent to build infrastructure intended to reduce poverty could not be appropriated for other purposes. This stems from DLT's ability to trace exactly where the currency has been spent and by whom. Outcomes • Increased transparency of international aid spending targeted specifically at the Global Goals to reduce corruption to better achieve desired development objectives. Maturity level • Unpredictability of donor demands may create bigger problems than fraud and corruption, and would therefore need to be carefully aligned to project outcomes to ensure effectiveness. • In every case of international aid, international donors needs to maintain a relationship with the host government. Where issues of corruption are linked to individuals within specific ministries or embedded within the systems of host governments, it is crucial to get buy-in from the recipient nations for this type of system. • Converting distributed ledgers into usable services of this nature requires the creation of a whole range of complementary capabilities ## Case 4: Reducing Market Friction And Enabling Innovation Overview One of the greatest potential benefits of DLT is its ability to remove barriers and friction in the market and enable the creation of new forms of information marketplaces7. As discussed in Chapter 1, the sharing of information between economic entities through distributed ledgers would enable new forms of innovation to emerge. This would allow ministers to achieve policy outcomes centred on assisting SMEs achieve economic growth through effective use of technological innovation. Background Reducing transaction costs for SMEs when dealing with local and national government would enable these businesses to move more freely within the market and face lower overall operating costs. At the same time, enabling these companies to register their intellectual property (IP) within a distributed ledger, rather than through traditional patent applications, may reduce the overall number of contract disputes. Contract disputes make up 57% of all litigation in the UK, more than any other category of legal action. DLT proposition DLTs could be applied in a broad variety of areas, particularly in smart contracts and asset registration. By registering assets on a distributed ledger, all property could effectively become 'smart assets', providing a robust and trustworthy proof of record for a broad variety of services that currently cost SMEs time and money. Examples include registering IP and patents, wills, notary services, NHS health data and SIPPs/Pensions. Distributed ledgers offer a new way to coordinate these types of services, in a truly digitally-enabled manner, with scale and efficiency. Distributed ledgers have the ability to handle micropayments, decentralised exchange, token earning and spending, and transfers in a way that the web currently does not8. As a result, DLT has the potential to re-invent the operating costs of local jurisdictions and businesses through9: • Business licencing • Registration • Insurance • Taxation management at many municipal and regulatory levels • Pension data It is possible that DLTs could help to completely remove some functions, as companies are able to register identities not just for their businesses, but also for their assets. More importantly, citizens can also have more control over their data assets (such as health data), which are traditionally held by government. This would enable citizens to check whether their data has been accessed and used in the correct manner for the correct reasons. In addition, the use of distributed ledgers allows for sharing of data across new forms of information marketplaces - or possibly even data utilities - allowing for the sharing of pension data. Outcomes • Reduced transaction costs for SMEs and streamlined cost of operations for local and national government. Additionally, having a trustworthy proof of ownership for digital assets such as IP will reduce the options for litigation, providing an overall social benefit for UK society. Maturity level • Requires local and national authorities to adopt DLTs ## Case 5: European Vat Overview The economy can be categorised in many ways, including (i) the tax-compliant economy, (ii) the tax quasi-compliant economy and (iii) the tax non-compliant (or 'black market') economy. VAT shortfalls occur in all three for a variety of reasons that may include business insolvency; creative use of international laws to structure companies in such a way as to circumvent tax liability; or the more straightforward 'no paperwork, cash only' scenarios. The annual shortfall in the EU's value added tax (VAT) revenue is estimated to be between €151 billion and €193 billion10. DLT has both the exponential growth characteristics and the potential to make transactions significantly more transparent. The UK could play a pivotal role in supporting the development of technology, process protocol and implementation solutions for DLT in order to reduce the EU's VAT shortfall. Background Moore's Law correctly forecasted the exponential growth in digital computational processing density several decades ago. In fact, information technology has been growing exponentially since the late 1800s, with current predictions indicating this should continue throughout the 21st century. Information technologies are self-generating because they help to navigate the unknowns of nature through scientific discovery. This in turn enables us to develop faster and more cost effective technologies, thus uncovering more of nature's secrets, which ultimately leads to a compounding of technological capacity. There are numerous information technologies available to help significantly reduce VAT shortfalls, including machine learning, super digital computers, quantum analogue computing, and distributed ledger technology. The key challenge is for governments to implement and leverage these technologies faster than organised crime groups can deploy them. DLT proposition The development of an EU-wide series of VAT standards and protocols would enable DLT to be deployed across Europe, with unilateral alignment of all VAT accounting transactions, from invoices to bank receipts. The system could include smart contracts designed to outsmart the tax quasi-compliant economy, which would also help to address the various threshold differences in VAT applicability across EU member states. With machine-learning devices reading the EU's VAT transactions in real time, erroneous transactions (including so-called carousel fraud) are far more likely to be spotted than by the current methods of auditing. Increasing traceability and transparency - including payment providers, banks and other financial institutions - would make the black-market economy more difficult to conceal. Outcomes • Reduce the administrative burden imposed on companies and other organisations to collect and pay VAT • Increase transparency of real-time transactions throughout the economy • Create opportunities to assess credit risk more accurately, reducing losses caused by insolvency • Provide data to lenders that offer finance to SMEs, including credit factoring • Enable smart contracts between treasuries and commerce Maturity level • Technologically ready • Important to bring payment organisations into the conversation early on, as their data inputs are also required to ensure visibility over payment settlements • Government agencies need to be able to handle DLT for tax • End-users and small business owners need to understand how to use DLT for effective tax management ## Conclusion Distributed ledgers undoubtedly hold value for government, offering new ways of operating that reduce fraud, error and the costs of delivering services to underserved users. At the same time, these technologies offer new forms of innovation and the ability to reduce transaction costs for SMEs in the UK. This chapter has highlighted only some of the possible use cases. As distributed ledgers are adopted more widely, it is likely that a new form of operating government services will emerge. ## G Lobal Perspectives Organisations that do digital business in cyberspace must be able to trust - and be trusted by - their partners. They also need to be interoperable with large and growing communities of other organisations around the world. Block chains have the potential to contribute to both. ## Chapter 7: Global Perspectives Introduction The rate of global change - both good and bad - is accelerating, driven by internet-enabled globalisation, societal expectations, and increasing competition for resources. Unlike the developing world, developed nations and their citizens have a consumerist ethos and privacy expectations that can conflict with traditional, resilient community values and personal norms of behaviour. This has left the state, rather than the community, responsible for helping those in distress and hard times. Governments struggle to satisfy these growing demands of consumer expectation and seemingly bottomless social assistance. US President John F . Kennedy's call - "ask not what your country can do for you, ask what you can do for your country" - has increasing relevance today: most citizens want to help their country but they lack the means to engage in the digital age. They want to be part of the herd, not a vulnerable outlier. One consequence of this lack of community behaviour is a polarisation in attitudes, an emergence of differing perceptions and an increasing tendency to oversimplify complex changes into a series of binary disconnected issues. The global reality is a complex mesh of physical, virtual, legal, historical, geographical, societal, behavioural, economic, informational and technological factors. The rate of change and the speed of introduction of new, disruptive technologies add to this complexity. Scale, speed and complexity have to be considered together. This makes it increasingly difficult for industry leaders and national governments to understand this mesh, and to plan, implement and realise benefits using their traditional non-collaborative organisational structures. The initiative lies with those who are more agile, such as the financial markets and organised crime. Increasingly, developing nations such as Kenya and Rwanda are leaping to new technologies, unencumbered by this legacy. In the developed world, some smaller and more homogeneous nations are making significant advances that are transcending borders to provide international benefits, particularly in Europe (see case studies on European energy markets, p76, and on Estonia, p80). The hallmarks of advancing digital nations include: • A digitally-informed leadership • An empowered, focused government department for all national digital transformation, which is internationally minded and collaborates closely with all industry sectors • A living, collaborative national plan, which is industry-led with government investment • Technologically aware, qualified and experienced senior political officials in every government organisation • Engineers and digital business leaders as elected politicians. The UK has much to do in each of these areas if it is to become one of the leading digital nations. Yet the world increasingly relies on digital economies. This requires us to do more than apply computer technology to existing economic models; instead, we must reassess our understanding of what a digital economy is becoming, as well as its constituent actors and activities. This is similar to the transition from cash-based to asset-based accounting, which requires every organisation to have a much wider understanding of the complexity of supply chains, services and markets, and demands a different approach to collaborative risk management, decision making, gainsharing and shared liability. To do digital business in cyberspace, an organisation has to be able to trust, and be trustworthy. It also has to be interoperable with large and increasing communities of other organisations. Trust and interoperability are foundational in cyberspace, much more so than in the physical world. Block chains have the potential to contribute to both, but the magic is not in the technology - it is in how we use it nationally. ## Trust And Interoperability Trust is a risk judgement between two or more people, organisations or nations. In cyberspace, trust is based on two key requirements: • Prove to me that you are who you say you are (**authentication**) • Prove to me that you have the permissions necessary to do what you ask (**authorisation**) If I am not satisfied with the response, I can still choose to allow you to proceed, but I am incurring risk. However, there is no viable relationship unless others trust me too. In this sense, being trustworthy is analogous to being creditworthy. Interoperability involves several factors: • Data interoperability. We need to understand each other in order to work together, so our data has to have the same syntactic and semantic foundations • Policy interoperability. Our policies need to be aligned or based on agreed common policy, so that I can be confident that you will treat my information in the way that I expect (and vice versa) • The effective, collaborative implementation and use of international standards Information protection is about access control, which requires authentication, authorisation and more. Authentication requires identity management of all entities involved (usually people, organisations, devices and software), to a given, internationally-defined level of assurance (LoA). Authentication across communities of multiple authorities or organisations requires federated identity management (FIM). At an international scale, such FIM currently exists only at 'low assurance', designated LoA 1 in international standards1. It is primarily applied in social networking where multi-jurisdictionality is not a significant issue. Google, GakuNin (the Japanese universities network), Microsoft, Ping Identity, The Nikkei newspaper, Tokyu Corporation, mixi, Yahoo! Japan and SoftBank have also deployed FIM systems; and there are more mature deployments underway by other organisations, such as Deutsche Telecom, AOL, and Salesforce.com. Medium assurance (LoA 2) requires evidence of identity during enrolment to meet Know Your Customer (KYC) requirements, which financial institutions require of consumers and businesses in financial transactions. There is some federation at LoA 2, mostly in banking systems. Several industries use security systems based on Public Key Infrastructure (PKI) federations that rely on a cryptographic standard called X.509. These offer high and very high assurance levels (LoA 3 and 4) for employee authentication, notably in aviation, the pharmaceutical industry, defence, banking and, increasingly, e-health. The US and China have the largest deployments of international-standard PKI federations, closely followed by South Korea (where it is mandated for all companies by regulation), Estonia, Netherlands and many others. At LoA 3+, it is possible to link a user's identity to other trust functions, such as legally-robust digital signatures, identity-linked encryption and physical access control in buildings. PKI federation isn't the only option for high assurance supply chain collaboration and sharing sensitive information at scale, but it is the de facto norm today. Block chains offer a potential alternative, but a combination of PKI federation and block chain federation offers even more attractive opportunities for greater digital accountability, assurance and trust in business processes, coupled with exploiting new technologies. In the UK, only the police service operates a large-scale PKI federation in accordance with international standards, albeit in a basic form. With best-practice collaborative governance, this could be expanded to support many UK government services, including the emergency services; and international collaborations in areas as broad as trade, border controls or migrants and refugees, with other allies who have similar PKI federations today. The strategy for the government's Public Services Network to use PKI federation for employee authentication has yet to be implemented, however, so there is no high assurance identity management of employees or collaborative trust across government organisations, based on international standards, that could federate with industry partners and international allies eg US, France and the Netherlands. In combination with block chains, PKI federation could provide enhanced services extending to the privacy-friendly handling of identity data and greater traceability of payments. The NHS has a very large PKI, but it does not comply with international standards and cannot (yet) federate. The MOD has international obligations to establish PKIs with the US-centric defence supply chains, and similar obligations under the NATO Cyber Defence Action Plan, but has no published implementation plans. Industry is considering other potential areas for PKI federation eg for countering food fraud, described in the 2014 Elliott Review into the integrity and assurance of food supply networks. It is also developing a memorandum of understanding with a South Korean government agency that would enable British companies to have PKI credentials that could be used in the supply chains of Korean businesses eg Samsung, Kia, Hyundai and Daewoo (which is currently the manufacturer of the largest container ships in the world). The UN's International Maritime Organisation is developing international guidelines for maritime cybersecurity, and has the potential to leverage the UK- Korea PKI federation initiative. There are more examples in other areas, and all would benefit from a forum where these discussions can come together in a collaborative manner. The EU Parliament approved the Electronic Identification, Authentication and Trust Services Regulation (eIDAS) in September 2014, giving nations three years to comply. Under eIDAS, if any nation 'notifies' an e-ID scheme for its citizens, the e-IDs are legally required to be accepted by every other member state for electronic public purposes. Much work has yet to be done, but eIDAS is forcing governments and industry to consider their overall plans to exploit FIM for societal and commercial benefit. In the UK, the government has introduced a federated, standards-based approach to identity assurance: GOV.UK Verify. GOV.UK Verify has been built to respond to the latest developments in the market by having competing providers of identity services and allowing users to choose which one to use. Enhancing and linking Verify to block chains and PKI federations could add value to Verify itself. Block chain and high assurance PKI federation solutions could benefit from Verify's privacy-friendly inputs. Together, in their different ways, they would contribute significantly to the UK's digital economy, border control and its efforts to combat cybercrime. ## Case Study 1 European Energy Retail Market Igor Nai Fovino and Jean-Pierre Nordvik, Joint Research Centre, European Commission currently investigating their practical applications, such as the following cases. The European Commission Energy Union Framework Strategy1 sets out the vision of an 'Energy Union' "with citizens at its core, where citizens take ownership of the energy transition, benefit from new technologies to reduce their bills, participate actively in the market, and where vulnerable consumers are protected". However, while the development of energy smart-grids is progressing steadily, the retail energy market is still waiting for modernisation. The Commission's policy initiative 'New Energy Market Design' will have to face several crucial points: • how to deliver appropriate information on costs and consumption to consumers so that they can identify new opportunities in a fullyintegrated continental energy market • how to reward for active participation, facilitate switching of contracts and manage demandresponse to dynamic prices • how to ensure interoperability in the market 1. Micro-Generation energy market. Microgeneration is the capacity for consumers to produce energy in-house or in a local community. The concept of 'market' indicates the possibility of trading energy that has been micro-generated among consumers and 'prosumers'. Traditionally, however, this market has been served by predefined bilateral agreements between prosumers and retail energy suppliers. Until now, electricitygenerating prosumers have not had real access to the energy market, which remains a privileged playing field for the institutionalised energy suppliers. This has greatly limited the economic advantages of micro-generation for endusers. Distributed ledgers, in combination with smart-metering systems and next-generation batteries (to accumulate energy locally), have the potential to open the energy-market to prosumer production. Smart meters could be used to account and register the micro-generated energy on a distributed ledger (becoming the equivalent of an 'energy-coin' system). for residential energy services, expanding consumers' choices, and enable a real gain from self-generation and self-consumption, and local micro-generation. Self-generated electricity could normally be either consumed within the house, or accumulated in next-generation batteries for later use, or simply given back to the grid. Alternatively, thanks to the distributed and pervasive nature of the ledger, In this context, distributed ledgers can act as a new driver to enhance the level of integration and development of the energy retail market. The Joint Research Centre2 of the European Commission is In cyberspace, every entity and transaction binds or links to an organisation. Establishing the validity of an organisation to the desired LoA, and information about it in real or near-real time, is a fundamental digital requirement. Increasing use of block chains will considerably increase this requirement to avoid any records in the chain becoming tainted. A new international standard is being developed for digital organisational identification, known as the Register of Legal Organisations (ROLO). Several nations, including the US, are already considering adapting the ROLO specification to meet their needs. Today, globalisation and the lack of digitally-suitable business registers is resulting in a situation, particularly in the EU, where the majority of financially active organisations in a country are not registered in that country or at all, but it is not possible to tell the difference. UK industry and government organisations, including law enforcement and cybersecurity organisations, urgently need ROLO UK as a digital trust anchor. Industry is starting to develop ROLO UK, which would benefit from greater participation by government user organisations. ## Digital Economies the produced energy could also be redeemed elsewhere, for example when charging an electric vehicle abroad; or sold through the ledger to the best buyer, according a mechanism similar to that of a stock-exchange market. Digital economies seek to harness speed, reach and efficiency. Federated trust enables confidence and risk reduction. Interoperability enables efficiency and reuse of capabilities. In a mature supply chain, each time a company competes in a new programme or sector, re-use gives it agility and a competitive advantage: a view held by aerospace and defence companies and voiced publicly by Airbus, Boeing, BAE Systems, Lockheed Martin, Northrop Grumman, Raytheon2 and others. 2. Energy Contracts Ledger. A consumer who intends to change energy supplier currently needs to close their contract with their current supplier, then open a new contract with a new supplier, and revisit the contractual conditions of all complementary energy services provided by third parties. Managing the administrative complexity of these operations is a real barrier to developing a competitive energy retail market, and is a source of cost for energy suppliers and distributors. Using distributed ledgers to record energy contracts online would greatly simplify these operations. It would allow consumers to finalise the transition from one supplier to another with just a few clicks on a computer or mobile device. Likewise, energy suppliers and energy service-providers would save resources otherwise devoted to these administrative operations. There are still questions about the scalability, security and stability of such applications. However, the benefits are so promising that they certainly merit further investigation. In February 2014, Neelie Kroes, then a vicepresident of the European Commission and its digital agenda commissioner, stated that "democracy must talk to technology3". She argued that we are making a transition to a data-driven world in which trust is key, and that "without security there is no privacy". She pointed out that strong cybersecurity is important to Europe's Single Digital Market, and that the EU Cyber Security Strategy is providing the right building blocks. Without such initiatives, she concluded, democracy would "fail to manage technology". The dialogues on these topics involving the EU, US and the Association of Southeast Asian Nations (ASEAN) are gradually converging in banking, electronics, pharmaceuticals, food, maritime, aerospace, cyberspace and law enforcement. Through the UN and organisations like the Council of Europe, there is a growing push for developed nations to help developing nations as they become part of the global digital economy. But a lack of digital governance hampers developing nations, creating major opportunities for cybercrime and terrorism that ultimately target developed nations. The Commonwealth could play a significant role in tackling this situation. Collaboration is key. ## The Potential Of Decentralised Ledgers And Block Chains Economies rely on collaborative governance to provide trust in the financial markets, ensuring that all play by agreed rules. Digital economies are the same. The primary reason that block chains are associated with cybercrime is an absence of strategic governance to establish agreed rules and ensure compliance. Once such governance (with policies, procedures and mechanisms) and enforcement exist, the true societal benefits of block chains can be realised. Governmental concerns about the instabilities and vulnerabilities associated with cryptocurrencies and their trading exchanges have made governments cautious regarding the use of block chains, and, generally, they would prefer industry to lead in the development of a better situation. The main areas for development today are: • Ungoverned block chains are used for unregulated and criminal activities, particularly where parties seek to be anonymous and unaccountable • Startup companies are working with leading banks to develop trusted cryptocurrencies and block chains eg a 'trusted Bitcoin'. This could offer significant benefit to major online consumer companies • Private block chains are being used in closed commercial communities to support digital trust mechanisms, under their own rules. These are noninteroperable and cannot scale to support supply chains Only recently have governments started to work with industry to explore the strategic potential of block chains. But implementation will accelerate, driven by four major enablers: • To provide a basis for cryptographic trust in a similar way to PKI. This means that block chains could federate with each other and also with existing PKI federations. Block chains could leverage PKI's deployed scale and governance, while PKIs could leverage block chain's payment and ledger functions. These synergies would open up new opportunities that smart, collaborative governance could accelerate. • Permissioned ledgers contain a data field of unlimited size. Information about a transaction, including the contract, licence or copyright, could be included, providing a strong additional factor for trust. This enables 'smart contracts' (ie the binding of the contract to the transaction - see Chapter 1 for more), offering efficiency and non-repudiation. • Leveraging new protocols, such as the new Uniform Economic Transfer Protocol (UETP) that links the producer to the carrier, the customer, the product, the payment and the banks, and also to the smart contract. The Netherlands is leading on this, with UK industry and possible police participation. US involvement is beginning and will accelerate due to their emerging regulations for cyberassurance across all supply chains. Other nations, such as South Korea and Japan, are expected to be involved soon. • Smartphones are becoming the de facto trusted user device. The latest smart phones include important new security features, including: Trusted Platform Module, which secures digital certificates and cryptographic keys for authentication, encryption and signing; Trusted Execution Environment, where secure processing occurs without the operating system that could be vulnerable to malware; and Trusted User Interface, which prevents a malware attack between the user and the device. Using near-field communication, the smart phone could interact securely with some national e-ID cards and electronic passports, so that a user could interact securely online with an authority eg at a border or with the police. Consumers and employees now have a secure, trusted device for the first time ever, with which they can sign transactions (eg using a block chain) and payments (eg using a 'trusted Bitcoin'). Samsung, HTC, and LG have been selling tens of millions of such advanced security-enabled smartphones, ready for the software to be deployed in early-mid 2016. Apple and others are expected to follow suit. Strong collaborative and pervasive governance is required to ensure that these capabilities are not abused or misused. These four enablers are encouraging greater use of block chains and distributed ledgers for financial purposes, and for a growing range of other digital, data-centric purposes across supply chains and with governments. As such systems mature, and their capabilities expand, these four enablers could help to solve a number of difficult social and global challenges. Examples include: • **Transparent and honest government**. Trust among citizens in developing countries is lower than in countries where stable and accountable legal and regulatory structures engender better community and societal behaviours. It takes a long time for people living in regions devastated by wars and autocratic regimes to trust their governments and to be relatively free of corruption. Accountability and assurance mechanisms (using block chains, FIM and related capabilities), embedded in business processes, are vital to ensure effective implementation and enforcement of laws, policies and organisational structures. • **Tax evasion and money laundering**. When the distribution curve of a country's wealth steepens excessively, money and asset ownership seeks off-shore domiciles to conceal wealth, reducing financial liquidity in home markets and thereby diminishing economic opportunity for those further down the wealth distribution curve. Eventually, capital starvation can start to unseat economies, followed by wide-scale youth unemployment that can scar lost generations with a long-standing distrust in their leadership. This undermines democracy, creating conditions for societal fracture, failed states, terrorism and human misery. Again, accountability and assurance are required to tackle these problems. • **Illegal trade and environmental vandalism**. About 50% of marine species have become extinct in the past 30 years, and the situation is similar on land. Despite international efforts under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), the evidence suggests we are heading towards the Earth's sixth mass extinction. If we are to have any hope of rescuing the global situation, we have to implement much stronger detection and asset tracking mechanisms, with the same accountability and assurance. • **Food fraud and supply chain disruption**. The UK is more dependent on food imports than ever before, and more vulnerable to national food denial than in 1917 or 1942. The food supply chain can be difficult to track - witness the meat adulteration saga of 2013 (widely known as the 'horsemeat scandal'), ## Case Study 2 Estonian Block Chains Transform Paying, Trading And Signing Alastair Brockbank, British Embassy Tallinn Experimenting with block chain technology was a logical step for Estonia. By providing a distributed and unalterable ledger of information, it has ideal qualities for the storage and management of public keys. These are a form of encryption key, provided by a designated authority, which can be combined with a private key to effectively encrypt messages and authenticate digital signatures. Estonia now has the most regularly used national Public Key Infrastructure (PKI) in the world. The three case studies below - profiling a bank, a start-up and a cybersecurity provider - show the transformative power of block chains for a wide range of transactions. All three examples underline that block chains must be made userfriendly. The customer need not know that they are trading in coloured coins, nor that their ID card login uses hash-function cryptography. In this sense, a block chain acts as a silent, more efficient workhorse behind a solution that looks familiar: a mobile payments app, an online crowdfunding and trading platform, or a login portal. Moreover, as a decentralised solution, a block chain is inherently more portable and scalable. It is capable of computing vast amounts of data every second and seamlessly working across borders. For companies in a country of just 1.3 million people, block chains thus offer a way for national solutions to more easily become global solutions. Their computational power also makes them faster, and in certain cases the technology has the disruptive power to make existing intermediaries redundant. As in the UK, the need for and extent of regulation is a key issue for the Estonian authorities. They understand that hesitation and indecision can be as damaging to innovation as strictness. The risks of innovators moving to new and less tightly regulated jurisdictions - specifically, the loss of revenue from failing to capitalise on commercial opportunities, and the potential for criminal activity - are patently clear. for example - and there are many opportunities for fraud. The international and UK food supply chains have no choice but to follow best-in-class supplychain assurance from other sectors, in order to implement accountability and granular traceability. • **Supply chain threats**. As cybercrime and international intellectual property theft increase (involving sums of more than $7 trillion globally), supply chains are coming under increasing regulatory, market and societal pressures for stronger assurance based on collaborative risk management, including accountability and federated identity management. Along with other advanced nations and international experts, the UK could influence the Council of Europe, the World Bank, G20 and the UN to implement block chains with strong authentication, to provide and enforce accountability and assurance. The UK government cannot do this alone. Industry wants the government to be part of an energetic national approach to achieve national capability and first-mover advantage, collaborating with industry to ensure UK is amongst global leaders. ## A Pioneering Bank Issues Cryptocurrency Securities Earlier this year, LHV Pank - the largest independent Estonian bank - became the first bank in the world to experiment with programmable money when it issued €100,000 worth of cryptographically-protected certificates of deposits. The experiment followed the establishment of a new LHV subsidiary, Cuber Technology, focused exclusively on Bitcoin-based digital securities. Cuber's work comprises two strands: CUBER securities and the Cuber Wallet. CUBER (Cryptographic Universal Blockchain Entered Receivable) securities are simply bank certificates of deposits recorded in the Bitcoin block chain. They are denominated in euros, may pay interest and are suitable for various purposes - as a store of value, medium of exchange, trust and escrow services, and even for machineto-machine transactions, opening potential applicability in the Internet of Things (IoT). LHV views CUBER securities as the Lego building block for their future financial innovation. The Cuber Wallet is the first demonstration of CUBER usability. It is a piece of software for mobile phones, enabling instant and free peerto-peer euro transactions, and low cost instant payments for merchants and consumers, using underlying CUBER securities. Users store their private keys on their smartphone to enhance security and mobility. To protect against server compromises, Cuber Wallet decentralises trust from the server and makes the users themselves the Bitcoin clients. The app uses SPV (Simplified Payment Verification) - a type of 'thin client' security - which means the user never has a complete copy of every block in the chain. Instead they download a smaller amount of data, the 'blockheaders', which link transactions to a place in the chain. This allows them to see that a network node has accepted the transaction, while blocks added after it further confirm that the network has accepted it. The wallet uses bitcoins as a data carrier, which they 'paint' by adding unique markers to them. This then represents a claim in fiat currency against LHV Bank, as the entry into a database represents a claim against the traditional bank system. By using fiat currency, the wallet can be used not just for personal transfers, but also for retail payments - the merchant has to approve this payment method just as they have to approve credit cards. LHV is currently testing it in a few physical locations, but anticipate wider utility in online business, particularly for smaller payments. The use of fiat currency undoubtedly makes the app more user friendly. LHV asserts that the underlying technology is the bank's concern: the user and merchant do not and should not need to ## Case Study 2 (Continued) see, nor know, that Cuber uses Bitcoin. ## A Liquid Aftermarket For Start-Up Investments The illiquidity of start-up investment is a common complaint from angel investors and founders alike. Backers typically need to part with at least €10,000, and must often wait 5 or more years to exit. Cuber's open source code and application program interface are available to third parties online, inviting other cryptocurrency exchanges and developers to tap into the technology. Both LHV and its development partner, ChromaWay, prefer to drive usable innovation with smaller software developers and start-ups, rather than large banks. Funderbeam - a reputed business intelligence platform for investors - may well have found a solution to this problem: a block chain-based investment marketplace, to buy and sell coloured coin stakes in start-up syndicates. When pressed on their challenges, LHV is clear: regulatory uncertainty risks killing Cuber's transformative power by severely limiting its reach. The bank urges regulators to embrace block chain technology and adapt, rather than run scared from it. Investors will soon be able to use Funderbeam's online platform to create an investment syndicate for one or several start-ups. Investment can be in any configuration, and there is no limit to the size of a syndicate. A £100,000 stake could comprise one lead investor and 99 backers investing £1,000; a lead investor on £75,000 and five backers on £5,000; or any other combination. Similar to crowdfunding, this diminishes the threshold to invest in start-ups. What differentiates Funderbeam from the crowdfunding alternatives is the issuance of 'coloured coins' representing syndicate members' stakes, which can be instantly bought, sold, or traded with other investors. This enables more fluid management of investment portfolios, and expedites financing for start-ups. The Bitcoin block chain underpins the aftermarket, allowing for fast, effective and transparent asset ownership tracking. On the face of it, being backed by a bank affords Cuber huge advantages, because transferring money from a conventional bank account to a digital wallet (and back again) is simplified. CUBER is technically still a security - the foundation of bank trading - albeit with decentralised record keeping. But in reality, being a bank remains a regulatory obstacle, because they are typically subject to more legal arbitrage than new innovators. Similarly, EU Know Your Customer (KYC) rules that require a face-to-face meeting to create a bank account disadvantage Cuber when other online payment services such as TransferWise and Holvi only need a quick online sign-up. If banks are to compete effectively in this market, regulation will need to impose no additional barriers to banks, nor reduce their mobility to reach and recruit new users. Admittedly, LHV is in an unusual position: an 'innovation-friendly' bank doing it themselves, but whose forward progress is currently restricted by regulatory uncertainty. With no positive movement, Cuber will either have to be distanced from LHV's license and the advantages that being tied to a bank bring, or look at moving outside Europe to another jurisdiction. Every syndicate is paired with a microfund. Once a syndicate is complete, and the start-up is funded, Funderbeam's aftermarket uses coloured coins to give all members of a syndicate a digital representation of their share in that microfund, which is immediately tradable. Backers can thus sell their whole share, or a proportion of it, once they have made a decent return or want to cut their losses. Developing a simple, secure and legally compliant bridge between crypto and traditional banking continues to prove exceptionally challenging for all players. But none are closer than LHV. Flexibility for investors is not the only benefit the block chain solution affords. Kaidi Ruusalepp, CEO of Funderbeam, also points to the efficiencies that a distributed ledger offers through bypassing bureaucracy. "We don't need a business registry, central depository, or another formal authority to confirm the integrity of a transaction," he says. "With the block chain, every investment, every ownership change has a secure, distributed audit trail." Jaan Tallinn, co-founder of Skype and an investor in Funderbeam, lauds the additional layer of security and verification it offers for online transactions. By being decentralised and unalterable, block chains can create more transparency in the equity market, without compromising anyone's privacy. Funderbeam's offering - providing flexibility, speed, security and transparency - shows how distributed ledgers can provide an alternative but wholly viable basis for small and medium-sized enterprise (SME) financing to expand in the 21st century. ## The Next Generation Of Public-Key Infrastructure Since 2013, Estonian government registers - including those hosting all citizen and businessrelated information - have used Guardtime to authenticate the data in its databases. Their Keyless Signature Infrastructure (KSI) pairs cryptographic 'hash functions' (see below) with a distributed ledger, allowing the Estonian government to guarantee a record of the state of any component within the network and data stores. This is no small undertaking. Estonia has the most regularly used national PKI in the world. Using their ID card, citizens order prescriptions, vote, bank online, review their children's school records, apply for state benefits, file their tax return, submit planning applications, upload their will, apply to serve in the armed forces, and fulfil around 3000 other functions. Entrepreneurs use the ID card to file their annual reports, issue shareholder documents, apply for licenses, and so on. Government officials use the ID card to encrypt documents for secure communication, review and approve permits, contracts and applications, and submit information requests to law enforcement agencies. Ministers even use their ID cards to prepare for and conduct cabinet meetings, allowing them to review agendas, submit positions and objections, and review minutes. Digital authentication is thus critical to government, business and public services alike, from drafting policy and legislation, to declaring finances and registering property and inheritance rights. Over 200 million digital signatures have been made using the ID card: some 39 per capita per year and rising. It is thus imperative for the government to know its records are the right records, and that they have not been altered from the inside, or by a cyber attack. So how does a block chain help? It helps because every alteration of a piece of data is recorded. By providing proof of time, identity and authenticity, KSI signatures offer data integrity, backdating protection and verifiable guarantees that data has not been tampered with. It is transparent and works to the user's benefit too: citizens can see who reviewed their data, why, and when; and any alterations to their personal data must be authorised. Moreover, through using hash functions, as opposed to asymmetric cryptography used in most PKI, KSI cannot be broken by quantum algorithms. It is also so scalable that it can sign an exabyte of data per second using negligible computational and network overhead. It removes the need for a trusted authority, its signed data can be verified across geographies, and it never compromises privacy because it does not ingest customer data. It is clear that the system marks a major advancement in PKI. Ultimately, the KSI block chain means that while the Estonian ID Card may never be immune to a breach (although there have been none so far), the government is assured that rogue alterations to public data will be 100% detectable. ## References Executive Summary 1 Government Office for Science 'FinTech Futures: The UK as a World Leader in Financial Technologies' 2015. Available at https://www.gov.uk/government/uploads/ system/uploads/attachment_data/file/413095/gs-15-3-fintech-futures.pdf Chapter 1 1 Government Office for Science 'FinTech Futures: The UK as a World Leader in Financial Technologies' 2015. Available at https://www.gov.uk/government/uploads/ system/uploads/attachment_data/file/413095/gs-15-3-fintech-futures.pdf 2 IBM Institute for Business Value 'Device democracy: Saving the future of the Internet of Things' 2015. Available at http://www-01.ibm.com/common/ ssi/cgi-bin/ssialias?subtype=XB&infotype=PM&appname=GBSE_GB_TI_ USEN&htmlfid=GBE03620USEN&attachment=GBE03620USEN.PDF 3 Government Office for Science 'The Internet of Things: making the most of the Second Digital Revolution' 2014. Available at https://www.gov.uk/government/ uploads/system/uploads/attachment_data/file/409774/14-1230-internet-of-thingsreview.pdf Chapter 2 Case Study: Research and horizon scanning 1 'CREDIT: Cryptocurrency Effects in Digital Transformations' EPSRC reference EP/N015525/1 (2015). Available at http://gow.epsrc.ac.uk/NGBOViewGrant. aspx?GrantRef=EP/N015525/1 2 '2015 ITaaU Community Conference'. Available at http://www.itutility.ac.uk/ event/2015-itaau-community-conference/ 3 Networked Society Lab, Ericsson 'ICT and the Future of Financial Services' (2014). Available at http://www.slideshare.net/Ericsson/horizon-scan-ict-andthe-future-of-financial-services 4 EPSRC 'Trust, Identity, Privacy and Security in the Digital Economy' (2015). Available at https://www.epsrc.ac.uk/funding/calls/trustidentityprivacysecurity/ 5 Perry M and others 'The currency of digital money' (2015). Available at https://www.youtube.com/watch?v=PCa3pTCegE8 6 3DaRoC 'Digital Intermediary Exchange Toolkit' (2015). Available at https://digitalintermediaries.wordpress.com/toolkit/ Chapter 3 1 Lessig L 'Code and other laws of cyberspace, Version 2.0', New York: Basic Books 2006. 2 New York Department of Financial Services 'BitLicense Regulatory Framework'. Available at http://www.dfs.ny.gov/legal/regulations/rev_bitlicense_reg_framework. htm Chapter 4 1 Internet Engineering Task Force 'Certificate Transparency' 2013. Available at https://tools.ietf.org/html/rfc6962. Also see http://www.certificate-transparency.org/ 2 Melara MS and others 'CONIKS: Bringing Key Transparency to End Users' Cryptology ePrint Archive: Report 2014/1004. Available at http://eprint.iacr.org/2014/1004.pdf 3 Danezis G and Meiklejohn S 'Centrally banked cryptocurrencies' Cryptology ePrint Archive: Report 2015/502. Available at https://eprint.iacr.org/2015/502.pdf 4 Courtois N 'Is Bitcoin Going to Split in Two?' 2015. Available at http://blog.bettercrypto.com/?p=1811 5 Nakamoto S 'Bitcoin P2P e-cash paper' 2008. Available at http://satoshi.nakamotoinstitute.org/emails/cryptography/1/ 6 Meiklejohn S and others 'A fistful of bitcoins: characterizing payments among men with no names' Internet Measurement Conference 2013 pages 127-140 7 Danezis G and others 'Statistical Disclosure or Intersection Attacks on Anonymity Systems' Information Hiding 2004 pages 293-308 8 Bonneau J and others 'Mixcoin: Anonymity for Bitcoin with Accountable Mixes' Financial Cryptography 2014 pages 486-504 9 Garman C and others 'Rational Zero: Economic Security for Zerocoin with Everlasting Anonymity' Financial Cryptography Workshops 2014 pages 140-155 10 Miers I and others 'Zerocoin: Anonymous Distributed E-Cash from Bitcoin' IEEE Symposium on Security and Privacy 2013 pages 397-411 11 Danezis G and others 'Pinocchio coin: building zerocoin from a succinct pairingbased proof system' PETShop@CCS 2013 pages 27-30 12 Groth J and Kohlweiss M 'One-Out-of-Many Proofs: Or How to Leak a Secret and Spend a Coin' EUROCRYPT 2015 pages 253-280 Chapter 5 1 Christensen CM and others 'Strategies for Survival in Fast-Changing Industries' Management Science 1998: volume 44, pages S207-S220 2 Jacobides MG and others 'Benefiting from innovation: Value creation, value appropriation and the role of industry architectures' Research Policy 2006: volume 35, pages 1200-1221 3 Baden-Fuller C and others 'Business Models & Technological Innovation' Long Range Planning 2013: volume 46, pages 419-426 4 Jacobides MG and others 'Who does what and who gets what: capturing the value from innovation' Advanced Institute of Management Research Briefing 2006. Available at http://faculty.london.edu/mjacobides/assets/documents/whodoeswhat. pdf 5 Perez C 'Technological Revolutions and techno-economic paradigms' Working Papers in Technology Governance and Economic Dynamics 2009: Tallinn University of Technology, Tallinn, Norway 6 Rifkin J 'The Zero Marginal Cost Society: The Internet of Things, the Collaborative Commons, and the Eclipse of Capitalism' 2014. New York, Palgrave Macmillan 7 Birch D 'Identity is the New Money' 2014. London Publishing Partnership Chapter 5 Case Study: Corporate actions 1 Oxera. 'Corporate action processing: what are the risks?' May 2004. http://www.oxera.com/Oxera/media/Oxera/downloads/reports/Corporateaction-processing.pdf?ext=.pdf Chapter 6 1 Swan M 'Blockchain: Blueprint for a New Economy' O'Reilly Media Inc 2015 2 Department for Work and Pensions 'Fraud and Error in the Benefit System 2013/14' 2014. Available at https://www.gov.uk/government/collections/fraud-and-error-inthe-benefit-system 3 Financial Inclusion Commission 'Financial Inclusion: Improving the financial health of the nation' 2015. Available at http://www.financialinclusioncommission.org.uk/ report 4 Rowlingson K and McKay S 'Financial Inclusion: Annual Monitoring Report 2014'. Available at http://www.birmingham.ac.uk/Documents/college-social-sciences/ social-policy/CHASM/annual-reports/chasm-annual-monitoring-report-2014.pdf 5 United Nations 'The Millennium Development Goals Report' 2010. Available at http://www.un.org/millenniumgoals/pdf/MDG%20Report%202010%20En%20 r15%20-low%20res%2020100615%20-.pdf 6 Ammous S 'Economics beyond Financial Intermediation; Digital Currencies' possibility for growth, poverty alleviation and international development' Columbia University Working Paper No. 82 November 2013 7 Mulligan CEA 'The Communications Industries in the Era of Convergence' Routledge 2011 8 Swan M 'Blockchain: Blueprint for a New Economy" O'Reilly Media Inc 2015 9 A more extensive list is available at 'Bitcoin Series 24: The Mega-Master Blockchain List'. Available at http://ledracapital.com/blog/2014/3/11/bitcoin-series-24-themega-master-blockchain-list (accessed 13 August 2015) 10 EU Taxation Commissioner Algirdas Semeta, quoted in 2013 at http://www.eureporter.co/economy/2013/09/20/fight-against-fraud-study-confirmsbillions-lost-in-vat-gap/ (accessed 18 September 2015) Chapter 7 1 ISO/IEC 29115 - Entity Authentication Assurance Framework 2 Including Boeing, Northrop Grumman and Raytheon joint video. 3 EU Cybersecurity Strategy High Level Review - 28 Feb 14. Chapter 7 Case Study: European Energy Retail Market 1 European Commission 'A Framework Strategy for a Resilient Energy Union with a Forward-Looking Climate Change Policy' 25 February 2015: COM(2015) 80 final. Available from http://eur-lex.europa.eu/resource. html?uri=cellar:1bd46c90-bdd4-11e4-bbe1-01aa75ed71a1.0001.03/ DOC_1&format=PDF 2 Joint Research Centre. Available from https://ec.europa.eu/jrc/ ## Acknowledgements I would like to thank the many contributors for the support they have provided to this review - Sir Mark Walport, Government Chief Scientific Adviser. The expert panel for their guidance and drafting of the evidence papers: Robleh Ali Bank of England Richard Brown R3 Patrick Curry British Business Federation Authority Richard Copland CGI Group Dr Phil Godsiff University of Surrey Mike Halsall Singularity University/ Almanis Derwen Hinds CESG Matthew Johnson Guardtime Dominic Hobson COOConnect Dr Vili Lehdonvirta Oxford University Jonathan Levin Chainalysis Dr Catherine Mulligan Imperial College London / Future Cities Catapult Professor M. Angela Sasse University College London Dr Chris Sier FiNexus Daniel Shiu GCHQ Simon Taylor Barclays ## Additional Contributions And Advice From Hadley Beeman Gds Dr John Baird EPSRC Alastair Brockbank British Embassy Tallinn, Estonia Dr George Danezis University College London Shaul David UKTI Nick Davies DWP Igor Nai Fovino Joint Research Centre, European Commission Leanne Kemp Everledger Dr Sarah Meiklejohn University College London Jean-Pierre Nordvik Joint Research Centre, European Commission Tom Price BIS Thomas Wilkinson Home Office Naomi Wright HMRC The review team for their support and synthesis of the evidence papers Dr Claire Craig GO-Science Martin Glasspool GO-Science Emma Griffiths GO-Science Elizabeth Surkovic GO-Science ## Editor Dr Mark Peplow © Crown Copyright 2016 This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk. Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned. This publication available from www.gov.uk/go-science Contacts us if you have any enquiries about this publication, including requests for alternative formats, at: Government Office for Science 1 Victoria Street London SW1H 0ET Tel: 020 7215 5000 Email: contact@go-science.gsi.gov.uk ## Gs/16/1
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## First Findings From The Uk Innovation Survey 2013 Knowledge And Innovation Analysis APRIL 2014 ## Contents | Introduction | | 1 | |-------------------------------------------------------------------------------|-----|-----| | | | | | 1. | | | | | | | | Innovation activity | | 3 | | | | | | 2. | | | | | | | | Breakdown of innovation activities | 6 | | | | | | | 3. | | | | | | | | Non-technological or wider forms of innovation | 8 | | | | | | | 4. | | | | | | | | Markets and exports | 9 | | | | | | | 4.1 | | | | | | | | Geographical markets | 9 | | | | | | | 4.2 | | | | | | | | Largest market in terms of turnover | 10 | | | | | | | 4.3 | | | | | | | | Exports | 10 | | | | | | | Context for innovation | | 11 | | | | | | 5. | | | | | | | | Co-operation arrangements | 11 | | | | | | | 6. | | | | | | | | Sources of information | 12 | | | | | | | 6.1 | | | | | | | | Public sector procurement and innovation | 13 | | | | | | | 7. | | | | | | | | Innovation in sectors | 13 | | | | | | | 8. | | | | | | | | Geography of innovation | | 14 | | | | | | 8.1 | | | | | | | | Country level differences | 14 | | | | | | | 8.2 | | | | | | | | Regional level differences | | 15 | | | | | | 9. | | | | | | | | Factors driving innovation 16 | | | | | | | | 10. | | | | | | | | Non-innovators | | 17 | | | | | | 11. | | | | | | | | Effectiveness of methods used to protect the value of innovations 18 | | | | | | | | 12. | | | | | | | | Skills for innovation | 19 | | | | | | | 13. | | | | | | | | Comparisons with the 2011, 2009 and 2007 UK Innovation Survey Panel data 21 | | | | | | | | 14. | | | | | | | | Comparisons with the 2007, 2009 and 2011 UK Innovation Surveys' cross-section | | | | data | | 22 | | | | | ## First Findings From The Uk Innovation Survey 2013 Hülya Hooker and James Achur, Department for Business, Innovation and Skills (BIS) Address: Orchard 2, 1 Victoria Street, London SW1H 0ET Email: hulya.hooker@bis.gsi.gov.uk ## Summary This report presents the initial analysis of the 2013 UK Innovation Survey (UKIS 2013), which is the second survey using a sample based on the Standard Industrial Classification 2007 (SIC 2007). This enables a more consistent comparison with the 2011 survey data in the time series. The survey is mainly postal but almost two fifths (39 per cent) of total responses (14,487) were collected by telephone interview. This compares favourably with the UKIS 2011 in which around half of the survey responses were collected by telephone interview. As it might be expected, most of the telephone interviews came from noninnovative enterprises. Following an overview of the data collection and methodology, this report goes on to discuss the key innovation statistics. After examining in which markets and regions innovative UK businesses are operating, the report then discusses collaborations and sources of information, factors driving innovation and barriers to innovation. This report also includes highlights from analysis of the panel data (overlap) between the 2011 survey and its predecessors from 2009 and 2007. It concludes with a comparison of this survey with the last three surveys from 2011, 2009 and 2007. This First Findings report will be followed by a Statistical Annex for UKIS 2013 which will contain detailed tables and will be published later in the year. ## Introduction This report presents the first findings from the UK Innovation Survey 2013, covering the three-year period from 2010 to 2012. It is the UK contribution to a Europe-wide Community Innovation Survey (CIS). This is the eighth Europe-wide CIS. CIS was originally conducted every four years, but since 2005 it has been conducted every two years. The 2013 survey is the fourth one on the biennial cycle. The UK Innovation Survey 2013 sampled 28,365 UK enterprises with ten or more employees. The survey was voluntary, and was conducted through both a postal questionnaire and telephone interview for businesses that had not yet completed a postal response. With over 14,000 enterprises in the achieved sample, the survey had a 51 per cent response rate. The results in this report are based on weighted data in order to be representative of firms. The responses were weighted back to the total business population of those in the Inter-Departmental Business Registration (IDBR). They were not weighted by factors which would give more weight to larger firms, such as employment or turnover. As in the 2011 survey, the 2013 survey also used a sampling format based on SIC 2007 which is an EU legislative requirement regarding the collection of innovation statistics. Similarly, the sample selection was conducted by ONS and it followed the same sampling methodology as the 2011 survey. As a result, the data in this survey are much more comparable to the data from the 2011 survey. The Department for Business, Innovation, and Skills (BIS) would like to thank all the businesses that completed the survey form either over the phone or by post. The UKIS continues to provide a means to measuring the level, types and trends in innovation activity within the UK. This data source contributes to our understanding of the constraining factors faced by businesses, across all sectors and size classifications, to innovate and other limitations in the system. It provides the empirical evidence to support policy measures. Although the sample size of the panel data (respondents also common to the 2011, 2009 and 2007 surveys) is significantly reduced to just over 1,250 businesses, the panel element in the survey series remains a valuable resource for both government and academic users alike. However, one needs to bear in mind that the changes in the sampling and collection methodology from the 2011 survey onwards would mean any comparisons made with the 2009 and 2007 provide a broad indication of changes over the mentioned time period only. In December 2011, the Department published its 'Innovation and Research Strategy for Growth1'. The 2014 Innovation Report2 was published in March 2014. The Autumn Statement 2013 emphasised government's commitment to ensure that the UK's capabilities remain world-leading while playing a key role in economic growth and scientific excellence. The Government will produce a 'Science and Innovation Strategy' for Autumn Statement 2014. Central to this strategy will be a roadmap of how the government's longterm commitment on science capital will deliver the research and innovation infrastructure. Through the harmonised questions in CIS, the UK Innovation survey data are also comparable with other countries. This provides useful international benchmarking for the UK performance in this area. The majority of the survey questions are concerned with innovation through new and improved products and processes (technological innovation) and with the investments that develop and implement them along with changes in business structures, management and marketing practices (non-technological innovation). The survey also asks businesses about the drivers to innovate as well as their perception of barriers to innovation. The questionnaire used for the survey remained mostly the same as in the 2011 survey. There was a new question added about what the 'largest market' was for businesses in terms of turnover. There was also an additional question concerning the most valuable cooperation partner for businesses. The composition of the 2013 achieved sample was similar to the last survey, with 22 per cent of sample consisting of large firms, compared to 21 per cent in the last survey. Whilst 50 per cent of the achieved sample were from businesses with 10 to 49 employees, 28 per cent came from enterprises with 50 to 249 employees. The 2013 survey is the second one conducted using a sample based on the Standard Industrial Classification 2007 (SIC 2007). The consistencies in sampling and survey methodologies, such as the use of SIC 2007 and telephone interviews to boost the postal responses between the two surveys provide us with the ability to make more direct comparisons across surveys. ## 1. Innovation Activity Innovation takes place through a wide variety of business practices and a range of indicators can be used to measure its level within the enterprise or in the economy as a whole. These include the levels of effort employed (measured through resources allocated to innovation) and of achievement (the introduction of new or improved products and processes). This section reports on the types and levels of innovation activity over the three year period, from 2010 to 20123 and makes some comparisons with the results obtained from the previous survey conducted in 2011. The definition of innovation activity4 here includes any of the activities described below that enterprises were engaged in during the survey period. These activities are as follows: 1. Introduction of a new or significantly improved product (good or service) or process; 2. Engagement in innovation projects not yet complete or abandoned; 3 All results are grossed up to the business population, and all figures quoted relate to UK Innovation Survey 3. New and significantly improved forms of organisation, business structures or practices and marketing concepts or strategies 4. Activities in areas such as internal research and development, training, acquisition of external knowledge or machinery and equipment linked to innovation activities5. 2010-2012* | | Per cent | |-------------------------------------------------|--------------------| | Type of activity | Size of enterprise | | 10-250 | 250+ | | employees | employees | | | | | 2013 | | | Innovation active | 45 | | Innovation active (old definition) | | | 6 | | | | | | 42 | 48 | | Broader innovator | 46 | | Wider innovator | 37 | | Activities | 39 | | Product innovator | | | 18 | 23 | | of which (share with new-to-market products) | | | 44 | 50 | | Process innovator | | | 10 | 15 | | of which (share with new-to-industry processes) | | | 23 | 26 | | Abandoned activities | | | 4 | 5 | | On-going activities | | | 15 | 19 | | Both product AND process innovator | | | 7 | 10 | | Either product OR process innovator | | | 21 | 28 | | 2011 | | | Innovation active | 37 | | Innovation active (old definition) | 36 | | Broader innovator | 39 | | Wider innovator | 31 | | Activities | 33 | | Product innovator | | | 19 | 23 | | of which (share with new-to-market products) | | | 46 | 50 | | Process innovator | | | 10 | 17 | | of which (share with new-to-industry processes) | | | 27 | 24 | | Abandoned activities | | | 4 | 6 | | On-going activities | | | 7 | 9 | | Both product AND process innovator | | | 7 | 13 | | Either product OR process innovator | | | 22 | 28 | | * = Unweighted base = 14,487 | | | | | 5 As in the 2011 UKIS, the questions in Section C 'Context for Innovation' of the questionnaire are only asked if the respondent said yes to Q3, 4, 6, 10 or 13 (i.e. strategic innovator, innovation activities, product innovator, process innovator or abandoned/incomplete innovation) in Section B 'Innovation Activities' of the questionnaire. This differs from survey routing used in surveys conducted before the UKIS 2011. For the purpose of the UK Innovation Survey and in line with the European-wide Community Innovation Survey, a business that had engaged in any of the activities described in points 1 to 3 given above is defined as being '**innovation active'**. For the purpose of this report, a business that has engaged in any of the activities described in points 1 to 4 given above is defined as a **broader innovator**. The businesses classed as a **wider innovator** are those that have engaged in the activity described in point 3 given above. The results, given in Table 1 show notable improvements on most of the innovation activities that businesses had engaged in throughout the reference period of 2010 and 2012. It is inevitable that economic conditions have an impact on the way businesses behave. In the last survey, the economic conditions were much more unfavourable and this had been reflected in the findings of the 2011 survey which had the reference period of 2008 and 2010. As Table 1 shows, the number of 'innovation active' (defined above) firms increased over the survey period; 45 per cent of enterprises were found to be 'innovation active', compared to 37 per cent of businesses in the 2011 survey. The share of large firms (those with more than 250 employees) classified as 'innovation active' was higher than small and medium enterprises (SMEs): 50 per cent vs 45 per cent of SMEs. The same difference also existed between large firms and SMEs in the 2011 survey. In line with the increase in the proportion of innovation active businesses, the number of firms defined as 'broader innovator' also increased to 46 per cent from 39 per cent in the 2011 survey. Interestingly, the share of SMEs in this category was higher than that of the large firms: 46 per cent of SMEs vs 41 per cent of large firms. There was a decline in the share of large firms from 44 per cent in the 2011 survey. There was also an increase on the wider innovator indicator (firms engaging in wider/nontechnical innovations, described in point 3 above) from 31 per cent in the 2011 survey to 37 per cent given above in Table 1. The difference in proportions of SMEs and large business was smaller in this survey period than the previous one; 37 per cent of SMEs reported in engaging in wider innovations, compared to 39 per cent of large firms. This compares to 31 per cent of SMEs and 35 per cent of large businesses in the 2011 survey. Product innovation remained broadly unchanged, with 18 per cent of firms reporting engagement in product innovations (compared with 19 per cent in the 2011 survey). Almost half of product innovations (44 per cent) were new to the market over this survey period, as compared to 46 per cent in the previous survey. The share of large firms having products new to the market stayed exactly the same at 50 per cent. However, this share was higher than that of SMEs in both this and the 2011 surveys (44 per cent and 46 per cent, respectively). Furthermore, process innovation remained exactly the same. One in ten firms reported engaging in process innovations. Whilst the share of SMEs reporting engagement in process innovations stayed the same over two survey periods, the share of large firms showed a slight fall from 17 per cent in the 2011 survey to 15 per cent. Almost a quarter (23 per cent) of process innovations were new to the industry processes, showing a decline from 26 per cent in the previous survey. Whilst there was a notable fall for SMEs from 27 per cent in the previous survey to 23 per cent, large firms reported a slight increase (24 per cent to 26 per cent) for having process innovations new to the industry. In most businesses7, both goods and services were mainly developed within the business. When asked whether the goods or services were developed mainly by their own business or enterprise group, 41 per cent of respondents said their 'goods' were developed mainly by their own business (50 per cent said their 'services' were developed mainly within the business). These figures were broadly in line with the previous survey's findings in which 43 per cent said 'goods' and 49 per cent said 'service innovations' were developed within their business. When asked about developing goods or services in partnership with other businesses/organisations, 17 per cent said their goods were developed mainly in partnership with other businesses. The corresponding figure for services was 14 per cent. One in ten businesses said their goods were developed mainly by other businesses or organisations. The corresponding figure for services was also ten per cent. These figures were broadly in line with those reported in the 2011 survey. Although the findings showed a similar proportion of abandoned innovation projects to the last period (four per cent in both surveys), the proportion of on-going innovation activities went up significantly from seven per cent to 15 per cent. The share of larger firms was significantly higher with 19 per cent, compared to nine per cent in the 2011 survey. A discussion of the details of the innovation indicators follows below. ## 2. Breakdown Of Innovation Activities As well as having a similar sampling methodology, both the 2011 and 2013 surveys incorporated a mixed mode of questionnaire completion (mainly postal but boosted with telephone interviews). This would mean one can expect a more consistent comparison over the two survey periods. As shown in Figure 1, the most commonly reported activities were acquisition of computer software and hardware (23 per cent and 20 per cent, respectively) and these proportions went up from 19 per cent of computer software and 16 per cent of hardware in the last survey. The proportions in other categories reported in Figure 1 remained broadly unchanged, except for a slight increase in the category of 'training for innovative activities' which went up from 12 per cent in the 2011 survey to 14 per cent. The amounts provided for each of the main innovation-related activities given in Figure 2 had been rather volatile in the survey series. Measures were taken in the 2013 survey to address this issue and to ensure that fluctuations were not due to wording of these questions. The key issue was although the survey questions about businesses' innovation activities referred to a three-year period (1 January 2010 to 31 December 2012), the estimates required for the amount of expenditure were for the year 2012 only. In this survey, the reference year for estimates was marked clearly and the instruction provided emphasised that estimates were asked for '2012 only' in capital letters. The wording of the questions in previous surveys did not make the point about the reference period equally clear. The results of this survey showed that the overall innovation expenditure provided for the year 2012 was significantly lower than the amount reported in the last survey. It is highly likely that tightening of the instructions for the expenditure question had an impact on amounts provided. This could in fact explain the notable reduction in the estimates for total expenditure. However, the ranking of the top three highest expenditure categories, given in Figure 2, remained unchanged. The largest share of innovation expenditure belonged to 'internal R&D' (40 per cent, compared to 35 per cent in the 2011 survey), followed by 'acquisition of capital' (i.e., advanced machinery, equipment and software with 25 per cent, compared to 30 per cent in the previous survey) and acquisition of external R&D (with 14 per cent, compared to 24 per cent in the 2011 survey). The category for the 'market introduction of innovations' went up from four per cent in the 2011 survey to ten per cent. There was also an increase in spending for the acquisition of external knowledge category, which went up from only one per cent in 2011 survey to four per cent. In all, the findings indicate that the total expenditure for 'internal R&D' amounted to around £11.2 billion. This was broadly in line with the most recent Business Enterprise Research and Development Expenditure (BERD) statistics 2012, which reported that businesses' own funds for R&D performed in the UK accounted for £11.3 billion8. ## 3. Non-Technological Or Wider Forms Of Innovation Innovation is not just about the development or use of technology or other forms of product (goods and services) and process change. There are also non-technological forms of innovation, such as new business practices for organising procedures or changes to marketing concepts and strategies. An organisational innovation is a new organisational method within an enterprise's business practices (including knowledge management), workplace organisation or external relations that has not been previously used. Enterprises were asked whether they had made any major changes to their business structure and practices in the three-year period from 2010 to 2012. The organisational innovation questions were revised to match the version found in the CIS harmonised questionnaire. Some of the findings are summarised in Table 2. Over a third (37 per cent) of businesses engaged in one or more types of nontechnological innovation over the latest survey period. Over a fifth (21 per cent) mentioned the implementation of *new business practices* for organising procedures, compared to 16 per cent of businesses in the 2011 survey. As in the 2011 survey, a higher share of large firms (26 per cent) reported this, compared to SMEs (21 per cent). The least frequently reported wider innovation was the implementation of new methods of organising external relationships, which was mentioned by only eight per cent of businesses over both survey periods, with SMEs having a lower share than large firms (eight per cent, compared to ten per cent of larger firms). Per cent Forms of innovation Size of enterprise 10-250 250+ employees employees All (10+ employees) Wider Innovator 37 39 37 New business practices 21 26 21 New method of organising work responsibilities 17 21 18 New method of organising external relationships 8 10 8 Changes to marketing concepts or strategies 16 16 16 * = Unweighted base = 14,487 The proportions of businesses that reported the implementation of new methods of organising work responsibilities and *changes to marketing concepts or strategies* remained the same with 18 and 16 per cent, respectively. There was no difference in the take up of changes to marketing concepts or strategies between SMEs and large firms. ## 4. Markets And Exports 4.1 Geographical Markets The businesses surveyed were asked which geographical markets they had operated in. As Figure 3 shows, the regional markets were still the most dominant market for UK enterprises; 68 per cent of firms reported operating in regional markets, compared to 67 per cent in the 2011 survey. Almost six in ten (57 per cent) operated at national level, showing an increase from 52 per cent in the last survey. However, the proportions of businesses operating in European countries and all other countries showed a decline, with 23 per cent reporting to operate in European markets (compared to 26 per cent in the last survey period), whilst 16 per cent were operating in world-wide markets (compared to 19 per cent in the previous survey). ## 4.2 Largest Market In Terms Of Turnover A new question was added which asked businesses what their 'largest market' was in terms of turnover. In all, 90 per cent answered the question about the geographical markets. Of these valid responses, only 64 per cent went on to provide estimates. Over half (57 per cent) reported that their largest markets were 'UK regional' (within approximately 100 miles of their business). Over a third (35 per cent) mentioned 'UK national'. European countries and overseas were cited by only three and five per cent, respectively. ## 4.3 Exports Only 16 per cent of businesses provided an estimate of exports for the year 2012. This compares to 19 per cent in the 2011 survey. Looking back at the survey series, proportions reporting estimates of exports have been steadily decreasing: 30 per cent of respondents gave an estimate in the 2005 survey. However, the trends indicate that the majority of exporters engaged in some form of innovation behaviour. ## Context For Innovation The survey asked questions about various aspects of the context relevant to business innovation behaviour. The following sections include statistics that refer to any businesses that had engaged in any of the four types of innovation behaviour described previously9. ## 5. Co-Operation Arrangements Over 40 per cent of all broader innovating enterprises (41 per cent, compared to 47 per cent in the last survey) reported having co-operation arrangements on some innovation activities. Over two thirds of the collaborations (67 per cent) were reported to be agreements operating at a national level. This proportion remained broadly the same which was 68 per cent in the last survey. As shown in Figure 4, the most frequently mentioned partners of businesses with cooperation agreements were clients or customers from the *private sector* (61 per cent). There was also a sizable proportion (31 per cent) of businesses that cited clients or customers from the *public sector*. The 2011 survey also reported that the most frequently mentioned partners for co-operation were 'clients or customers' (73 per cent). However, this category included *both* private and public sectors clients/customers and therefore cannot be directly comparable in terms of change over time for this particular response category. However, other response categories presented in Figure 4 showed similar proportions for the co-operation partners over the two survey periods. A new question was added that asked businesses which type of co-operation partner they had found most valuable for their business innovation activities. Almost two thirds (63 per cent) did not provide a valid response for this question. Clients or customers from the private sector were seen as the most valuable partners for co-operation, which accounted for 11 per cent of broader innovators with co-operation arrangements (two per cent mentioned clients or customers from public sector). One in ten cited suppliers of equipment, materials, services or software, whilst eight per cent reported other businesses within their enterprise group as the most valuable co-operation partner. ## 6. Sources Of Information Table 3 provides the details of the extent to which businesses use external resources in their innovation activities. It is important to know how far enterprises engage with external sources and the relative importance of technology and other innovation-related knowledge and information. Innovation is increasingly complex, requiring the co-ordination of multiple inputs. Firms can gain guidance, advice or even inspiration for their prospective innovation projects from a variety of both public and private sources. Businesses were asked to rank information sources on a scale from "no relationship" to "high importance". The sources presented were: - **internal**: from within the enterprise itself or other enterprises within the enterprise group; - **market**: from suppliers, customers, clients, consultants, competitors, commercial laboratories or research and development enterprises; - **institutional**: from the public sector such as government research organisations and universities or private research institutes; and - **other sources**: from conferences, trade fairs and exhibitions; scientific journals, trade/technical publications; professional and industry associations; technical industry or service standards The findings from businesses' rating of these sources are given in Table 3. The ranking of information sources has been fairly consistent throughout the history of the survey. Overall, market sources such as clients and customers and internal sources (within their enterprise group) were rated as the most important source of information for innovation. Again, the least frequently cited sources were institutional sources. The most notable decrease in firms' rating for sources of information was in the category of 'scientific journals and trade/technical publications', which was down from eight per cent to three per cent. The proportion was the same among large and small firms. The 2011 survey showed that this source was much more popular among large firms (15 per cent, compared to eight per cent of SMEs). | | | |--------------------------------------------------------|-----------| | Per cent | | | | | | | | | Size of enterprise | | | 10-250 | 250+ | | employees | employees | | | | | All (10+ employees) | | | | | | Information sources | | | Internal | | | | | | Within your enterprise group | 50 | | Market | | | | | | Suppliers of equipment | 20 | | Clients or customers from private sector | 24 | | Clients or customers from public sector | 11 | | Competitors or other enterprises in your industry | 11 | | Consultants, commercial labs or private R&D institutes | 8 | | Institutional | | | | | | Universities or other higher education institutes | 2 | | Government or public research institutes | 2 | | Other sources | | | | | | Technical, industry or service standards | 9 | | Conferences, trade fairs, exhibitions | 6 | | Scientific journals and trade/technical publications | 3 | | Professional and industry associations | 6 | | * = Unweighted base = 6,992 | | ## 6.1 Public Sector Procurement And Innovation A new question was added which asked firms whether they had any procurement contracts to provide goods or services for 'domestic public sector organisations' or 'overseas/non-domestic public sector organisations'. Around 15 per cent of respondents reported having procurement contracts to provide good or services for domestic public sector organisations. This compared to four per cent having similar contracts to supply overseas/non-domestic public sector organisations. ## 7. Innovation In Sectors The numbers of the 'innovation active' businesses across all industrial and commercial sectors are charted in Figure 5. As pointed out before, a more direct comparison with the 2011 survey results is possible because of having the same sectoral reclassification and a more consistent methodology between the two surveys. As can be seen in Figure 5, the production sector, particularly manufacturing industry was the most innovation active: 62 per cent of 'manufacture of electrical and optical equipment' were innovation active. This was broadly the same in the 2011 survey. Electricity, gas and water supply was the only industry within the production sector that showed a decline since the last survey. All other industries showed significant increases. The construction sector also showed an increase, going up from 31 per cent in the 2011 survey to 42 per cent. The industries within the distribution and services sectors also showed significant increases. The top three industries with the highest shares were: real estate, renting and business activities (48 per cent), wholesale trade (46 per cent) and financial intermediation (45 per cent). These three industries also had the highest shares in the 2011 survey. ## 8. Geography Of Innovation 8.1 Country Level Differences Figure 6 presents the shares of innovation active businesses across the countries and shows a comparison with the 2011 data based on the innovation active definition. There were seven percentage points between the least and most 'innovation active' country, with Wales having the highest share (47 per cent) and Northern Ireland lowest (40 per cent). The same pattern was also found in the 2011 data in terms of highest and lowest shares. However, the shares for all four countries were notably higher in this survey. ## 8.2 Regional Level Differences There were eight percentage points between the least and most 'innovation active' region. Although the East Midlands region had the highest proportion with almost 50 per cent, this was closely followed by South East (48 per cent), Eastern (47 per cent), North East (47 per cent) and South West (47 per cent). The North West and London regions had 42 per cent which were the lowest shares. However, the share of all regions went up notably since the 2011 survey with increases of five to ten percentage points between this survey and the last one. ## 9. Factors Driving Innovation Businesses defined as 'broader innovators' were asked to rank a variety of drivers for innovating on a scale from no impact to low, medium or high impact. Table 4 gives the proportion of businesses that had rated 'high' in each of the innovation factors presented to them. Quality enhancement was again the most motivating factor, rated high by over a third (36 per cent) of businesses described as broader innovator. There was a significant increase in the numbers citing 'replacing outdated products or processes' which was the second most frequently mentioned factor driving innovation (rated 'high' by 31 per cent). This factor was reported 'high' by 17 per cent in the 2011 survey. As in the previous survey, there was a notable difference between the factors motivating large firms and SMEs. For example, 'reducing costs per unit produced or provided' was higher in the agenda for SMEs whilst 'entering new markets' seemed to be higher for large enterprises. In both 2011 and 2013, 'reducing environmental impact' and 'improving health and safety' were the least highly rated innovation factor overall. Yet these were still rated 'high' by a fifth (19 per cent) of large businesses. | | Per cent | |-------------------------------------------------------|----------------| | | | | | | | Size of enterprise | | | | | | | | | | | | 10-250 employees | 250+ employees | | Innovation factors | | | | | | Improving quality of goods or services | 35 | | Replacing outdated products or processes | 31 | | Increasing market share | 28 | | Increase range of goods or services | 28 | | Increasing value added | 21 | | Entering new markets | 21 | | Meeting regulatory requirements (including standards) | 20 | | Reducing costs per unit produced or provided | 18 | | Improving capacity for producing goods or services | 16 | | Improving flexibility for producing goods or services | 16 | | Improving health and safety | 13 | | Reducing environmental impact | 10 | | * = Unweighted base = 6,992 | | ## 10. Non-Innovators Businesses that reported having no innovation activity during the survey period were asked to indicate why it had not been necessary or possible to innovate. They were offered the response categories presented in Figure 810, alongside a response category saying 'none of those apply'. Over two thirds (68 per cent) said none applied in their case. Over a tenth (11 per cent) said 'no need due to market conditions' which was the most frequently cited reason. Around five per cent mentioned 'no need due to previous innovations' and a few (three per cent) cited 'factors constraining innovation'. As well as having much lower proportions citing these reasons as compared to the last survey, the pattern of response also differed from the 2011 survey. The most frequently cited reason in the 2011 data was 'factors constraining innovation' (31 per cent) which represented the least frequently reason in this survey. included in the 2013 survey and therefore, it is not possible to explore further what factors would be rated high as barriers to innovation. ## 11. Effectiveness Of Methods Used To Protect The Value Of Innovations Successful innovations often generate intellectual property that businesses will try to protect. This can be done in numerous ways depending upon the knowledge generated and the business and market context. In this survey, the question for this aspect was about asking businesses how effective they had found each of the methods given in Table 5 for maintaining or increasing the competitiveness of product or process innovations introduced during 2010 to 2012. As it can be seen in Table 5, the proportions reported were low. However, earlier surveys showed that all these methods had been made little use of in practice, which would indicate that these low proportions were to be expected. The two most effective methods to maintain competitiveness were keeping goods or services as complex as possible (six per cent) and having a lead time advantage (five per cent). There was a size effect of businesses for keeping products complex. Higher proportion of large firms rated 'complexity of goods or services' (eight per cent), compared to six per cent of SMEs. Similarly, compared to SMEs, higher number of large firms also gave more weight to trademarks and patents. ## Innovation As 'High'* Per cent Size of enterprise 10-250 employees 250+ employees All (10+ employees) Methods for competitiveness Patents 2 4 2 Design registration 1 3 1 Copyright 2 3 2 Trademarks 2 5 3 Lead time advantages 5 6 5 Complexity of goods or services 6 8 6 Secrecy (include non-disclosure agreements) 3 5 3 * = Unweighted base = 14,487 ## 12. Skills For Innovation The skills question, apart from the standard question on the proportion of employees holding a degree or above, was first asked in 2011 survey. This was the second time it was included. It asks businesses about whether they had employed or brought in certain skills over the survey period. Per cent Size of enterprise 10-250 employees 250+ employees All (10+ employees) All Science or engineering subjects 10 9 10 Other subjects 13 13 13 Broader innovators Science or engineering subjects 12 10 12 Other subjects 14 13 14 Non- innovators Science or engineering subjects 4 7 4 Other subjects 11 13 11 * = Unweighted base = 14,487 Table 6 presents the results from the standard question and gives the average proportion of employees who hold a degree or higher. Comparisons with the 2011 results showed that the average proportions increased for both 'science or engineering' subjects (went up from seven per cent in the previous survey to 10 per cent) and other subjects (went up from nine per cent in 2011 to 13 per cent). For broader innovators, the increases were across the board. However, for non-innovators, the increases were much higher for 'other' subjects than for 'science or engineering'. The results from the questions that were recently added are in Tables 7 and 8. Table 7 sets out the results for a range of skills asked about in the survey. These skills can relate either to employees or skills brought in. As can be seen, large firms were more likely to use each of the listed skills than SMEs. ## Sources With Listed Skills By Firm Size* | | | |----------------------------------------------------|----------------| | Per cent | | | | | | | | | Size of enterprise | | | | | | 10-250 | 250+ employees | | | | | Listed skills for employees in-house or brought in | | | | | | Graphic artists/ layout/ advertising | 27 | | Design of objects or services | 18 | | Multimedia/ web design | 27 | | Software development/ database management | 23 | | Engineering/ applied sciences | 14 | | Mathematics/ statistics | 9 | | * = Unweighted base = 14,487 | | Table 8 compares 2011 and 2013 surveys for all respondents. It also presents the differences between the shares of broader innovators and non-innovators for employing the same listed skills as in Table 7. Again, these could be either in-house or brought in from external sources. As can be seen in Table 8, there were notable increases in employment of all six of the listed skills. The increase was highest for the 'graphic artists/advertising' category which went up from 15 per cent in the 2011 survey to 27 per cent. The skills category of 'mathematics/statistics' showed an increase of five percentage points, up from five to ten per cent. Non-innovators increased their shares in all six skills categories whilst the shares for broader innovators remained broadly the same | | | |-------------------------------------------|--------------| | Per cent | | | Broader | Non- | | | | | | | | All* | | | | innovators** | | | | | | | | 2011 | 2013 | | Graphic artists/ layout/ advertising | 15 | | Design of objects or services | 9 | | Multimedia/ web design | 17 | | Software development/ database management | 14 | | Engineering/ applied sciences | 8 | | Mathematics/ statistics | 5 | * = Unweighted base for All is 14,487 for 2013; 14,342 for 2011. **= Unweighted base for broader innovators is 6,992 in 2013; 5,744 in 2011; + = Unweighted base for non-innovators is 7,495 in 201; 8,598 in 2011. ## 13. Comparisons With The 2011, 2009 And 2007 Ukis Panel Data The availability of panel data (businesses responding to the 2013, 2011, 2009 and 2007 surveys) enables some comparison of businesses' innovation activities over time. Of the 1,275 businesses in the four survey panel, around two thirds (66 per cent) were large enterprises. Of the remaining 34 per cent, most of them were businesses with 50 to 249 employees (31 per cent), with only three per cent coming from firms with 10 to 49 employees. Figure 9 presents the innovative characteristics of the panel data. A comparison with Table 1 shows that the 2013 panel data results differ from the general survey results. As compared to businesses in the general survey, the firms in the panel data were notably more innovative across all innovation indicators. The same was also true for the comparison of the 2011 panel data results with the 2011 general survey data. ## 14. Comparisons With The 2007, 2009 And 2011 Ukis Crosssection Data As in the 2011 survey, the 2013 survey used a sampling format based on SIC 2007, which is an EU legislative requirement regarding the collection of innovation statistics. Similarly, the sample selection was conducted by ONS and it followed the same sampling methodology as the 2011 survey. Furthermore, the definition used for 'innovation active' was the same across the last two surveys. As a result, one would expect to see that the data in this survey are much more comparable to the data in the 2011 survey. Figure 10 presents a general comparison of the results for the key innovation indicators for the four surveys, this time using the cross-section data. The chart shows similar trends for the 2011 and 2013 data, with the notable increases on the shares of innovation active and broader innovators. ## 15. Conclusions And Next Steps This first findings report presents some top-line results of the latest Innovation Survey and provides information on some dimensions of the changes in innovation behaviour in the UK relative to the 2011 survey. The report also provides some comparisons with earlier surveys making use of both panel and cross-section data. The UK Innovation Survey represents a major source of data for the research community. The data feeds into the economic analyses and other policy related work. It provides both a periodic snapshot of innovation behaviour and has the additional benefit of the panel dataset which facilitates longitudinal studies and evaluations of innovation policy. The data is also comparable with other countries, which provides useful international benchmarking for the UK performance in this area. The Department for Innovation Business and Skills will publish more extensive, detailed survey results in the form of a Statistical Annex of the UKIS 2013 data later in the year. As with previous surveys, it is expected that there would be a substantial body of further research using the survey results and publications in various forms over the next few years. Data will be available for researchers in the Virtual Micro-Data Laboratory (VML) and from the Secure Data Service (SDS).11 ## Annex - Methodology The UK Innovation Survey is funded by the Department of Business, Innovation and Skills (BIS). The survey was conducted on behalf of the BIS by the Office for National Statistics (ONS). The UK Innovation Survey is part of a wider Community Innovation Survey (CIS) covering EU countries. The survey is based on a core questionnaire developed by the European Commission (Eurostat) and Member States. This is the eight iteration of the survey (CIS8). CIS7, covering the period 2008 to 2010, was carried out in 2011 and the results form part of various EU benchmarking exercises for international comparisons. The UK Innovation Survey 2013 sampled over 28 thousand UK enterprises. The survey was voluntary and conducted by means of both a postal questionnaire and telephone interview for businesses that had not yet completed a postal response. ## Coverage And Sampling The survey covered enterprises with 10 or more employees in sections C-K of the Standard Industrial Classification (SIC) 2007. This was the second time survey data was collected using a sample based on the Standard Industrial Classification 2007 (SIC 2007). The sample was drawn from the ONS Inter-Departmental Business Register (IDBR) in January 2013. ## Response And Weighting The questionnaires for the survey were dispatched between 25 and 27 February 2013. Valid responses were received from 14, 487 enterprises which gives a response rate of 51 per cent. The results in this report are based on weighted data in order to be representative of the population of firms. The responses were weighted back to the total business population of those in the IDBR. On average each respondent represents 12 enterprises in the population. © Crown copyright 2014 You may re-use this information (not including logos) free of charge in any format or medium, under the terms of the Open Government Licence. Visit www.nationalarchives.gov.uk/doc/open-government-licence, write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk. This publication available from www.gov.uk/bis Any enquiries regarding this publication should be sent to: Department for Business, Innovation and Skills 1 Victoria Street London SW1H 0ET Tel: 020 7215 5000 If you require this publication in an alternative format, email enquiries@bis.gsi.gov.uk, or call 020 7215 5000.
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## Heritage & Design Statement Blackbrook House Blackbrook Lane Chapel-en-le-Frith Derbyshire SK23 0PU On behalf of: Mr T Ross May 2019 ## Contents 1. INTRODUCTION **....................................................................................................... 3** 2. SITE EVALUATION **.................................................................................................... 4** 3. HERITAGE ASSET DESIGNATIONS **.......................................................................... 8** 4. PROPOSED WORKS **................................................................................................. 8** 5. VALUES **................................................................................................................... 10** 6. SUMMARY AND CONCLUSION **........................................................................... 11** 7. REFERENCES **........................................................................................................... 12** 8. APPENDICES **.......................................................................................................... 13** ## 1. Introduction 1.1. This Heritage and Design Statement has been prepared by Magnus Technical Engineering on behalf of Mr Tom Ross in support of their pre-application for an extension to Blackbrook House, Blackbrook Lane, Chapel-en-le-Frith, Derbyshire, SK23 0PU. 1.2. Planning permission for the extension is sought to enable the applicants to increase their living accommodation. 1.3. The property has been designated as a non-heritage asset by Peak District National Park Authority. 1.4. The aim of this statement is to assess any potential impact of the proposed extension to Blackbrook House on the heritage value and significance of the property. 1.5. This statement has been set out in accordance with the general guidelines set out in the Historic England publications. 1.6. It is understood that this assessment will supplement the current pre-application and the proposed plans and drawings should be read in conjunction with this statement. ## 2. Site Evaluation 2.1. **The History Of Blackbrook Hamlet** 2.1.1. Blackbrook is presently a hamlet of eight households, nestled within the steep sided valley of Blackbrook. It is situated one mile to the East of Chapel-en-le-Frith in the High Peak and is located predominantly within the Peak District National Park on the Western fringe of the Dark Peak. The Peak District National Park boundary runs along Blackbrook Lane. 2.1.2. Originally the old route to Buxton, was via what is now Blackbrook Lane, which passed through the hamlet. The A6 Buxton Road was then used, which is situated further to the West. This was replaced by the existing bypass in 1987. The brook was re-routed and Blackbrook Lane has now become a single lane cul-de-sac, with little traffic. 2.1.3. A substantial semi-mature woodland now forms part of the A6 embankment landscape, which rises steeply to the west of the hamlet and provides some screening to Blackbrook, thereby returning the hamlet to its former state of privacy. 2.1.4. The origins of Blackbrook are not recorded, but the plentiful water supply and a sheltered position suggest human settlement from mediaeval times. Families living in Blackbrook would historically be connected to small scale farming. 2.1.5. Some of the buildings date back to the Tudor period and have since been modified, rebuilt or extended. 2.1.6. Today, seven households, together with holiday cottages, form a diverse community, which includes a working farm and a plant nursery. 2.1.7. A series of historical maps and photographs of Blackbrook and Blackbrook House are included at the end of this statement. See appendix 1. 2.1.8. No buildings in the hamlet are listed. However, Blackbrook House, Blackbrook Farm, Rookery Farm, Brookside, Blackbrook Cottage and High Peak House and the associated out buildings are noted for architectural significance. Blackbrook is not within a conservation area. ## 2.2. Blackbrook House: **The Setting And Heritage Value** 2.2.1. Blackbrook House lies on the north edge of the hamlet of Blackbrook and though associated with hamlet, is to a large degree visually and physically separated from the settlement by a wooded valley which contains a tributary of Blackbrook. The property sits at a lower level than the main settlement which tends to reinforce the sense of separation. The property comprises two buildings, Blackbrook House and The Coachhouse, a former barn. The buildings and garden of the property occupy a sheltered position in a valley bottom, of approximately one acre. The front of the house faces West to Blackbrook Lane which is the only vehicular approach to the house. The front elevation is framed by a statuesque Copper Beech tree and the setting of the property is primarily enclosed and private. 2.2.2. Blackbrook House is not a Listed Building, however it is recorded as a Peak District NPA Monument: as an extant 19th century farmstead. See Appendix 2. The buildings have been previously identified as a non-designated heritage asset, and therefore are of significant local interest. They clearly contribute to the historic character of the landscape and the main façade of the house is an important element in the approach to the hamlet along Blackbrook Lane. 2.2.3. The Western boundary of the property follows the boundary of the Peak District National Park, along a retaining wall bordering Blackbrook Lane. The Northern and Eastern boundaries are adjacent to neighbouring fields, which are used for livestock grazing. The Southern boundary is adjacent to woodland, a tributary to Blackbrook and Rockery House Farm. 2.2.4. Blackbrook House has developed organically over the years as a result of a series of additions and developments to what appear to have been two agricultural cottages and an outbuilding. This has resulted in an unusually close spatial relationship between the Coach House and the main house. The south elevation of the house is largely enclosed by the featureless rear façade of the Coach house. 2.2.5. Blackbrook House dates from the Seventeenth Century. It was likely to have been a yeoman farmers dwelling until the late Eighteenth Century, when the building was substantially extended to the west, resulting in a more imposing and formal front elevation in the 'Derbyshire Georgian Style'. As a result, the rear of Blackbrook House has a more 'cottage style' appearance, commensurate with its age. 2.2.6. A farm building or barn, now known as the Coach House, was likely added in the Eighteenth Century to the South of Blackbrook House. Today this is used as short term holiday accommodation. 2.2.7. A traditional gated entrance from Blackbrook Lane leads onto an enclosed gravel courtyard which provides the frontage to the Coach House and a timber framed garage. The main house is located behind the Coach House and is only partially visible from the courtyard. 2.2.8. A high stone retaining wall to the East of the house supports the walled garden to the rear of Blackbrook House. The building is to a degree detached from the walled garden by the retaining wall being set approximately 1.5 meters lower than the main lawn. The walled garden and main lawn are linked to the house by a flight of steep uneven stone steps and a ramp. 2.2.9. The North elevation is a stone gable end and abuts a neighbouring field. The ground floor of the house is approximately one meter lower than the level of this field. There is one small low level window on the North elevation with obscured views from the house into the field. The field is crossed by a little used public right of way, from which there are views to the front and North elevations. 2.2.10. The East elevation, to the rear of the house, is private, enclosed and not overlooked. This is the position of the proposed single story extension. 2.2.11. The property is not overlooked by other dwellings. Although the adjacent farmstead to the South is located at a higher level, views to Blackbrook House are screened by a combination of intervening trees, vegetation and farm outbuildings. 2.2.12. A tributary that feeds Blackbrook runs through the property. It is separated from the house by the walled garden and passes South of the Coach House within a 30 meter long underground stone culvert. It then passes underneath Blackbrook Lane to feed Blackbrook. There is a type of mill race situated behind the timber framed garage. This is thought to have been associated with the Coach House building. 2.2.13. Key Dates: 1747 - Earliest deeds. Yeomans house. 1787 - Front reception rooms and formal facade rebuilt 1841 - Bay window added the South elevation, with Victorian sash windows and lead roof. 1930's - Blackbrook estate broken up 1940's - Part of the stone roof to the front of the house replaced with Welsh slate. Roof timbers replaced. 2.2.14. Historic deeds for the property were last held in 1984, and have since gone missing. 2.2.15. In accordance with the Peak District National Park Farmsteads Character Statement, it would appear that the layout of the farmstead does not form any of the traditional layout types discussed. However, there is some slight resemblance to the most common type of 'loose courtyard' arrangement, as the Coach House (the working element of the original farmstead) is to one side of the main house. The main courtyard is in-front of the Coach House and forms the current gravel driveway. The courtyard does not lie between the main house and the Coach House, here there is simply a small enclosed stone flagged space. ## Exterior: 2.2.16. The building is of coursed gritstone stone construction in good condition. The courses are noticeably narrower and more formal on the Georgian extension to the front. The roof is constructed in two finishes, the older East half in local stone tiles, and the Georgian half in Welsh slate tiles. The Welsh slate element of the roof replaced stone in the 1940s. The character of the rear East elevation is more rustic and less defined than the imposing and strong frontage. 2.2.17. The property has recently been refurbished and re-pointed using traditional heritage techniques including lime mortar. 2.2.18. There are a number of key historical architectural features to Blackbrook House (see photographs at Appendix 3): 2.2.19. The windows and doors to the property are in a variety of different styles, dating subtly from different eras. Having studied old photographs of the house, it appears that some windows were replaced in the mid-1980's and some replaced within the last 5 years. All are constructed from timber. 2.2.20. To the front Western elevation, there are dressed stone quoined corners. On the upper floor, there are four-bedroom windows, each are double hung sash windows, with 6 over 6 window panes. On the ground floor, there are three ornate floor to ceiling French windows with internal shutters. Above the centrally located front door is a flat door pediment, with dressed stone quoin surround. Ornate stone heads above the windows on both elevations are seen in the Georgian style. 2.2.21. To the Southern elevation, there is an early Victorian bay window extension with lead roof. This encompasses large Victorian sash windows with a recent 6 pane glass and timber door. A tall, narrow combined 8 pane window is used to light the downstairs WC and an upstairs bathroom. There are variations in coursing of the stone, providing evidence of past extension. 2.2.22. To the Eastern elevation, there are again a number of window styles. Tall plain glazing lights the hallway and landing. To the first floor there are 3 over 3 Victorian sash windows to the bathroom. The utility room has a similar 1980s style 16 panel window. The kitchen and rear bedroom have recent double glazed 6 over 6 Georgian sash replacement windows. The rear entrance is a 1980s style stable door with six glazed panels and three timer panels. Dressed stone quoined corners are seen to the part of the building that protrudes furthest to the East housing the utility room. There are further variations in the coursing of the stone to the South Eastern elevation, providing further evidence of past extension. ## Interior: 2.2.23. Downstairs, there are two formal reception rooms to the west, a hallway and cloakroom WC, and a kitchen and utility room to the east. Upstairs there are four bedrooms, a dressing room and two bathrooms. Recent renovations have been made internally. Original features have been restored. The house has recently been re-plastered with traditional lime finish using skilled heritage methods. ## 3. Heritage Asset Designations 3.1. Blackbrook House is not a Listed Building and has no formal heritage designation, however it has been identified as a non-designated heritage asset by the Peak District National Park Authority (see appendix 2). 3.2. The Ministry of Housing, Communities and Local Government define a non-heritage asset in the following way; "Local planning authorities may identify non-designated heritage assets. These are buildings, monuments, sites, places, areas or landscapes identified as having a degree of significance meriting consideration in planning decisions but which are not formally designated heritage assets. In some areas, local authorities identify some nondesignated heritage assets as 'locally listed'. A substantial majority of buildings have little or no heritage significance and thus do not constitute heritage assets. Only a minority have enough heritage interest for their significance to be a material consideration in the planning process." ## 4. Proposed Works 4.1. The existing kitchen at the rear of the house suffers from a lack of natural light. It faces East and the only existing kitchen window faces a 1.2 meter high retaining wall. The intention is to improve the living space within the current kitchen at the rear of the house, with the addition of a sympathetic single story extension in a traditional style. This will provide an enhanced family space within the existing kitchen area and improve the natural light. It will incorporate landscaped terracing to better connect the rear of the property to the existing walled garden, making better use of the different ground levels and making the steps to the garden safer. 4.2. The external envelope including the key historic architectural features of Blackbrook House will be retained, The proposal aims to harmonise with the existing building and reflect key design elements within the existing building and windows. It is subservient to the original building and is limited in size to approximately 19 square meters. The final footprint of the kitchen will be similar to the lounge. 4.3. The relationship between the house and the walled garden is being improved and opened out by stepping the retaining wall to create two terraces. Further South, the existing high retaining wall and ramp will be kept. The flight of stone steps will be reintroduced to a position that is slightly further South to follow the new desire line between the garden and back door. The steps will be split into two shorter flights to improve access to the garden. The garden modifications will help to tie in and enhance the connection between the house and garden. 4.4. In accordance with Peak Park District Planning policy, we have aimed to retain the character of the existing house by maintaining the overall historic form and visual integrity. The proposal is sympathetic, is not overlooked and is considered to be an appropriate enhancement to a building which has been much altered in the past. The main Georgian frontage of the house is unaffected as the extension is to rear of the house in a private enclosed setting linked to the walled garden. 4.5. The extension is single story and small scale allowing the main house to be the dominant element in the composition. It provides a design that is also in keeping with the rest of the building. The design will not result in the loss of any original key features, therefore the development is considered to be appropriate. 4.6. The effect of the proposed development on the house and setting is mitigated by using a more traditional design style, building methods and materials. The pitched Welsh slate roof is in keeping and the roof form allows the first floor bedroom window to retain light and views to the garden. The width of the extension has been reduced to conserve the stone quoin features on the existing elevation which will largely remain exposed. 4.7. The proposal affects only part of the East elevation and has been designed to retain the irregular character of this elevation. Although it introduces a higher proportion of glass, the window design reflects the style of the existing sash windows on the East elevation, and the upper level of the West facing Georgian frontage, thereby conserving its individual character. The proposal is in proportion to the existing building and retains the distinctive elements of the historic character of the building and its setting. ## Materials & Form 4.8. Other buildings in Blackbrook are predominantly constructed of local stone with pitched roofs, in the same way as Blackbrook House and the Coach House are built. The proposal follows this traditional theme. 4.9. Proposed materials will be of a high quality with an attractive appearance to complement the existing style, colour, pattern and texture of the existing building. Reclaimed stone will be used to match existing stone work at the rear of the property, where reasonably possible. Traditional lime pointing will be used to match the existing mortar which has been made using Mercaston Grit sand from a local quarry in Belper and natural hydraulic lime. 4.10. Windows and doors will be constructed of hard wood timber, and as can be seen on the drawings, will reflect the existing style of the windows and doors evident to the front and rear of the house. The design encompasses 6 over 6 Georgian style sash windows and floor to ceiling French doors to reference the existing windows to the front. These will be painted cream to match the rest of the external timber work of the house. 4.11. Downpipes will be 'Martin Brett' cast iron effect, to match the existing downpipes in situ on the majority of Blackbrook house and the Coach House. Drainage will be reconnected to the existing system. 4.12. The proposed glass roof lantern is of a medium size and traditional shape and form. It is designed to increase natural light within the internal space, and externally complements the pitched slate roof. 4.13. Stone from the existing stone window mullions will be reused internally. Stone removed from the external kitchen wall will be re-used where possible within the extension. Walling stone removed from lowering the existing retaining wall will be reused within the new terrace. The aim is to make both the terrace and the extension to appear as if it has been in situ for a good period time. 4.14. The Proposal will meet current building regulations. ## Landscaping 4.15. The alterations to the garden are relatively minor. The existing stone retaining wall would be 4 meters further East and the steep embankment would be partially remodelled into two lower terraces as described above. The use of terracing reduces the overshadowing effect of the existing wall and enhances the walled garden context. The proposed terraces will be planted with a combination of herbaceous perennials and low growing shrubs to improve the aspect to garden from the house and continue the existing planting theme within the walled garden. Flowering species will be chosen specifically to benefit and encourage pollinating insects. ## 5. Values 5.1. We have undertaken an appraisal of the buildings history and aesthetic value, commensurate with its local significance. This has informed the design. 5.2. Owing to the nature of the proposed work, which involves a sympathetic single-storey extension, it would not have a negative effect on its local heritage value and importance. 5.3. The proposed amendments to the building will enhance the aesthetic value of the property. The extension is considered to be beneficial as the relationship to the walled garden is improved. ## 6. Summary And Conclusion 6.1. National Planning Policy as well as specific guidelines issued by the Peak District National Park have been extensively reviewed and adopted, and provide the backbone of the proposal. 6.2. The proposed single story extension to the existing kitchen is seen as a continuation of the organic development of the building. It respects the key architectural detailing of the house and incorporates materials from the past building styles to form a unified and appropriate extension that is suited to modern day living preferences. 6.3. The proposed extension has been sited in such a way that it does not affect the farmstead layout. The loose courtyard arrangement in front of the Coach House and the small space between the rear of the Coach House and the main house are unchanged. 6.4. The design has a complimentary relationship between the existing building and its context. It works in harmony with the main building, and is therefore deemed to have a neutral impact on the historic and visual character of the property. 6.5. The proposal aims to enhance the irregular elevation to the rear by incorporating terracing, and would improve the relationship between the house and walled garden without adversely affecting the context of the building group and sense of enclosure. The design is sensitive to the historic qualities of the building and respects the setting and relationship to the Coach House, using reclaimed local materials where possible. It will not have a harmful impact on a historical significance of the building, and it will remain clear that it is an extension. 6.6. The proposals will not detract from the amenities of the area. The primary use remains as a residential dwelling house. The internal family space would be greatly enhanced. The proposal does not affect the relationship to the Coach House. The frontage and views from the public right of way is not affected. There will be no effect on local transportation systems or infrastructure. 6.7. The proposal is considered to comply with planning policy and guidelines and the effect of the proposal on the heritage value of the property is demonstrated to be negligible. 7. References Peak District Design Guide - https://www.peakdistrict.gov.uk/__data/assets/pdf_file/0013/90211/designguide.pdf Peak District 7. Alterations and Extensions Detailed Design Guide - https://www.peakdistrict.gov.uk/__data/assets/pdf_file/0020/90218/designguidepart7.pdf Peak District Guidance for preparing a Heritage Statement - https://www.peakdistrict.gov.uk/__data/assets/pdf_file/0007/823399/DMP-Appendix-05- Heritage-Statement-Guidance.pdf Peak District Dark Peak. National Character Area 51. https://www.peakdistrict.gov.uk/looking-after/living-and-working/farmers-landmanagers/historic-farmsteads-guidance Peak District Development Management Policy: Conserving and Enhancing the National Park's Characteristics. https://www.peakdistrict.gov.uk/__data/assets/pdf_file/0007/828286/Chapter-3-Conservingand-Enhancing-.pdf Peak District National Park Farmsteads Character Statement. https://www.peakdistrict.gov.uk/__data/assets/pdf_file/0010/987553/PDNP_Farmsteads_Char acter_Statement_v2.pdf National Planning Policy Framework - https://www.gov.uk/government/publications/nationalplanning-policy-framework--2 History of Chapel-en-le-Frith: History and its people - William Braylesford Bunting, 1940 The Book of Chapel-en-le-Frith Derbyshire: A Community History of the Parish - Mike Smith, 2003 Peak District Conservation Officers ## 8. Appendices 8.1. Appendix 1 - Historic Photographs, Maps And Drawings IN THE RIGHT DEMOLISHED. DATE UNKNOWN ## Blackbrook Deeds - Property Outlined With Red Boarder. Circa 1984 ## Proposed A6 Bypass To The South Of Blackbrook Hamlet. Now Built. Plan Circa 1979. ## Derbyshire (Northern Devision). Sheet 1 X 13. 1878 ## 8.2. Appendix 2 - District Npa Monument Full Report 26/02/2019 - Monument record received by email from Natalie Ward. Copied below. 27/02/2019 - Dr D Campbell HER officer confirmed that the Monument record does not have any additional information ## 8.3. Appendix 3 - Blackbrook House ## Northern Elevation. Gable End South Eastern Elevation - Rear
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# Blue Badge Scheme City Of York Council Internal Audit Report 2016/17 ## Summary And Overall Conclusions Introduction The Blue Badge Scheme was introduced to help disabled people with severe mobility problems to access goods and services by allowing them to park close to their destination either as a driver or as a passenger. Parking for Blue Badge users may also be at a reduced cost or free of charge. It is a national scheme, although local authorities are responsible for much of the administration of the scheme, including processing applications. In 2015-16 the council received approximately 3000 Blue Badge applications. ## Objectives And Scope Of The Audit The purpose of this audit was to provide assurance to management that procedures and controls within the system will ensure that: - Procedures are in line with good practice guidance - Payments for Blue Badges are appropriately managed - Applications are processed and authorised correctly within the required timescales - Blue Badges are subject to an appropriate renewals process ## Key Findings The authority has in place procedures to process new applications, renewals and payments as well as monitoring any issues that may be occurring. Procedures within the authority are based on national good practice guidance. During the course of the audit the service implemented a formal appeals process for rejected applications and reduced the duplication in the recording of applications when the council changed from Frameworki to Mosaic for Adult Social Care cases. The finding in the report relates to the contract for further assessments. ## Overall Conclusions It was found that the arrangements for managing risk were very good. An effective control environment appears to be in operation. Our overall opinion of the controls within the system at the time of the audit was that they provided **High Assurance**. ## 1 Contract For Further Assessments Issue/Control Weakness Risk There is no contract in place for additional assessments The authority may not be able to address issues if they occur ## Findings There is no current contract in place for the further assessments undertaken by the NHS where the application cannot be fully assessed in house by council staff. The service are working with the council's procurement department to ensure that the contract is correctly procured and put in place. ## Agreed Action 1.1 The service is currently working with Procurement to finalise an agreement with a provider for the service. This has been done through a framework City of York Council have in place with another local authority. ## Audit Opinions And Priorities For Actions Audit Opinions Audit work is based on sampling transactions to test the operation of systems. It cannot guarantee the elimination of fraud or error. Our opinion is based on the risks we identify at the time of the audit. Our overall audit opinion is based on 5 grades of opinion, as set out below. Opinion Assessment of internal control | High Assurance | |--------------------------------------------------------------------------------------------------------------| | | | Substantial | | Assurance | | Overall, good management of risk with few weaknesses identified. An effective control environment is in | | operation but there is scope for further improvement in the areas identified. | | | | Reasonable | | Assurance | | Overall, satisfactory management of risk with a number of weaknesses identified. An acceptable control | | environment is in operation but there are a number of improvements that could be made. | | Limited Assurance | | Overall, poor management of risk with significant control weaknesses in key areas and major | | improvements required before an effective control environment will be in operation. | | No Assurance | | Overall, there is a fundamental failure in control and risks are not being effectively managed. A number of | | key areas require substantial improvement to protect the system from error and abuse. | | | ## Priorities For Actions Priority 1 A fundamental system weakness, which presents unacceptable risk to the system objectives and requires urgent attention by management. Priority 2 A significant system weakness, whose impact or frequency presents risks to the system objectives, which needs to be addressed by management. Priority 3 The system objectives are not exposed to significant risk, but the issue merits attention by management. Where information resulting from audit work is made public or is provided to a third party by the client or by Veritau then this must be done on the understanding that any third party will rely on the information at its own risk. Veritau will not owe a duty of care or assume any responsibility towards anyone other than the client in relation to the information supplied. Equally, no third party may assert any rights or bring any claims against Veritau in connection with the information. Where information is provided to a named third party, the third party will keep the information confidential.
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## Investment Club Certificate Please read the notes on page 2 for information on when to complete this form. Enter the member's proportionate share of income and gains (as either a fraction or percentage) from the club's investments Investment club's income for the year ended 0 | Club income | Member's share | |------------------------------------|------------------| | Tax credits £ | | | Dividends received or | | | net income £ | Tax credits £ | | Dividends received or | | | net income £ | | | UK dividends | | | Overseas dividends | | | Savings income taxed at basic rate | | | Untaxed income | | Club details Member's share Net sale proceeds £ Capital gains £ Capital losses £ Net sale proceeds £ Capital gains £ Capital losses £ / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / / Date of sale DD MM YYYY Date of acquisition DD MM YYYY Name of company and description of holding for example, ordinary or preference share Schedule of gains and losses made during the year Include realised gains and losses only / / / / / / / / / / / / Notes Shortly after 5 April the Treasurer or other officer of the club should: - prepare two copies of this form for each member of the club to indicate the member's share of the income, and capital gains or losses of the club for the year to 5 April - give one copy to the member, and - keep the second copy in the club's record. The member should enter the details from this form onto their own tax return, if one is received. If a member does not normally receive a tax return and they have income or capital gains to declare, they can find guidance if they go to hmrc.gov.uk For more information about investment clubs go to hmrc.gov.uk
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# Prison Population Projections 2010 - 2016 England And Wales Ministry of Justice Statistics Bulletin Published 10th August 2010 Decorative image ## Contents | Key points | 2 | |--------------------------------------------------------------------------------|-----| | | | | 1. | | | | | | Introduction | 4 | | | | | 2. | | | | | | Prison population June 2009 to January 2010 | 6 | | | | | 3. | | | | | | Modelling methodology and projection scenarios | 7 | | | | | 4. | | | | | | Results | 9 | | | | | 5. | | | | | | Caveats on prison population projections | 12 | | | | | Appendix A: Additional tables | 13 | | | | | Appendix B: Testing the validity of 2010-2016 prison population projections 16 | | | | | | Appendix C: Detail of models, scenarios and assumptions | 17 | | | | | Appendix D: Stakeholders consulted about scenarios | 25 | | | | | Contact Points for further information | 26 | | | | | | | | | | ## Key Points This bulletin presents projections of the prison population in England and Wales from June 2010 to December 2016. The projections are based on assumptions about future sentencing trends and incorporate the anticipated impacts of selected policy and procedural initiatives. As part of ongoing work to improve modelling and forecasting across the Ministry of Justice, the method used to generate this year's prison projections has been revised and updated. The new method uses a single model to create projections over the full time range. This model uses a theoretical model of convictions and ONS population projections to predict the monthly prison population. Three projected scenarios have been modelled. These "no change", "increased sentencing" and "decreased sentencing" scenarios, reflect potential changes in sentencing behaviour and correspond to (though do not use the same assumptions as) the "medium", "high" and "low" scenarios used in the 2009 projections. Other impacts included in the projections, such as those of legislation and changing procedures are applied equally to all three scenarios. The projected prison populations for the three scenarios are given in Table 1. By the end of June 2016, the prison population is projected to be 83,100 on the "decreased sentencing", scenario, 88,500 on the "no change" scenario and 93,600 on the "increased sentencing" scenario. Sentencing trends Year Increase No change Decrease 2011 88,000 87,100 86,100 2012 89,300 87,700 85,900 2013 90,800 88,400 85,700 2014 92,000 88,700 85,200 2015 92,800 88,600 84,200 2016 93,600 88,500 83,100 This year's central projection is lower than the central projection created in 2009, if 2009-based projections are revised to account for the withdrawal of End of Custody Licence (the original projections assumed the scheme would continue indefinitely). This is largely due to a recent flattening of the prison population, which has happened despite upward pressures from the withdrawal of End of Custody Licence in March 2010. The withdrawal of End of Custody Licence is estimated to have had an impact of increasing the prison population by 1,200. Between June 2009 and June 2010, the prison population increased by 1,500. The assumptions informing these projections, and therefore the projections themselves, are subject to uncertainty. This is represented by the three scenarios, with each scenario being only as likely as the assumptions which inform it. These assumptions are based on extensive consultation (see Appendix D for a list of those consulted), and emerging data on them is being monitored. However, this publication does not predict which scenario is most likely to occur in the future. These projections take no account of any impacts which might result from the recently published Ministry of Justice Structural Reform Plan1. As such these projections provide a set of "baseline" scenarios against which the impacts of future changes can be assessed. ## 1. Introduction This bulletin presents prison population projections for England and Wales from July 2010 to December 2016. The projections are produced to aid development, capacity planning and resource allocation within the Criminal Justice System (CJS) and the National Offender Management Service (NOMS). The latest published useable operational capacity (30th July 2010) is 87,9472. Three possible future scenarios have been agreed through a consultative process. The scenarios cover three possible future sentencing trends (future changes in custody rates3 and average custodial sentence lengths for determinate sentences). These scenarios also take into account drivers which impact equally on each scenario:  views of future parole hearing frequency and expected outcomes for indeterminate sentences;  the impact of changes to arrangements for release on licence for current prisoners sentenced under the Criminal Justice Act 1991, which were brought in through the Criminal Justice and Immigration Act 20084; and  the impact of the withdrawal of End of Custody Licence in March 2010. As part of ongoing work to improve modelling and forecasting across the Ministry of Justice, the method used to generate this year's prison projections has been significantly revised and updated. The new method uses a single model to predict the monthly prison population for the entire projection period. The model takes into account the future size of the population of England and Wales (including the effects of migration) and the aging of the prison population. The new method also includes all prisoner types in a single model. Appendix C provides details of the methods used to produce the prison projections and the assumptions behind them. These projections take no account of any impacts which might result from the recently published Ministry of Justice Structural Reform Plan. As such these projections provide a set of "baseline" scenarios against which the impacts of future changes can be assessed. The Structural Reform Plan includes reform of sentencing and penalties, the rehabilitation revolution and reform of the prison estate, all of which are likely to have an impact on the prison population. ## 2. Prison Population June 2009 To January 2010 his The use of immediate custody (as opposed to other disposal options) and the average custodial sentence length are the two major factors that influence the future prison population. The "Story of the Prison Population 1995 - 2009" - a Ministry of Justice publication - addresses the changes in the prison population since 19955 and explains how these two factors, combined with key legislative and policy changes, influenced the prison population over t period. Tougher sentencing and enforcement outcomes and a more serious mix of offence groups coming before the court are the two factors that have caused the 66% increase in the prison population over this period. In the past year the prison population has continued to rise, growing from 83,500 in June 2009 to 85,000 in June 2010 (see Table 2). Ministry of Justice statisticians estimate that around 1,200 of this growth was the impact of the withdrawal of End of Custody Licence (ECL). If ECL had continued, growth from June 2009 to June 2010 would have been at a similar rate to that seen from June 2008 to June 2009 (0.4%). | Population in Custod | y | Year | % Difference | |---------------------------|--------|--------|----------------| | Start of Year End of Year | | | | | June 2004 to June 2005 | 74,500 | 76,200 | 2.3% | | June 2005 to June 2006 | 76,200 | 78,000 | 2.4% | | June 2006 to June 2007 | 78,000 | 79,700 | 2.2% | | June 2007 to June 2008 | 79,700 | 83,200 | 4.3% | | June 2008 to June 2009 | 83,200 | 83,500 | 0.4% | | June 2009 to June 2010 | 83,500 | 85,000 | 1.8% | The projections published in 2009 estimated a value at 30 June 2010 of 83,900 for the "low" scenario, 84,900 for the "medium" scenario and 85,700 for the "high" scenario. Adjusting for the impacts of the withdrawal of End of Custody Licence gives a value of 85,100 on the adjusted "low" scenario, 86,100 on the adjusted "medium" scenario and 86,900 on the adjusted "high" scenario, so growth from June 2009 to June 2010 has been lower than implied by the low scenario. ## 3. Modelling Methodology And Projection Scenarios The method used for generating projections of the prison population in England and Wales has been revised and updated in order to produce projections for 2010-2016. The new method removes any need to align the results of parallel models. At the core of the method is a single stock-flow model which is used to generate monthly prison population projections for the entire period for sentenced (including recall) and remand prisoners. This replaces a number of parallel models which were used to produce different time range sections of earlier projections. Inputs to the prisons stock-flow model are projections of future convictions which are predicted using ONS population projections combined with the Grove-MacLeod theory of re-offending6,7. Using ONS population projections ensures that the size and make up of the future population of England and Wales, which is driven by aging, death and migration, as well as by the number of live births, is accounted for. The stock-flow model monitors the size of the sentenced (including recall) and remand prison populations. This depends on the inflows defined above and the outflows, which are defined by average custodial sentence lengths for subsets of these populations. The model also contains a module which looks at the aging of the prison population over time. For this publication, the results of the stock-flow model are supplemented with an estimate of the future non-criminal population, which is based on the average of published data from March to May 2010. The models are based on data up to January 2010 from various sources including sentencing trends, prison receptions, discharges and populations, demographics and criminal histories of offending. Three projected scenarios have been modelled as shown in Table 3. These "no change", "increased sentencing" and "decreased sentencing" scenarios, reflect potential incremental changes in sentencing behaviour and correspond to (though do not use the same assumptions as) the "medium", "high" and "low" scenarios used in the 2009 projections. The three scenarios also incorporate the impact of past legislative and procedural change - the withdrawal of End of Custody Licence and the legacy of retrospective changes to release arrangements. The scenarios modelled are not predictions of what will happen to the prison population and none of them reflect potential changes to the prison population as a result of the Structural Reform Plan. ## F8 Percentage change in… Custody Rate Average Custodial Sentence Length Adult Young Adult Adult Young Adult Sentencing Trends Male Female Male Female Male Female Male Female Increase +1 +1 +1 +1 +0.5 +0.5 +0.5 +1 No Change 0 0 0 0 0 0 0 0 Decrease -1 -1 -2 -1 -0.5 -0.5 -0.5 -0.5 The modelling methodology, projection scenarios and assumptions used are described in detail in Appendix C. 8 These are percentage changes in custody rate and average custodial sentence length, even though custody rate is also expressed as a percentage. They are not percentage point increases. ## 4. Results The "no change" scenario projects that the prison population will rise to 78,00 by the end of June 2011 and to 88,500 by the end of June 2010. The "increased sentencing" scenario projects that the prison population will rise to 88,000 by the end of 2011 and to 93,600 by the end of June 2016. The "decreased sentencing" scenario projects that the prison population will rise to 86,100 by the end of June 2011 but fall to 83,100 by the end of June 2016. Chart 1 presents the projected scenarios with historical figures to show changes in the prison population since January 2008. Appendix A contains tables for annual projected end of June populations, average financial year populations and total monthly populations for each scenario. Further breakdowns show the sentenced population by gender, the remand population by gender and the non-criminal population. Tests on the validity of the current projections have been performed. These are discussed in Appendix B. Chart 1 shows a rise in all three scenarios until 2011 (end June figures). From this point, the decreased sentencing scenario remains stable until 2012, before falling each year to 2016. The no change sentencing scenario continues to rise past 2011 until 2014, where it stabilises to 2016. Finally, the increased sentencing scenario increases every year to 2016. These trends reflect the cumulative impacts of the various sentencing, legislative and procedural assumptions that are used to generate the projections. The seasonal pattern reflects the dip in the prison population which is always seen around the Christmas period. For the no change sentencing scenario, the custody rate and average custodial sentence length for determinate sentences are assumed to be constant going forward. Therefore, the early growth under this scenario (from current population levels) is likely to stem from the legacy effect of previous sentencing policy on average custodial sentence lengths and the increase in the indeterminate sentenced population (IPPs). The difference between the increased, no change and decreased sentencing scenarios directly reflects the different sentencing trend assumptions used in these scenarios to generate the projections. Full details of these scenarios can be found in Appendix C. Chart 2 plots the no change sentencing scenario projection against the historical actual data and the three scenarios from the 2009-based prison population projections, "high", "medium" and "low" scenarios. When comparing these figures it is important to note that in this chart the 2009-2015 projections have been adjusted for the withdrawal of the End of Custody License scheme (an additional 459 prisoners in March 2010 and an additional 1200 prisoners per month thereafter). The 2010-2016 "no change" scenario tracks between the "low" and "medium" scenarios of the adjusted 2009-based projections. Although based on similar assumptions, a completely different modelling technique has been used to produce the 2010-based projections, yet the central projection still lies within the boundaries of the previous projections. A comparison of end of June figures from the 2009 and 2010 projections can be found in Appendix A. The lower level of the new projections can be attributed to the lower than predicted overall growth observed between June 2009 and June 2010. This is largely due to a recent flattening of the prison population, which has happened despite upward pressures from the withdrawal of End of Custody Licence in March 2010. ## 5. Caveats On Prison Population Projections The projections presented here are a set of scenarios which reflect the impact of three possible trends in sentencing behaviour, combined with the impacts of changes to legislation which took place before May 2010. No attempts have been made to incorporate the effects of the Structural Reform Plan or any other new proposals, as the details of these have yet to be announced. These projections therefore provide a set of "baseline" scenarios against which the impacts of future changes can be assessed. Even without new policy change, the actual future prison population may be not the same as any of these "baseline" scenarios suggest. Changes to criminal justice processes, which are not modelled here, could influence the numbers of offenders being brought to the point of sentence or the way that offenders are managed. Changes to sentencing behaviour may also be different to those modelled here. Both sentencing behaviour and criminal justice processes, as well as policy decisions, can respond to a multitude of environmental factors, such as high profile criminal cases and public debate, which cannot be anticipated. Assumptions for modelling and scenario development were captured through a consultative process that included all major stakeholders (see Appendix D). The assumptions are based on analysis (where reliable data is available) and on expert judgement from policy makers, key deliverers and system influencers. The assumptions are therefore likely to be more robust for those measures and processes that have a well-defined boundary than those that do not. Data used in the model has been derived from various sources, including sentencing trends, prison receptions, discharges and populations, demographics and criminal histories of re-offending. Due to technical problems relating to the supply of data for statistical purposes some of this data was unavailable for July 2009 to February 2010. This means certain data has been estimated from past or closest equivalent data. At the total level, the projections for March, April, May and June 2010 are within 0.2% of published data (MoJ Population in Custody). The ways in which expert judgement, data estimation and underlying statistical modelling variation each contribute to these have not been separately estimated. ## 10 Appendix A: Additional Tables Annual tables of overall projected prison population Sentencing trends Year Increase No change Decrease 2011 88,000 87,100 86,100 2012 89,300 87,700 85,900 2013 90,800 88,400 85,700 2014 92,000 88,700 85,200 2015 92,800 88,600 84,200 2016 93,600 88,500 83,100 | Year | Increase | No change | Decrease | |-------------------|------------|-------------|------------| | Sentencing trends | | | | | 2010/2011 | 86,200 | 85,700 | 85,200 | | 2011/2012 | 88,200 | 87,100 | 85,800 | | 2012/2013 | 89,600 | 87,700 | 85,600 | | 2013/2014 | 91,000 | 88,300 | 85,300 | | 2014/2015 | 92,100 | 88,500 | 84,700 | | 2015/2016 | 92,900 | 88,400 | 83,700 | Sentencing trends Year 2009+ECL 2010 Difference 2011 88,100 87,100 -1.1% 2012 88,900 87,700 -1.3% 2013 88,800 88,400 -0.5% 2014 89,200 88,700 -0.6% 2015 89,900 88,600 -1.4% 10 All figures are rounded to the nearest hundred. Components may not sum due to rounding. 11 The 2009 "high" scenario is not directly comparable with the 2010 "increase" scenario; and the 2009 "low" scenario is not directly comparable with the 2010 "decrease" scenario. These are not shown. Annual tables of subgroups within the overall projected prison population Sentencing trends Sentenced Population Increase Decrease No change Year Male Female Male Female Male Female 2011 69,900 3,600 69,100 3,600 68,100 3,500 2012 71,300 3,700 69,700 3,600 68,000 3,500 2013 72,700 3,700 70,400 3,600 67,900 3,500 2014 74,000 3,800 70,900 3,600 67,500 3,400 2015 74,900 3,800 70,900 3,600 66,700 3,400 2016 75,700 3,900 70,900 3,600 65,800 3,300 | Male | Female | |---------------|----------| | Year | | | Remand | | | Non-criminals | | | 2011 | 12,400 | | 2012 | 12,300 | | 2013 | 12,300 | | 2014 | 12,200 | | 2015 | 12,100 | | 2016 | 12,000 | Monthly tables of overall projected prison population | | | | | | | Sentencing trends | Sentencing trends | |--------|----------|-----------|----------|--------|----------|---------------------|---------------------| | Month | Increase | No change | Decrease | Month | Increase | No change | Decrease | | Jul-10 | 85,800 | 85,500 | 85,100 | Oct-13 | 91,600 | 88,800 | 85,900 | | Aug-10 | 86,000 | 85,600 | 85,200 | Nov-13 | 91,600 | 88,800 | 85,800 | | Sep-10 | 86,600 | 86,100 | 85,700 | Dec-13 | 89,800 | 86,900 | 83,800 | | Oct-10 | 86,900 | 86,400 | 85,900 | Jan-14 | 91,000 | 88,100 | 84,900 | | Nov-10 | 87,100 | 86,500 | 85,900 | Feb-14 | 91,200 | 88,200 | 84,900 | | Dec-10 | 85,400 | 84,800 | 84,100 | Mar-14 | 91,400 | 88,300 | 85,000 | | Jan-11 | 86,700 | 86,000 | 85,300 | Apr-14 | 91,600 | 88,500 | 85,100 | | Feb-11 | 86,900 | 86,200 | 85,500 | May-14 | 91,600 | 88,300 | 84,800 | | Mar-11 | 87,200 | 86,500 | 85,700 | Jun-14 | 92,000 | 88,700 | 85,200 | | Apr-11 | 87,500 | 86,700 | 85,900 | Jul-14 | 92,200 | 88,800 | 85,200 | | May-11 | 87,500 | 86,700 | 85,700 | Aug-14 | 92,100 | 88,600 | 84,900 | | Jun-11 | 88,000 | 87,100 | 86,100 | Sep-14 | 92,500 | 89,000 | 85,200 | | Jul-11 | 88,300 | 87,300 | 86,200 | Oct-14 | 92,700 | 89,100 | 85,200 | | Aug-11 | 88,200 | 87,100 | 86,000 | Nov-14 | 92,700 | 89,000 | 85,100 | | Sep-11 | 88,600 | 87,500 | 86,300 | Dec-14 | 90,900 | 87,100 | 83,100 | | Oct-11 | 88,800 | 87,700 | 86,400 | Jan-15 | 92,000 | 88,200 | 84,100 | | Nov-11 | 88,800 | 87,600 | 86,300 | Feb-15 | 92,200 | 88,200 | 84,100 | | Dec-11 | 87,000 | 85,800 | 84,400 | Mar-15 | 92,400 | 88,400 | 84,200 | | Jan-12 | 88,300 | 86,900 | 85,500 | Apr-15 | 92,500 | 88,500 | 84,200 | | Feb-12 | 88,500 | 87,100 | 85,500 | May-15 | 92,400 | 88,300 | 83,900 | | Mar-12 | 88,700 | 87,300 | 85,700 | Jun-15 | 92,800 | 88,600 | 84,200 | | Apr-12 | 88,900 | 87,400 | 85,700 | Jul-15 | 93,000 | 88,800 | 84,300 | | May-12 | 88,900 | 87,300 | 85,600 | Aug-15 | 92,900 | 88,500 | 84,000 | | Jun-12 | 89,300 | 87,700 | 85,900 | Sep-15 | 93,300 | 88,800 | 84,200 | | Jul-12 | 89,600 | 87,900 | 86,000 | Oct-15 | 93,500 | 88,900 | 84,200 | | Aug-12 | 89,500 | 87,700 | 85,800 | Nov-15 | 93,400 | 88,800 | 84,000 | | Sep-12 | 90,000 | 88,100 | 86,100 | Dec-15 | 91,600 | 86,900 | 82,000 | | Oct-12 | 90,200 | 88,300 | 86,200 | Jan-16 | 92,800 | 88,000 | 83,100 | | Nov-12 | 90,200 | 88,300 | 86,100 | Feb-16 | 92,900 | 88,100 | 83,000 | | Dec-12 | 88,500 | 86,400 | 84,200 | Mar-16 | 93,100 | 88,200 | 83,100 | | Jan-13 | 89,700 | 87,600 | 85,300 | Apr-16 | 93,300 | 88,300 | 83,100 | | Feb-13 | 89,900 | 87,700 | 85,300 | May-16 | 93,200 | 88,100 | 82,800 | | Mar-13 | 90,100 | 87,900 | 85,500 | Jun-16 | 93,600 | 88,500 | 83,100 | | Apr-13 | 90,400 | 88,100 | 85,500 | Jul-16 | 93,800 | 88,600 | 83,200 | | May-13 | 90,300 | 87,900 | 85,400 | Aug-16 | 93,600 | 88,400 | 83,000 | | Jun-13 | 90,800 | 88,400 | 85,700 | Sep-16 | 94,000 | 88,700 | 83,200 | | Jul-13 | 91,000 | 88,500 | 85,800 | Oct-16 | 94,100 | 88,800 | 83,200 | | Aug-13 | 90,900 | 88,300 | 85,500 | Nov-16 | 94,100 | 88,700 | 83,200 | | Sep-13 | 91,400 | 88,700 | 85,800 | Dec-16 | 92,300 | 86,900 | 81,300 | ## Appendix B: Testing The Validity Of 2010-2016 Prison Population Projections The figures in this bulletin are not predictions of the prison population and should not be taken as such. However, comparing them with the actual figures allows us to test the strength of the projections. As the model used data up to January 2010, we can compare our projections with the actual prison population in subsequent months. Table B1 shows average and maximum percentage difference between the projected and published population figures13 in March, April, May and June 2010. Population breakdown Average % deviation Largest % deviation Total prison population -0.1 -0.2 All sentenced male -1.0 2.1 All sentenced female 1.8 2.5 Male remand 0.3 0.9 Female remand 6.8 11.1 The "no change" projected prison population is in line with recent published actual population figures, deviating no more than -0.2% (200 in 85,000). Similarly, the total projected sentenced population (i.e. those people on a determinate or indeterminate sentence, together with the recall population) deviates from published figures no more than -1.0% on average for males (1.8% for females) and -2.1% at worst (1,400 in 68,000) (2.5% for females (90 in 3,500)). The average projected male remand population does not deviate significantly from the published figures - on average the difference is 0.3% and at worst it is 0.9% (100 in 12,000), but the projected female remand population does deviate significantly from published figures (6.8% on average and 11.1% at worst (80 in 750). The female remand population is both small and volatile and is therefore difficult to model. Past projections have not provided greater accuracy for this population. For example, the projections published in 2008 predicted a central value for end June 2009 which was higher than published figures by 11%. ## Appendix C: Detail Of Models, Scenarios And Assumptions The Updated Modelling Approach The method used for generating projections of the prison population in England and Wales has been revised and updated. A single stock-flow model is now used to generate prison population projections for the entire period, so there is no need to align the results of multiple models. This model is similar to the long-term prison projection model used for earlier projections, but it generates monthly projections, models the aging of the prison population and includes all prisoner types. The short-term prisons projection model is not used because it cannot produce reliable projections into the distant future (more than 24 months) and because some of the time series data it relies on (prison receptions, sentence length and time served data) is unavailable for July 2009 to February 2010. ## Overview Of The Modelling Approach Central to the updated modelling approach is the prison population stock-flow model. Projections of future convictions are fed into this model and outputs from this model are manipulated to account for the impact of changes in legislation and process on the prison population, as shown in Figure C1. ## Prison Projections Prison Projections Producing Convictions Projections Numbers of future offenders are predicted using the Grove-MacLeod theory of re-offending. This asserts that offending can be modelled on the assumptions that:  within offender groups (which are defined by gender and re-offending behaviour), the fraction of the population who will be convicted of at least one offence remains constant over time; and  that, having been convicted, the probability of being convicted again remains constant within each offender group, irrespective of number of previous convictions. The Grove-MacLeod theory was originally developed using Offender Index data from 1953, 1958, 1963 and 1968. It has been shown to provide an effective model for offending in England and Wales14,15. We have applied the theory (which has been further developed by modelling males and females separately) to Police National Computer data from 200916 to derive parameters which show:  the fraction of each offender group who are predicted to be convicted at least once (the Criminality Fraction);  the Probability of First Conviction17 and the Average Time to First Conviction; and  the Probability of Reconviction and the Average Inter-conviction Time for further offences. The six offender groups are defined by gender and by common Probabilities of Reconviction and Average Inter-conviction Times (or high Rates of Reconviction), as shown in Table C1. There is no need for a group with a low Probability of Reconviction and low Average Inter-conviction time to effectively model the data. ## parameters from other recent years. 17 Reflecting the onset age of criminal responsibility and the rising probability that criminal behaviour will result in a conviction as individuals age from juveniles to adults, the Probability of First Conviction rises from zero before age 10 to a constant adult value at age 18 Male Female Gender Probability of Reconviction Average Inter-conviction Time Average Reconviction Rate High Low High High High Low Low High Low High Low High High High Low Low High Low d A stock-flow model is used to produce convictions projections based on these theoretical parameters and on ONS population projections18. The advantage of using population projections over projections of live births (which were use for earlier publications) is that they account for the effects of migration, as well as births and deaths, on the size of the population and on its gender and age composition. Figure C2 shows how the stock-flow model works. Population cohorts (90 cohorts, each with a single, nominal date of birth) enter the model. Criminality Fractions are then used to define the fraction of each cohort which falls into each of the six offending groups and which will be convicted at least once. Criminality Fractions are also used to define the fraction of each cohort which will never be convicted. Cohorts flow from the stock representing the fraction of the cohort that will be convicted at least once into the stock representing the fraction with one conviction. The rate at which this happens is based on both the Probability of First Conviction (calculated from the age of the cohort) and the Average Time to First Conviction. Following first conviction, offenders may or may not be convicted again. The Probability of Reconviction is used to calculate the proportion of the cohort that has received a conviction that will go on to receive another conviction. The Average Inter-conviction Time is used to determine the rate at which this happens. After this, offenders may or may not be convicted a further number of times, looping through the stock representing the fraction of the cohort with more than one conviction which will be convicted again. Eventually, continual application of the Probability of Reconviction means that the whole cohort has flowed into the various stocks that represent the fraction of the cohort which will not be convicted (again). 18 ONS population projections: www.statistics.gov.uk/StatBase/Product.asp?vlnk=10710 (Mid- Criminality Fraction Fraction of cohort with no convictions 1/X Cohort Stocks Cohort Flows The cohorts are aged as time progresses in the model. At each modelled time point, the fraction of each cohort which has been convicted is counted. This fraction is multiplied by the population estimates for the age of that cohort at that time to give the total number of convictions for the cohort. The model produces monthly convictions projections from the start of 2000 to the end of 2016. Projections for total convictions by gender gave a reasonable fit to historical data, but projections broken down by age group were not found to model the historical numbers of convictions well. To account for this, projections for juveniles, adults and young adults19 were adjusted using the fractional difference between projected and historical values for the whole of 2009 (with males and females treated separately). 2009 data was also used to find additive seasonality which was applied to the entire projected period. The resulting projections were between 3% and 11% of historical data for the last half of 2008 (average absolute difference) with the largest deviations appearing for the smallest and most volatile populations. Total convictions projections show a slow decline from 2010. This is principally due to the projections for juveniles and young adults and can be attributed to changes in the underlying population, where the number of people aged from 10 to less than 21 is predicted to fall from 2010 to 201520. Other historical deviations from the projections may be attributable to changes in the system, e.g. a change in focus on crime type or a change in the type of disposals used for detected crimes. For the future projections we assume there will be no further changes in system behaviour. ## Producing Prison Population Projections Prison population projections are produced using the Prison population stockflow model. The principal sub-populations in prison - determinate sentence, life sentence, imprisonment for public protection (IPP), remand and recall - are modelled using stock-flow structures based on the generic structure shown in Figure C3. To enable detailed calibration of the model, the stock-flow channels are further broken down by gender, reception age group and sentence length sub-band. Monthly inflows to prison for these sub-populations are based on the convictions projections described above. Historical receptions are set equal to the fraction of total convictions which resulted in each type of reception. Projected receptions are set to the average of this fraction for the last twelve months of historical data (February 2009 to January 2010 inclusive). For recall prisoners this assumes that recalls can be averaged over time. The model explicitly shows a certain fraction of recall receptions per conviction and sets recall receptions in the same month as their related conviction receptions. We assume that this is effective in implicitly modelling the real world situation in which individual prisoners can be recalled a number of times and recall receptions are always some time after their related conviction receptions. Monthly outflows (including outflows due to prisoner mortality) for determinate sentence, remand and recall prisoners are based on average custodial sentence length. Data on average custodial sentence length is calibrated in the model so that the modelled stock of prisoners is close (within 0.5% at the total level) to the actual historical numbers21. Projected outflows are based on average of this calibrated sentence length for the last twelve months of historical data. Prison Population Receptions / Pre-tariff ends Average Time Served IPP and life sentence prisoners have an extra section in the stock-flow structure which models their pre-tariff detention. Outflows from this section into the generic stock-flow structure depend on tariff length which is left largely unchanged from the management information source data (though life sentence tariffs were tuned for data before 2005, when more detailed data started to be collected on life sentences as a consequence of changes in the 2003 Criminal Justice Act22). Subsequent outflow for IPP and life sentence prisoners depend on the frequency and outcome of Parole Board hearings. These values are tuned so that over history the entire modelled stock of pre- and post-tariff prisoners is close to the actual historical numbers23. Projected outflows are based on the calibrated frequency and outcome of Parole Board hearings averaged over the last twelve months of historical data. The non-criminal population is modelled differently. In this case, the projected size of the non-criminal population is set equal to the average size of the noncriminal population over the last 3 months of published data. This ensures that the non-criminal projections reflect the latest and most accurate count of the non-criminal population. The main stock-flow structure shown in Figure C3 calculates the flow of prisoners into and out of prison based on their age group on reception (juvenile, young adult, adult). Dynamic aging matrices are used to convert projections by reception age group into projections by current age group. Separate matrices are provided for males and females and remand and sentenced prisoners. The population in prison at the end of each modelled month is aggregated into the categories defined by gender, current age group and, for determinate sentence prisoners, sentence length band, to produce unadjusted prison projections. ## Accounting For The Impact Of Legislation And For Seasonal Effects Prison stock-flow model outputs are subject to post-model adjustments to show the impact the withdrawal of End of Custody Licence (ECL) and the legacy of retrospective changes to release arrangements. Post-model adjustments are also used to account for seasonal variation in the population. Post-model adjustments have been applied equally to all the scenarios modelled. n ECL was introduced for determinate sentence prisoners at the start of June 2007 and ended in mid March 2010. The effect of ECL was to reduce the prison population by 1,200 prisoners24. The prison stock-flow model outputs do not account for ECL because they are based on management informatio which included ECL prisoners (for administration purposes). To model ECL, determinate sentence projections were reduced by 1,200 (with reductions for the various sub-populations scaled according to the fraction of the total for that category over the central 31 months of the ECL period) between June 2007 and February 2010 and by 741 in March 2010. Release arrangements for determinate sentence prisoners were changed in 2005 (as a result of changes made in the 2003 Criminal Justice Act) so that determinate sentence prisoners who committed offences from 2005 were released at the half way point of their sentence, instead of at the two-thirds point. No post-model adjustments are required to model this change because there is sufficient historical data to ensure any impacts are captured in the model calibration. However, in 2008 the Criminal Justice and Immigration Act applied this change retrospectively to most determinate prisoners who had committed offences before 2005. The calibration of the model assumes these prisoners would serve their sentence as they would have done before the retrospective rule change, so the "bounty" gained in each category as a result of the change needs to be subtracted from the determinate sentence projections. Total "bounty" gained was found to be 229 prison places at peak levels. It was also found to reduce over time as the number of prisoners to which the retrospective change applies goes down. Additive seasonality is seen over history for determinate sentences and remand prisoners. Projections for these prisoner types were smoothed using a centred 13 month average and seasonality was added back in to the projections. Seasonality was added to the smoothed projections over the bulk of the historical period using the simple difference between smoothed and non-smoothed historical data. It was added in to the smoothed projections over the future period (and the last six months of the historical period) using average seasonal adjustments from mid 2006 to mid 2009. No smoothing or seasonal adjustments were made for projections of IPP, life sentence, recall or non-criminal prison populations. ## Sentencing Scenarios Three scenarios have been modelled using the prison population stock-flow model. These scenarios reflect potential changes in sentencing behaviour which are manifested as uncorrelated changes in custody rates and average custodial sentence lengths for determinate sentenced prisoners. The scenarios are: "no change", "increased sentencing" and "decreased sentencing", these correspond to (though do not use the same assumptions as) the "medium", "high" and "low" scenarios used in the 2009 projections. The scenarios used are summarised in Table C2. The "no change" scenario assumes that custody rates and average custodial sentence lengths remain static at levels reported in January 2010 for all offenders. The "increased sentencing" scenario assumes that custody rates are increased by 1% of the current rate each year for all offenders; that average custodial sentence lengths for all males and adult females are increased by 0.5% of the current length each year; and that average custodial sentence lengths for young adult females are increased by 1% of the current length each year. The "decreased sentencing" scenario assumes that custody rates for all females and adult males are reduced by 1% of the current rate each year, that custody rates for young adult males are reduced by 2% of the current rate each year and that average custodial sentence lengths for all offender groups are reduced by 0.5% of the current length each year. Percentage change in… Custody Rate Average Custodial Sentence Length Young Adult Adult Young Adult Adult Sentencing Trends Male Female Male Female Male Female Male Female Increase +1 +1 +1 +1 +0.5 +0.5 +0.5 +1 No Change 0 0 0 0 0 0 0 0 Decrease -1 -1 -2 -1 -0.5 -0.5 -0.5 -0.5 Sentencing for juveniles follows the same patterns as sentencing for young adults in each of these scenarios and no changes are made to custody rates or average custodial sentence lengths for life sentence, IPP, remand, recall and non-criminal prisoners. No scenarios have been included in these projections which reflect changes to the prison population which might arise from the Structural Reform Plan. ## Appendix D: Stakeholders Consulted About Scenarios Internal stakeholders from across the Ministry of Justice. External representatives from: National Offender Management Service (NOMS)—Estates; NOMS—Population Strategy; NOMS—Public Protection Unit; NOMS—Scenario Analysis Team; The Magistrates' Association; The Probation Service; The Justices' Clerks Society; The National Bench Chairmen's Forum; The Parole Board; The Sentencing Council. ## Contact Points For Further Information Current and previous editions of this publication are available for download at Web link: www.justice.gov.uk/publications/prisonpopulation.htm Press enquiries should be directed to the Ministry of Justice press office: Tel: 020 3334 3536 Email: statistics.enquiries@justice.gsi.gov.uk Other enquiries about these statistics should be directed to: Ministry of Justice, Justice Statistics - Analytical Services Zone C, 7th Floor 102 Petty France London SW1H 9AJ 020 3334 3737 General enquiries about the statistical work of the Ministry of Justice can be emailed to: statistics.enquiries@justice.gsi.gov.uk General information about the official statistics system of the UK is available from www.statistics.gov.uk
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## January 2019 Update The LGAs Children's Services Programme Team is responsible for delivering a range of activities and support to help local authorities improve services for children. This newsletter is to provide an update on the key developments in the programme and over the last quarter. We have also used the opportunity to provide more information on the role of Children's Improvement Advisors (CIAs) along with a 'day in the life of' one of our CIAs. This is the first update in recent times and we intend to provide these on a quarterly basis. Those peers who have already been part of either a review, diagnostic or peer challenge will have used the Knowledge Hub to access the pre-review documentation. We have set up a private Knowledge Hub group just for peers - this is anyone who has completed our peer training and/or been part of an LGA peer team in relation to Children's Services (including Early Years). Later this month we will add peers to the group - we are going to use the group to keep everyone informed as to developments with our children's programmes and we will also use it to let you know of upcoming peer challenges so that you can let us know if you are available. If you do not want to be added to the group then please get in touch. Children's Services Peer Challenge Programme Refresh: to respond to the changing needs of Councils and the different approach now taken by Ofsted through ILACS we are refreshing the safeguarding peer review methodology. A revised model is being piloted in early 2019 and will feature a modular approach where Councils can build a review tailored to their individual needs. Peer Review Delivery: since April 2018 we have delivered 9 reviews and have 15 more scheduled, with more to come. Early Years Peer Challenge Programme: funded by the DfE, we have now piloted this in three councils and have agreed the roll out to a further 10 areas. The criteria for identifying the next cohort of councils to receive an early years peer challenge is currently being agreed and will be published soon. In addition, we are busy training early years peers with nearly 60 having completed the training and further sessions in early 2019. We are also working closely with the early Intervention Foundation who have developed an Early Years Maturity Matrix which will be used as part of the peer challenge process. Further developments will include the delivery of three learning and evaluation events over the next 18 months and the agreement that DfE will fund a follow up visit, 12 months after each peer challenge. Children's Finance Diagnostic: there has been lots of interest in this new offer and we are piloting this work in two councils in January/February 2019. These pilots will inform the development of a framework and guidance materials to support the roll out of the diagnostic from April onwards - get in touch if you want to explore the possibility of receiving a children's finance diagnostic. Elected member support and development: providing support, development opportunities and peer mentoring for lead members and chairs of children's scrutiny. Delivering regional workshops on topics such as children's service finance; performance management and corporate parenting and working to ensure effective children's services lead member network exist in all regions providing the opportunity for shared learning and collaboration. Peer recruitment: all our peer reviews rely on the expertise, experience and commitment of people already working in the sector. Being a part of a peer team is a hugely rewarding experience and you will receive support and training so that you can participate fully. At the moment we are particularly looking for skills and experience in the following areas:  Early Years Peer Reviews (council officers, health professionals, school head teachers/education leads)  Children's Finance Diagnostics (senior officers involved with children's services finance and commissioning) If you, or your colleagues, are interested in getting involved and want to find out more, please get in touch. Children's Improvement Advisers (CIA) These are key people in the LGA's support of Children's Services at Councils, and we have one covering each local government region in England. A summary of their role is below, and attached is a 'day in the life' diary of one of our CIA's, Claire Burgess. Working closely alongside the Local Government Association's Principal Adviser in each region the CIA will be instrumental to the improvement of children's services within councils. The key purpose of their role is:  To provide support to the Principal Adviser and work with councils that have been identified for sector-led support and develop strong relationships with Leading Members, Chief Executives and Directors of Children's Services and build a clear understanding of their needs to identify innovative solutions, broker improvement strategies, and ensure they are delivered;  To provide complementary support and assistance, where required, to existing Regional sector led improvement programmes for children's services and contribute to the development of the Local Government Association's (LGA) peer support service and support improvement in local authorities;  To deliver programmes to support and develop leadership and best practice in councils and support councils at risk, acting as a broker between the Local Government Association (LGA) and local authorities;  To commission additional capacity and expertise, through to facilitating staff development and change management programmes. Working with regional networks to ensure best practice, policies and partnerships are shared.
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Description ## Freedom Of Information: Records Released As A Result Of Freedom Of Information (Foi) Requests July 2006 This Table Lists The Individual Records Opened In July 2006 As A Result Of Foi Requests. Subject Catalogue Reference Date of record Atomic Energy AB 7/25401 1980 Jan 01 - 1980 Dec 31 Estimated risk of multiple fatalities due to meteorite strikes on England and Great Britain (England, Scotland and Wales) L S Fryer and K R Beck Cecil Day-Lewis Board of Stamps IR 59/1215 1972 Jan 01 - 1996 Dec 31 Buildings and Land HO 190/1137 1917- 1918 'Citadel Tavern', English Street, Carlisle Central Criminal Court J 267/349 1973 Jan 01-1984 Dec 31 Brown, Bruce and others: charged with robbery being armed; case papers Central Criminal Court J 267/348 1972 Jan 01-1976 Dec 31 Brown, Bruce and others: charged with robbery being armed; case papers Central Criminal Court CRIM 1/3814 Session: 1962 Jan 2 Defendant: HANRATTY, James Charge: Rape and murder Civil list PREM 5/180 1915- 1955 Theodore Powys; Albert Mansbridge; Elsie Sullivan (widow of J W N Sullivan) Colonial Office CO 1021/5 1952- Coronation: civil | 1953 | representation from Malta | |--------------------------------|------------------------------| | | | | Colonial Office | CO 1021/7 | | 1953 | | | Approval for representation of | | | Colonial Police at the | | | Coronation in the form of a | | | small armed contingent | | | | | | Contempt of Court | | | Cases | | | J 129/100 | 1963- | | 1976 | | | Relf, Robert. 3 parts | | | | | | Crime | HO | | 144/1709/424501 | | | 1921 | | | CRIMINAL CASES: | | | O'CONNOR, Edward | | | Convicted at Stafford on 10 | | | November 1921 for murder | | | and sentenced to death | | | | | | Crime | HO 144/1810 | | 1923 | | | CRIMINAL CASES: | | | WEAVER, William Henry | | | Convicted at Worcester on 7 | | | February 1908 for murder | | | and sentenced to death | | | (commuted) | | | | | | Czechoslovakia | BW 27/17 | | 1951 | | | Correspondence and papers | | | dealing with events up to, and | | | including, Council's | | | withdrawal from | | | Czechoslovakia | | | | | | Department of | | | Health and Social | | | Security: | | | Children's Division | | | BN 62/135 | 1959 | | Full inspection: Farnworth St | | | Aidan's Approved School, | | | Widnes, Lancs | | | | | | Department of | | | Health and Social | | | Security: | | | Children's Division | | | BN 62/1700 | 1958 | | Rose Hill Remand Home for | | | Boys Longley Lane, | | | Manchester 22 Lancs: | | | indecency | | | | | | BN 62/125 | 1953- | | 1954 | | | Department of | | | Health and Social | | | Security: | | | Children's Division | | | Scholar's complaint of | | | indecency against staff | | | member | | | | | | BN 62/2024 | 1966 Jan | | 01-1967 | | | Dec 31 | | | Department of | | | Health and Social | | | Security: | | | Children's Division | | | Red Bank Training School, | | | Newton-le-Willows, | | | Lancashire: complaints of | | | indecency | | | | | | Department of | | | Health and Social | | | Security: | | | BN 62/2012 | | | The Fylde Approved School, | | | Blackpool, Lancashire: | | | indecency | | | Children's Division | | |---------------------------------|-----------------| | Director of Public | | | Prosecutions | | | DPP 2/906 | 1941 | | HESSELDEN: Murder | | | | | | Director of Public | | | Prosecutions | | | DPP 2/306 | 1935 | | RUXTON, Buck: Murder | | | | | | Director of Public | | | Prosecutions | | | DPP 2/4039 | 1965- | | 1967 | | | ALPHON, Peter Louis: S66 | | | Post Office Act 1953. | | | Threatening telephone calls | | | to Lord RUSSELL | | | | | | Foreign Office | FO 371/121773/1 | | Syrian information that Israel | | | possesses an atomic bomb | | | and plans to use it to destroy | | | Arab oil fields should | | | hostilities break out. | | | [Previously closed extract: | | | Jacket VR 1091/52. Now | | | opened and reunited with | | | parent piece] | | | | | | Foreign Office | FO 371/121789/1 | | Conversation with Ali Abu | | | Nuwar on the Even Yehuda | | | incident. [Previously closed | | | extract: Jacket VR 1091/622. | | | Now opened and reunited | | | with parent piece] | | | | | | Foreign Office | FO 371/121795/1 | | Information that General | | | Burns is extremely anti-Israel. | | | [Previously closed extract: | | | Jacket VR 1091/802G. Now | | | opened and reunited with | | | parent piece] | | | | | | Foreign Office | FO 371/121798/1 | | Comparison of British | | | Government's reasons for | | | intervention in Egypt-Israel | | | hostilities with evidence of | | | French motives. [Previously | | | closed extract: Jacket VR | | | 1091/870G. Now opened and | | | reunited with parent piece] | | | | | | Foreign Office | FO 371/121803/1 | | Report by UN Relief official | | | concerning the Gaza area - | | | equipment captured by the | | | Israelis etc. [Previously | | | closed extract: Jacket VR | | | 1091/1016. Now opened and | | reunited with parent piece] Foreign Office FO 371/128140/1 1957 Straits of Tiran: memorandum handed to US State Department giving views of HM Government. Previously closed extract: VR 1081/401. Now opened and reunited with parent piece Home Office HO 45/23955 1949 CRIMINAL: Unduly harsh sentenced passed on 9 first offenders following political demonstration outside American embassy Home Office HO 144/21531 1941 WAR: Defence Regulation 93B: retention of articles and documents seized. Home Office HO 144/12235 1929- 1930 POLICE: Textile dispute at Bradford: action by police Home Office HO 144/21223 1930- 1932 DISTURBANCES: Lancashire cotton trade dispute. Home Office HO 144/21224 1932- 1939 DISTURBANCES: Lancashire cotton trade dispute Home Office: out letter books Home Office HO 151/10 1913 Sept 8-1919 May 21 Home Office HO 144/22427 1931 CORONERS AND INQUESTS: Verdict of 'possession by evil spirit' in suicide case Home Office: Children's Department MH 102/187 1939 Wellesley Nautical School: copy of Chief Inspector's report concerning an investigation into indecent behaviour among the boys Home Office: Fire Service HO 346/211 1977 Oct 14 - 1978 Jan 20 Home Office papers advising the course of action to be taken in the event of a strike by firemen Home Office: Fire Service HO 346/214 1974 Jul 26 - 1980 Revision of contingency plans in the event of strike action by | Sep 29 | firemen | |----------------------------------|------------| | | | | Inland Revenue | IR 62/1747 | | 1938 | | | Bequest to the National Trust | | | for places of historic interest | | | or natural beauty: O C J G L | | | Overbeck | | | | | | Inland Revenue | IR 40/7979 | | 1945 | | | Double taxation discussions | | | between the United States of | | | America concerning income | | | tax and estate duty | | | | | | Law Officers' | | | Department | | | LO 2/458 | 1967 | | Applications for the Attorney- | | | General's fiat under the Race | | | Relations Act 1965: 'Mankind | | | Quarterly': no consent | | | | | | Lord Chancellor's | | | Office | | | LCO 6/2867 | 1976 | | The British Bank of the | | | Middle East | | | | | | Medical Research | | | Council | | | FD 9/1394 | 1969 | | Advice requested on behalf of | | | parents of Thalidomide | | | children: question of payment | | | of fee | | | | | | Metropolitan Police MEPO 2/10280 | 1962- | | 1963 | | | Use of foetuses in firearms | | | testing | | | | | | Metropolitan Police MEPO 3/2459 | 1908- | | 1950 | | | Distribution of obscene | | | books, literature and | | | photographs: general | | | correspondence, reports and | | | specimens | | | | | | Metropolitan Police MEPO 8/68 | 1947 | | Illustrated Circular of | | | Confidence Tricksters and | | | Expert Criminals | | | | | | Metropolitan Police MEPO 3/1896 | 1945- | | 1953 | | | Illustrated circular (copy | | | dated 1947 attached) on | | | international confidence | | | tricksters etc: circulated to | | | Interpol and Dominions | | | | | | Metropolitan Police MEPO 2/9720 | 1962- | | 1968 | | | A6 murder: question of new | | | evidence in the case of | | | James Hanratty | | | | | | Ministry of Defence DEFE 13/554/1 | 1957 | |--------------------------------------|------------| | Previously closed extract: | | | Now released and reunited | | | with parent piece | | | | | | Ministry of Health | MH 154/744 | | 01-1976 | | | Dec 31 | | | Discussions and | | | correspondence with the | | | victims' solicitors and the | | | Thalidomide Children's Trust: | | | newspaper cuttings, briefs | | | and correspondence | | | | | | Ministry of Health | MH 96/1268 | | 1967 | | | Outbreaks of `Q' fever | | | | | | Ministry of Health | MH 168/89 | | 01 - 1969 | | | Dec 31 | | | Society for the Aid of | | | Thalidomide Children: | | | briefing, case notes and | | | correspondence | | | | | | Ministry of National | | | Insurance | | | PIN 35/358 | 1972 Jan | | 01-1976 | | | Dec 31 | | | Background notes for debate | | | on thalidomide children | | | | | | National Coal | | | Board | | | COAL 89/115 | 1968 Mar- | | 1986 Sept | | | Comrie Colliery Scottish | | | North Area | | | | | | National Coal | | | Board | | | COAL 32/20 | 1970- | | 1982 | | | NCB Publications: Public | | | Relations: National Coal | | | Board (NCB) Organisation | | | | | | Nationality and | | | Naturalisation | | | HO 405/19567 | 1947 Jan | | 01 - 1949 | | | Dec 31 | | | GOLDSTEIN, S Date of birth | | | August 1892 | | | | | | Nationality and | | | Naturalisation | | | CAILLER, H Date of Birth: | | | 10.09.1895 | | | HO 405/7676 | 1936 Jan | | 01-1937 | | | Dec 31 | | | Nationality and | | | Naturalisation | | | HO 144/3220 | 1924 | | Roumania. Resident in | | | London. Certificate 11,030 | | | issued 21 March 1924. | | | Nationality and | | | Naturalisation | | | HO 144/3495 | 1924 | | Russia. Resident in | | | Newcastle-upon-Tyne. | | | Certificate 10,827 issued 11 | | | January 1924. | | | Nationality and | | | Naturalisation | | | HO 144/9067 | 1928 | | Harris), from Poland. | | | Resident in London. | | | Certificate B.920 issued 21 | | | December 1928. Palester, | | | Abram Icchok (or Abraham | | Isaac Harris). Child of Hersz Palester. Certificate B.920. Nationality and Naturalisation HO 144/2063 1923 Myers, Joseph Samuel, from Russia. Resident in Belfast. Certificate 9,717 issued 22 January 1923. Nationality and Naturalisation HO 405/16169 1939 Jan 01 - 1940 Dec 31 GRONING, G Von Date of birth 12.10.1897 Nationality and Naturalisation HO 405/2348 1935 Jan 01 - 1935 Dec 31 BARK, P Date of Birth: 19.04.1869 Nationality and Naturalisation HO 144/12430 1930 Wauters, Joseph (or Joseph Walters), from Belgium. Resident in Luton. Certificate 19136 issued 15 December 1930. Nationality and Naturalisation HO 405/11905 1938 - 1947 EHRENFELD, A Date of birth 27.03.1891 Nationality and Naturalisation HO 144/10448 1929 Klawir, Isadore (or Isadore Glover), from Russia. Resident in Belfast. Certificate 17318 issued 6 July 1929. Nationality and Naturalisation HO 405/33040 1935 Jan 01 - 1935 Dec 31 LOVE, G Date of birth: 18/02/1888 Nationality and Naturalisation HO 144/10713 1929 Rydz, Schloima (or Solomon Rich), from Russia. Resident in Bradford. Certificate 17753 issued 27 November 1929. Nationality and Naturalisation HO 144/3644 1924 Meltzer, Aaron (known as Harry Meltzer), from Russia. Resident in London. Certificate 11,288 issued 15 July 1924. Nationality and Naturalisation HO 144/4425 1919- 1925 Meltzer, Sidney Solomon, from Austria. Resident in London. Certificate 4353 issued 29 July 1919. Melcer, Jozef (or Joseph Meltzer), from Poland. Resident in Tottenham, Middlesex. Certificate 12244 issued 17 July 1925. Nationality and Naturalisation HO 144/7525 1924- 1927 Meltzer, Abraham, from Russia. Resident in London. Certificate 11287 issued 15 July 1924. Nationality and Naturalisation HO 405/35584 1950 Jan 01 - 1950 Dec 31 MILLER, I aka MELTZER Date of birth 25/08/1899 Nationality and Naturalisation HO 144/14354 1931 Blasenstein, Schya (or Charles Birnhak), from Poland. Resident in London. Certificate A19704 issued 20 April 1931. Nationality and Naturalisation HO 405/12209 1939 - 1949 EVANGELISTI, R Date of birth 05.08.1871 Nationality and Naturalisation HO 405/26550 1934 Jan 01 - 1946 Dec 31 KUCZYNSKI, R R Date of birth: 12/08/1876 Nationality and Naturalisation HO 144/15612 1932 Hellmann, George (known as George Hellman), from Germany, Resident in Carterton, Oxon. Certificate AZ1462 issued 25 May 1932. Nationality and Naturalisation HO 144/9522 1928 Seener, Elias Boris, from Russia. Resident in London. Certificate 16595 issued 10 November 1928. Nationality and Naturalisation HO 144/3479 1924 Yedwab, Jacob (known as Jack Cohen), from Russia. Resident in London. Certificate 11,544 issued 21 October 1924. Nationality and Naturalisation HO 144/16081 1932 Vichinski, Yucob (known as Jack Cohen), from Russia. Resident in London. Certificate AZ2062 issued 16 September 1932. Nationality and Naturalisation HO 144/9385 1928 Steinberg, Aizic Volf (or John or Jack Steinberg), from Roumania. Resident in London. Certificate 15604 issued 12 January 1928. Nationality and Naturalisation HO 144/2286 1923 Katz, Abraham, from Russia. Resident in London. Certificate B 548 issued 25 September 1923. Katz, Isaac. Child of Abraham Katz. Certififcate B 548. Nationality and Naturalisation HO 144/12254 1930 Katz, Abraham, from Russia. Resident in London. Certificate 17970 issued 22 January 1930. Nationality and HO 144/16899 1932 Van Lier, Abraham, from the | Naturalisation | Netherlands. Resident in | |----------------------------------|-----------------------------| | London. Certificate AZ1674 | | | issued 23 June 1932. | | | Nationality and | | | Naturalisation | | | HO 144/5689 | 1926 | | Victor), from Russia. Resident | | | in London. Certificate 13857 | | | issued 23 September 1926. | | | Nationality and | | | Naturalisation | | | HO 405/22687 | 1947 Jan | | 01 - 1948 | | | Dec 31 | | | HOCHWALD, R Date(s) of | | | birth: 29.02.1902 | | | | | | Nationality and | | | Naturalisation | | | HO 144/15903 | 1932 | | Afghanistan. Resident in | | | London. Certificate BZ101 | | | issued 13 May 1932. | | | Mirzoeff, Alice. Child of | | | Gabriel Mirzoeff. Cetificate | | | BZ101. Mirzoeff, Jaffa. Child | | | of Bagriel Mirzoef. Certificate | | | BZ101. Mirzoeff, Sarah. Child | | | of Gabriel Mirzoeff. Certificate | | | BZ101. Mirzoeff, Zulay. Child | | | of Gabriel Mirzoeff. Certificate | | | BZ101. | | | Nationality and | | | Naturalisation | | | HO 405/27375 | 1946 Jan | | 01 - 1948 | | | Dec 31 | | | KOHN, L Date of birth: | | | 24/03/1899 | | | | | | Nationality and | | | Naturalisation | | | HO 405/15080 | 1913 Jan | | 01 - 1948 | | | Dec 31 | | | FORSHMAN, E aka | | | FORSCHMAN, M aka | | | FURSHMAN Date of birth | | | 03.12.1903 | | | | | | Nationality and | | | Naturalisation | | | HO 405/27105 | 1936 Jan | | 01 - 1962 | | | Dec 31 | | | KLAJMAN, D aka CLAYMAN | | | Date of birth: 22/10/1900 | | | | | | Nationality and | | | Naturalisation | | | HO 405/16064 | 1934 Jan | | 01 - 1935 | | | Dec 31 | | | GLENCK, A H W Date of birth | | | 06.04.1872 | | | | | | Northern Ireland | HO 267/228 | | 1923 Nov | | | Case of James Laverty, John | | | Kearney and David McKinstry | | | sentenced to ten years' | | | imprisonment for IRA | | | activities | | | | | | Police | HO 45/22338 | | 1948 | | | POLICE: Central conferences | | | of Chief Constables | | | | | | Prime Minister's | | | Office | | | PREM 5/200/1 | 1929- | | 1931 | | | Previously closed extracts. | | | Now opened and reunited | | | with parent piece | | Prime Minister's Office PREM 5/199/1 1924- 1929 Previously closed extracts. Now opened and reunited with parent piece Prime Minister's Office PREM 5/198/1 1924 Previously closed extracts. Now opened and reunited with parent piece Prime Minister's Office PREM 5/196/1 1922 Previously closed extract. Now opened and reunited with parent piece Prison PCOM 9/368 1938 CALDWELL, Charles James: convicted at Manchester on 14 March 1938 Prison PCOM 9/870 1940 OSTLER Vincent: convicted at Durham 22 April of murder and sentenced to death Prison PCOM 9/871 1940 APPLEBY William: convicted at Durham 10 April of murder and sentenced to death Prison PCOM 9/323 1933 PARKER, Ernest Wadge: convicted at Durham on 9 November 1933 Prison PCOM 9/892 1941 MORGAN Samuel: convicted at Liverpool 17 February 1941 of murder and sentenced to death Prison PCOM 9/914 1942 WILLIAMS David Roger: convicted at Liverpool 4 February of murder and sentenced to death Prison PCOM 9/918 1942 EDMONDSON Douglas: convicted at Liverpool 21 April of murder and sentenced to death Prison PCOM 9/1143 1946 HENDREN Thomas: convicted at Liverpool 27 June of murder and sentenced to death Prison PCOM 9/287 1930- 1931 BETTS, Victor Edward: convicted at Birmingham on 5 December 1930 Prison PCOM 9/312 1932- 1933 HANBURY, Jeremiah: convicted at Birmingham on 8 December 1932 Prison PCOM 9/1594 1951 WRIGHT, Jack: at Liverpool on 12 June 1951 convicted of murder; sentenced to death; executed on 3 July 1951 Prison PCOM 9/1127 1946 CHARLES Arthur: convicted at Durham 11 February of murder and sentenced to death Prison PCOM 9/827 1938- 1945 MOHAMED Jan: convicted at Manchester Assizes 27 April 1938 of murder and sentenced to death Prison PCOM 9/262 1930- 1936 JACKSON, Christopher: convicted at Durham 4 November 1936 Prison PCOM 9/356 1936- 1937 HASLAM, Max Mayer: convicted at Manchester on 10 December 1936 Prison PCOM 9/1260 1949 ROBERTS Benjamin: convicted at Durham 1 November of murder and sentenced to death Prison PCOM 9/1575 1950 TURNAGE, Patrick George: convicted at Durham on 26 October 1950 of murder; sentenced to death; executed on 14 November 1950 Prison PCOM 9/964 1942- 1943 ROBERTS Ronald: convicted at Manchester 16 November 1942 of murder and sentenced to death | Prison | PCOM 9/1034 | 1944 | |-------------------------------|----------------|---------| | DAVIDSON John Gordon: | | | | convicted at Manchester 1 | | | | May of murder and sentenced | | | | to death | | | | | | | | Prison | PCOM 9/1670 | 1953 | | MERRIFIELD, Louisa: | | | | convicted at Manchester on | | | | 31 July 1953 of murder; | | | | sentenced to death; executed | | | | on 18 September 1953 | | | | | | | | Prison | PCOM 9/1605 | 1951- | | 1952 | | | | ALI, Tahir: convicted at | | | | Durham on 28 January 1952 | | | | of murder; sentenced to | | | | death; executed 2 March | | | | 1952 | | | | | | | | Prison | PCOM 9/1495 | 1951- | | 1952 | | | | BRADLEY Alfred: convicted | | | | at Manchester Assizes on 7 | | | | December 1951 of murder; | | | | sentenced to death; executed | | | | 15 January 1952 | | | | | | | | Prison | PCOM 9/1035 | 1944 | | GALBRAITH James: | | | | convicted at Manchester 11 | | | | May of murder and sentenced | | | | to death | | | | | | | | Prison | PCOM 9/1137 | 1946 | | CLAYTON Walter: convicted | | | | at Manchester 16 July of | | | | murder and sentenced to | | | | death | | | | | | | | Prison | PCOM 9/899 | 1941 | | RICHARDS Eli: convicted at | | | | Birmingham 22 July of | | | | murder and sentenced to | | | | death | | | | | | | | Royal Arms | HO | | | 144/1634/410847 | | | | 1920 | | | | ROYAL - TITLE ROYAL AND | | | | ROYAL ARMS: Title Royal: | | | | Empire Tug Co. Ltd - refused. | | | | | | | | Royal Arms | HO 144/22735 | 1943- | | 1946 | | | | ROYAL - TITLE ROYAL AND | | | | ROYAL ARMS: Use of | | | | Crown: Ministry of Supply: | | | | crown in badge of uniformed | | | | car drivers of Mechanised | | | | Transport Corps later | | | | MOSAP Car Service | | | Treasury T 1/11025/1 1909 Previously closed extract: Paper 10552 of 1909. Now released and reunited with parent piece Treasury T 1/12132/1 1918 Previously closed extract: Paper 4332 of 1918. Now released and reunited with parent piece Treasury T 231/683 1951- 1958 Sterling area (except UK): investments in foreign countries and Canada United Nations Organisations HO 274/33 1977 Jan 01 - 1977 Dec 31 Sub-Commission on Prevention of Discrimination and Protection of Minorities: discussion between Baroness Elles, former UK representative on Sub- Commission, and the Home Office on deportation and extradition
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## A Councillor'S Workbook On Bribery And Fraud Prevention Contents | Foreword | 3 | |---------------------------------------------------------------------------------------|-----| | Bribery and fraud prevention | 4 | | Section 1 | | | Fraud from a local authority perspective | 5 | | Section 2 | | | Council and councillor responsibilities in relation to fraud prevention and detection | 9 | | Section 3 | | | The fraud response | 12 | | Section 4 | | | Fraud risk management | 19 | | Section 5 | | | Assurance that fraud arrangements are effective | 22 | | Section 6 | | | What you have learned and further reading | 26 | This councillor workbook includes references to materials published by the Local Government Association (LGA) and Chartered Institute of Public Finance and Accountancy CIPFA) Further information can be found on www.lga.gov .uk and www.cipfa.org ## Foreword This workbook has been designed as a learning aid for elected members. It makes no judgement about whether you have been a member for some time, or whether you have been elected more recently . If you fall into the former category the workbook should serve as a useful reminder of some of the key skills, approaches and tactics involved in neighbourhood and community engagement - it may even challenge you to reconsider how you have approached aspects of the role to date. Those members who are new to local government will recognise that they have much to learn. The workbook will help you to get up to speed on the main areas of the neighbourhood and community engagement role that require focus and attention. In effect, it should provide you with some pointers on how to develop a style and approach that you are comfortable with, and that enables you to be most effective in your day to day duties. The workbook offers few firm rules for ward members as it is recognised that each individual must decide how best to approach the role. This will be influenced by the other commitments in your life, the type of ward you represent and the methods and approaches that suit you best. There is no presumption about 'typical wards' or 'typical members' and the workbook should serve more as a direction marker rather than a road map. In practical terms, the document will take between two to three hours to work through. You do not need to complete it all in one session and may prefer to work through the material at your own pace. The key requirement is to think about your own approach to neighbourhood and community engagement - how the material relates to your local situation, the people you serve and the council you represent. In working through the material contained in this workbook you will encounter a number of features designed to help you think about the issues surrounding the development of neighbourhood and community engagement. These features are represented by the symbols shown below: Guidance - this is used to indicate guidance, research, quotations, explanations and definitions that you may find helpful. Challenges - these are questions or queries raised in the text which ask you to reflect on your role or approach - in essence, they are designed to be thought-provokers. Case studies - these are 'pen pictures' of approaches used by councils elsewhere. Hints and tips– a selection of good practices that you may find useful. Useful links - these are signposts to sources of further information that may help with principles, processes, methods and approaches. ## Bribery And Fraud Prevention Every organisation whether large or small is at risk from fraud and councils are no exception to this. All councils have a duty to protect the public purse and a major part of this is by limiting exposure to fraud and corruption and reducing risk through effective prevention and detection. Authorities, even the smallest, are constantly under threat from fraudsters whether that be single person discount fraud, reducing council revenue or a cyberattack causing a major data loss, reputational damage and fines from the information commissioner. Fraud is estimated to cost UK councils around £2.1 billion per year which is money that cannot be used to support local communities. As an elected member you have a range of statutory and moral obligations to protect the assets of your authority and you also need to equip yourself with the knowledge to deal with enquiries and questions from residents. ## Section 1 Fraud From A Local Authority Perspective The Scale Of Fraud The challenge presented by fraud to councils is significant. As stated in 'The Local Government Counter Fraud and Corruption Strategy 2016- 2019' (usually known as Fighting Fraud and Corruption Locally), it is estimated that fraud costs councils around £2.1 billion each year and some reports produced by other organisations suggest that this figure could actually be higher. The CIPFA (Chartered Institute of Public Finance and Accountancy) counter fraud and corruption tracker , known as CFaCT is an annual survey of fraud activity in councils (and some other public bodies) and measures detection rates across local government and across different types of fraud. Based on returns in 2016 CIPFA estimates that over £325 million worth of fraud was detected in the UK public sector in 2015/16, with the biggest fraud areas being council tax and housing tenancy fraud. In previous years housing benefit fraud will have figured highly on this list. Whatever the stats and reports say, is clear is that every pound lost by councils to fraud is a pound that cannot be spent on supporting the community. ## Useful links The full CFaCT report for the UK can be found here: www.cipfa.org/services/counter-fraud-centre/ fraud-and-corruption-tracker If your authority took part in the survey they will have received a free comparison report showing their counter fraud activity compared to other authorities in the same tier. See if you can obtain a copy from your fraud manager or head of internal audit. If your council didn't take part in the survey perhaps you can encourage them to do so next year? The Fighting Fraud and Corruption Locally strategy and companion documents can be found at: www.cipfa.org/services/counter-fraud-centre/ fighting-fraud-and-corruption-locally ## The Impact Of Fraud The impact of fraud should never be underestimated. Fraud leaves the council with less to spend on services for residents and costs taxpayer's money. Fraud against a local council is not a victimless crime. There's not only the lost/stolen money to consider but also the: • loss of working time, with officers putting things right and liaising with police and lawyers • cost of the investigation and any subsequent court costs • increased insurance premiums. There are also non-financial implications that are often forgotten. These will also, indirectly, have a financial impact, which is often difficult to qualify, such as: • reduced or poor service for residents • political impacts, eg government interventions, by-elections • reputational damage for individuals or the council as a whole • poor staff morale leading to poor performance and/or more fraud. ## What Is Fraud? 'Fraud is any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain.' 'Managing the business risk of fraud' published by the Institute of Internal Auditors, et al There are a number of definitions of fraud that are commonly used, however the majority of crimes committed that are considered to be fraud will be prosecuted under the Fraud Act 2006. Many activities that are carried out by councils are covered by specific legislation, for example, offences such as making false statements in order to obtain a council house or unlawful sub-letting of a council tenancy. ## Challenges Think about the services that your council provides and identify some fraudulent activity that might occur within each of the categories. Answers: If you would like to know more about the Fraud Act 2006 the key provisions of the Act can be found here www.legislation.gov .uk/ukpga/2006/35/contents Fraud Act 2006 This legislation was introduced to make the law of fraud simpler and more readily understandable providing a clear understanding of the ways in which fraud can be committed. The Act gives us the provision for the general offence of fraud which is made up of three key sections: • S2. Fraud by false representation • S3. Fraud by failing to disclose information • S4. Fraud by abuse of position. There are many other 'activities' that may fall under the overarching definition of fraud and are indeed types of fraud, the most common of these include: • corruption • bribery • theft • money laundering. To give a clearer understanding of these terms, they can be defined as: • **Corruption**: The misuse of a person's position to commit offences, which can include theft, extortion and a number of other crimes, including the soliciting of bribes. The defining characteristic of corruption is that it involves collusion between two or more individuals and is often associated with those holding public office. • **Bribery**: The offering, giving, receiving, or soliciting of any item of value, or an advantage to another person, to induce that person to improperly perform a relevant function or activity, or to reward them for improper performance. • **Theft**: Dishonestly appropriating property belonging to another with the intention of permanently depriving that person of it. • **Money laundering**: The process by which criminals attempt to disguise the original ownership and control of the proceeds of criminal activity by making such proceeds appear to have derived from a legitimate source. Useful links You can find out more about bribery and corruption by completing the CIPFA's Bribery and Corruption e-learning module, in partnership with the LGA. To access the site for the first time, please email: elearning@local.gov .uk http://lms.learningnexus.co.uk/LGA ## Areas Of Fraud Risk For Councils The estimated annual loss to fraud in councils is £2.1 billion. According to the CIPFA Fraud and Corruption Tracker 2016, the areas posing the highest fraud risk were: 1. Council tax fraud Fraud can occur when an individual intentionally gives incorrect or misleading information in order to pay less or no council tax. Examples include someone stating that they live alone when another adult also lives there or someone claiming to be a student when they aren't. 2. Social housing/tenancy fraud The unlawful misuse of social housing. This can be broken down into two main areas; social housing fraud and Right to Buy fraud. The former includes offences such as unlawful subletting, false applications, non-residency and unauthorised tenancy succession and the latter includes fraudulent applications under the right to buy/acquire schemes. 3. Procurement fraud This occurs in connection within the local authority supply chain. It can happen at any point throughout the procurement cycle but is particularly prevalent in the contract letting phase. It can also include tendering issues, split contracts and double invoicing. 4. Adult social care and direct payments Includes overstatement of needs through false declarations, multiple claims across authorities, collusion with care agencies and posthumous continuation of claims. ## Other High Risk Fraud Areas For Councils Housing benefit fraud Councils are no longer responsible for the investigation of this fraud but as administrators of this benefit there is a responsibility to actively prevent attempts of fraud and to notify the Department of Work and Pensions (DWP) of any suspected fraudulent activity including false applications and failing to declare changes in circumstances. Business rates (NNDR) fraud Offences include providing false details to obtain exemptions and reliefs and unlisted properties. Blue Badge misuse There are 2.39 million Blue Badges in issue in the UK and it is estimated that 20 per cent of these are subject to fraudulent misuse such as use of the badge when the holder is not present and the alteration of a badge. Recruitment fraud Includes false CVs, job histories, qualifications, references or referees. Insurance fraud False claims made against a council or their insurers such as 'trips and slips'. Grant fraud There are many different types of local authority grants paid out to individuals, businesses and charities. Fraud types include work not carried out, funds diverted, ineligibility not declared. Cyber fraud Such as phishing, allows a range of fraud types resulting in diversion of funds and the creation of false applications for services and payments. Pension fraud Occurs when the pension provider is not notified of changes in circumstances and payments continue to be cashed fraudulently. Examples include failure to notify the pension provider about the death of the recipient and failure to declare returning to work after retirement. No recourse to public funds Fraudulent claim of eligibility, usually by the provision of false papers or by overstaying. ## Case Study Dudley Metropolitan Borough Council'S Code Of Practice Dudley Metropolitan Borough Council has codes of conduct for employees and councillors which set out the high standards expected of them. These are also intended to relay certain messages to all suppliers as there is a growing expectation that all service providers in local government should adhere to the same principles of being open and transparent when dealing with colleagues, residents and partners. In developing its 'Suppliers' Code of Practice' Dudley aimed to reinforce good working practices and to stamp out fraud, bribery, corruption and unacceptable business practices. Staff who buy in goods and services on behalf of the authority and all suppliers are required to work to the guidelines in this code of practice. All active suppliers have received an email announcing the launch of the code and shown where the code is available on the council's website. The code includes useful contacts if people want to report problems to the council and reinforces the availability of a fraud hotline operated by Audit Services. Audit Services also intends to approach key suppliers to obtain feedback and ask for written assurance that they comply with the code. Dudley's leaflet 'Beating fraud is everyone's business', which sets out guidelines for employees, managers and councillors, is available on the CIPFA website. www.cipfa.org/services/counter-fraud-centre Reproduced from Fighting Fraud and Corruption Locally 2016-19 ## Section 2 Council And Councillor Responsibilities In Relation To Fraud Prevention And Detection Well governed organisations have a range of policies, procedures and frameworks to support effective risk management, transparency, accountability, financial control and effective decision making, many of which relate directly or indirectly to fraud prevention. Applying these is not only the responsibility of the audit committee or cabinet. As an elected member, you have an essential role to play in protecting the public purse, in particular within your council. You are responsible for ensuring that your authority adequately manages its risks and that local residents receive value for money. -You have a duty of trust to residents called the 'fiduciary duty' and a major part of this is ensuring that your council adequately controls its finances to reduce losses to fraud and corruption. In addition to your fiduciary duty, as a councillor you are a public servant and are expected to uphold certain standards of conduct and behaviour in your public life. The Committee on Standards in Public Life calls these standards the 'Seven Principles of Public Life' (also known as the Nolan Principles). ## Useful links If you would like to read more the full report on the Seven Principles of Public Life can be found here: www.gov .uk/government/uploads/system/ uploads/attachment_data/file/543819/CSPL_ Annual_Report_2015-2015.pdf ## The Seven Principles Of Public Life The Seven Principles of Public Life apply to anyone who works as a public office-holder . This includes all those who are elected or appointed to public office, nationally and locally, and all people appointed to work in the civil service, local government, the police, courts and probation services, non-departmental public bodies (NDPBs), and in the health, education, social and care services. All public office-holders are both servants of the public and stewards of public resources. The principles also have application to all those in other sectors delivering public services. ## 1. Selflessness Holders of public office should act solely in terms of the public interest. ## 2. Integrity Holders of public office must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships. ## 3. Objectivity Holders of public office must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias. ## 4. Accountability Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this. ## 5. Openness Holders of public office should act and take decisions in an open and transparent manner . Information should not be withheld from the public unless there are clear and lawful reasons for so doing. ## 6. Honesty Holders of public office should be truthful. ## 7. Leadership Holders of public office should exhibit these principles in their own behaviour. They should actively promote and robustly support the principles and be willing to challenge poor behaviour wherever it occurs. As a councillor you are expected to adhere to a code of conduct. A similar code of conduct will also apply to officers of your council. However, the biggest threat is from external sources, whether that is residents who may lie or exaggerate their circumstances to defraud or steal from the council or large scale, organised fraudsters, attacking public sector organisations as they perceive them to be a 'soft target'. As a councillor your role in protecting the public purse may take a number of guises depending on your role and the responsibilities of your council but they may include: 1. reporting suspicious activity in your locality to your audit or fraud team eg subletting or council tax evasion 2. scrutinising risk registers and challenging if the fraud risks appear to not be well managed 3. oversight and scrutiny of budgets, especially in high risk areas 4. ensuring you declare any interests if you sit on committees such as planning 5. monitoring performance of your audit or fraud team with regard to detection and prevention of fraud 6. supporting the principles of good governance, and supporting an anti-fraud culture across the council, including whistleblowing 7. supporting the publicising of successful prosecutions by your council to act as a deterrent and perhaps providing quotes to the press if appropriate. ## Something To Think About… 'Most public officials have probably never been offered a bribe and would feel pretty confident that they could spot the offer. If they don't necessarily think of themselves as totally incorruptible, they often think they can avoid getting entangled in situations where their conduct may be called into question. However, thinking you don't need help or guidance in knowing what is legal or illegal, or even what is right or wrong, in every circumstance is a risk - a risk that could and should be avoided by getting the most of what help and guidance is available.' Prof Alan Doig Visiting Professor, Newcastle Business School, Northumbria University Activity Imagine you are in the following situations, what you would do. ## 1. A resident comes to speak with you at your surgery and tells you that their neighbour is subletting their council property. 2. There has been a lot of publicity on TV about cyber fraud. You ask a question of your council's chief information officer (or equivalent) about what the council is doing to protect itself. The answer is "it's not a problem for us, so we don't really need to worry too much about it". You are not really comfortable that your chief information officer is taking the risk seriously . 3. You hear a rumour that a member of the planning committee has failed to declare that he has shares in a supermarket that want to develop in your area. 4. Your council is criticised by the external auditors for not doing enough to promote an antifraud and corruption culture. You are given the responsibility of leading the campaign. What might you do? Please see page 26 for some suggested answers. ## Section 3 The Fraud Response Councillors are not responsible for investigating fraud. If you become aware of fraud, or suspect it, you should immediately report it to the responsible officer in accordance with your authority's local procedures and policies. Do not be tempted to begin an investigation yourself, even if this appears to be helpful. However, you should be aware of the arrangements your council has in place for responding to fraud and this is particularly important if you are given special responsibilities in this area, such as being a member of the audit and/or governance committee. | Acknowledge | Prevent and Detect | Pursue | |------------------------------------|----------------------|----------| | Acknowledging and | | | | understanding fraud risks | | | | Preventing and detecting more | | | | fraud | | | | Being stronger in punishing fraud/ | | | | recovering losses | | | | i | i | i | | • Assessing and understanding | | | | fraud risks | | | | • Making better use of | | | | information and technology | | | | • Committing support and | | | | resource to tackling fraud | | | | • Enhancing fraud controls and | | | | processes | | | | • Maintaining a robust anti-fraud | | | | response | | | | • Developing a more effective | | | | anti-fraud culture | | | Fighting Fraud and Corruption Locally 2016-19 Activity What are your council's procedures for councillors to report fraud or suspicions of fraud? If you do not know, check with your member support officer or your authority's monitoring officer. A robust and strategic approach is required to effectively tackle fraud perpetrated against local government organisations. In order to tackle fraud risk, councils should have in place a strategic response based upon three basic principles as detailed below: • Prioritising fraud recovery and the use of civil sanctions • Developing capability and capacity to punish fraudsters • Collaborating with law enforcement ## Acknowledge This is key and will underpin any anti-fraud strategy. If an organisation does not accept that they are at risk from fraud, then they will never be able to develop an effective anti-fraud response and ironically will leave themselves open to a higher likelihood of attack from fraudsters. As a starting point a council should: • make a proper and thorough assessment of its fraud and corruption risks that are specifically considered as part of the overall risk management process • develop and implement an action plan in place to deal with the identified risks • report regularly to its senior board eg audit committee, and its members ## Prevent And Detect The old adage that 'prevention is better than cure' is never more appropriate than in dealing with fraud. The reason for many processes that appear annoying and bureaucratic is to introduce steps that make it harder for people to carry out fraud. Active prevention and fraud risk management is the most cost-effective way to fight fraud, make savings and reduce risk. Effective prevention should include: • A robust programme of anti-fraud and corruption awareness training for councillors, senior managers and all staff. • Standards of conduct and policies, that are well communicated, including: ◦ ◦officer and councillor codes of conduct ◦ ◦risk management policy ◦ ◦financial regulations and procurement policy ◦ ◦anti-fraud, corruption, money laundering and bribery policies ◦ ◦whistleblowing policy ◦ ◦register of interests ◦ ◦gifts and hospitality policy. Use of technology and data sharing to enable thorough due diligence with regards to recruitment, applications for services, the Right to Buy scheme and procurement processes. A well-publicised anti-fraud and corruption strategy and policy, and the publicising of successful investigations into cases of fraud and corruption, to build and develop a strong antifraud culture. Such a culture, when promoted from 'the top down', will encourage staff and service users to actively participate in fraud prevention through awareness and encouraging them to report any suspicions. Effective and well operated controls within systems that are regularly audited to provide assurance that they are working. Good networking by officers and sharing intelligence between authorities so that new types of fraud are picked up early. Unfortunately, no matter how good prevention measures and controls are, there will still be occasions when your council suffers fraud losses. In these circumstances it is vital that there is the ability to call upon competent, professionally accredited counter fraud specialists trained to a professional standard to investigate the suspected fraud. Councils need to ensure that evidence is lawfully gathered and professionally presented, irrespective of whether the anticipated outcome is a disciplinary hearing, civil action or criminal proceeding. ## Pursue Successful investigations will result in the identification of the fraudster and usually a financial figure representing the loss to the council. The authority will then have a number of options open to them regarding any course of action they may wish to take. This is a crucial part of the enforcement response and is needed to punish the fraudsters and act as a deterrent to others. Options available to councils include prosecution, cautions, fines and disciplinary action. The recovery of any financial loss is also one of the most effective ways to deter offenders. It demonstrates that that if caught, they will have to repay their 'ill-gotten gains'. It is important, therefore that there is a culture of rigorous pursuit of losses and that this is publicised. ## Investigative Approaches Councils need to regularly review their approach to fraud investigation and adapt when necessary. Some councils have dedicated corporate antifraud teams to deal with all types of fraud and corruption. Others rely on audit staff to conduct investigations and some bring in outside experts when the need arises. Some councils have merged their internal audit and fraud teams to reduce costs. None of these is necessarily better or worse; it depends upon the circumstances of the authority. However, fraud investigation is a specialist job so it is important that councils have access to such trained and experienced staff. ## Case Study Recovery Of Fraud Losses A council employee was illegally paid to provide confidential contract information. The employees' responsibilities included awarding council contracts for ICT equipment. The employee introduced two new suppliers to the tender list, subsequently advising them of tender submissions by competing companies. This enabled the two companies concerned to underbid competitive rivals to secure the contracts. The fraud was identified as a result of information from an anonymous informant. The employee was dismissed and subsequently found guilty under the Fraud Act and sentenced to two years' imprisonment. The council successfully obtained a confiscation order under the Proceeds of Crime Act for £75,000 which was the amount the employee had illegally been paid. Source: Audit Commission (2014) Activity What kind of anti-fraud and corruption approach does your council have? Ask your monitoring officer or head of audit/risk management. Do you think it is the right approach? Irrespective of how any council decides to tackle its fraud and corruption risk, there are always two types of investigation that councils may be involved in; proactive and reactive. ## Proactive Investigations These are intelligence led, making use of information from profiling or data-matching exercises. A common example of this type of investigation would be where the authority was looking to identify people defrauding the council tax single person discount (SPD) scheme. A household with only one adult is entitled to a 25 per cent discount on their council tax. Checking council tax records against the electoral role can identify cases where a person claims to be living alone is actually living with another adult. This type of data matching is legal and very effective in finding errors or frauds. ## National Fraud Initiative (Nfi) The National Fraud Initiative (NFI), coordinated by the Cabinet Office matches electronic data within and between public and private sector bodies to help prevent and detect fraud. These bodies include police authorities, local probation boards, fire and rescue authorities as well as local councils and a number of private sector bodies. Participation in the NFI is mandatory for councils who are required to submit data to the National Fraud Initiative on a regular basis. Reactive investigations These involve the search for and the gathering of evidence following an allegation or fraud referral, or the discovery of a set of circumstances which amount to an offence. In these cases, the offence is usually already being committed. An example would be where a member of the public contacts a council to inform them that one of their council tenants is unlawfully sub-letting their council property. ## Case Study London Borough Of Harrow And Luton Borough Council (Nfi 2012/13 Exercise) A payroll-to-payroll match identified an employee who was working full-time in a middle management position, in addition to a part-time night care worker role dealing with vulnerable adults. During the investigation it was established that some weeks she worked in excess of 70 hours, potentially placing vulnerable adults at risk. There was a suspicion that she had been able to work both shifts on a weekly basis by sleeping whilst at work and the information shared between councils showed that she regularly breached the Working Time Regulations. After investigation, she was found guilty and dismissed for gross misconduct by one authority and subsequently disciplined by the other for breaching the Working Time Regulations, but later resigned from the role. This case study comes the official Cabinet Office NFI pages and is one of many cases studies to be found there. They make interesting reading. You may very well find one from your council there. Take a look. www.gov .uk/government/publications/ national-fraud-initiative-case-studies/nfipublic-sector-case-studies In these cases a professionally qualified investigator, will carry out an investigation that could have some or all of the following components: • evidence gathering • interviewing witnesses and taking statements • interviewing the alleged perpetrator • preparing the case for court • giving evidence at court. ## The Challenges Faced By Councils In Dealing With Fraud And Corruption There are a number of challenges facing councils and their ability to effectively tackle fraud and corruption and to manage the risk it poses. Public sector budget reductions The impact of budget reductions has a three-fold effect: • less resources to maintain administrative procedures that prevent fraud • potentially reduced resources for investigating fraud • the risk of greater fraud activity by professional criminals or opportunists who identify local authorities as more vulnerable. These challenges have led to innovative thinking on ways of approaching the fraud and corruption risks such as joint working with other authorities or other public bodies and data sharing (such as the London Counter Fraud Hub). The best and most forward thinking councils use budget constraints as the impetus to drive forward the robust recovery of losses and other criminal assets which can and do lead to significant financial rewards. Some councils who employ successful financial investigators generate income by charging other organisations such as housing associations for investigative services. The Metropolitan Police's Serious and Organised Crime Command has successfully collaborated with financial investigators from several London borough councils There are currently nine Metropolitan Police Criminal Finance Teams set up as hubs - four in the north, four in the south and one central team - that are instrumental in training and mentoring several council investigators working together to tackle serious and organised acquisitive crime. The focus of this relationship is to recover assets and ensure that criminals do not benefit from criminal activities. ## How Innovative Has Your Council Been? Is There Scope For More? Maintaining an anti-fraud culture Councils need to develop and embed a culture with clear values and standards in which beating fraud and corruption is part of the daily business. The 'tone from the top' is crucial in this respect and councilors and senior leaders should be seen to 'walk the walk' in terms of their ethics, values and behaviours. The CIPFA Counter Fraud Centre has developed its 'top 10 tips' (see activity below) to support organisations in developing and maintaining an effective anti-fraud culture. Activity Review the Top 10 Tips, on the following page, and consider (find out if you don't already know) how good or bad your council is at each of these. Give a score from 1 - 5. ## 1. Set The Tone At The Top Creating an anti-fraud culture is part of good governance and, led by a council's councillors and corporate directors, should start with a clear commitment to tackling fraud, corruption and other similarly delinquent behaviours. Ideally, zero tolerance to fraudsters (as opposed to fraud per se) should form the centre-piece of your organisation's anti-fraud strategy reinforcing expected standards in public service as set out in the 'Seven Nolan Principles of Public Life'. Having professionally qualified counter fraud staff in place can help to achieve this, as they have the credibility, standing and expertise to raise the profile of the anti-fraud agenda internally. Score: 1…2…3…4…5 ## 2. Know And Prioritise Your Fraud Risks Knowing what the fraud and corruption risks are in an authority determines the type of framework you need to put in place and how your staff work within it. For example, if your risks include procurement fraud, those responsible for procuring contracts and services need to recognise fraud, bribery and corruption indicators when they see them. Professionally qualified counter fraud staff can assist with this process as they can assess risk and train operational staff in appropriate action. Score: 1…2…3…4…5 ## 3. Scan The Horizon Fraud is constantly changing and fraudulent schemes often target frontline staff who are an organisation's first line of defence. What might seem a low fraud risk today might turn into a high one in the future. It is therefore vital that your organisation is up-to-date on the latest threats and risks and how to tackle them. Professionally qualified counter fraud staff can ensure that staff know who to come to if they suspect something amiss. As part of their continued professional development, counter fraud staff will also be 'plugged into' various anti-fraud networks which are vital sources of new information and threat alerts. Score: 1…2…3…4…5 ## 4. Build Fraud Awareness Creating an anti-fraud culture and beating fraud should be everyone's business within a council, from the dedicated counter fraud specialists through to the procurement team, HR, facilities staff and beyond. A qualified counter fraud practitioner will be fully trained in how to help mobilise the entire organisation in the fight against fraud. Whether using e-learning, staff briefings, training, posters or internal alerts - or a combination of all these - they will be best placed to define and execute awareness programmes. Score: 1…2…3…4…5 ## 5. Ensure Policies And Procedures Are In Order Professionally qualified counter fraud staff should be adept at finding the fraud gaps in existing organisational policies and procedures and determining what is required to plug those gaps in a cost-effective manner. For example, a general anti-fraud policy should include: guidelines on what to do when suspicions of fraud arise; a fraud response plan; processes for creating and implementing gifts and hospitality registers, declarations of interest registers and so on. An accessible and well-articulated whistleblowing policy should also be part of any effective antifraud culture. Score: 1…2…3…4…5 ## 6. Create A Dedicated Anti-Fraud Team Build capacity by creating a counter fraud team comprising of professionally qualified who are operationally independent from other teams. This will ensure their objectivity and impartiality. The team should be provided with the necessary resources required for their function, which would include an element of contingency or 'flex' to cater for unforeseen surges in work, such as large and complex investigations. With the necessary safeguards in place, the team should also have access to the information, data systems and senior personnel they need to effectively perform its function. Score: 1…2…3…4…5 ## 7. Take Action Recovering money lost to fraud so it can be spent on key services is obviously vital. Professionally qualified counter fraud staff will be fully trained in conducting effective investigations and pursuing cases through the legal system, including the preparation of cases for prosecution. They will have the ability to give evidence in a court of law and take steps to recover lost funds. Score: 1…2…3…4…5 ## 8. Measure Success Today's counter fraud specialists not only understand how to detect, prevent and recover fraud losses; they are also trained to measure and report on the effectiveness of the preventive measures they put in place. This forms a key part of an organisation's anti-fraud culture as it highlights to senior management the successes of counter fraud work. Score: 1…2…3…4…5 ## 9. Publicise Your Success Sharing the outcome of a successful investigation or how an anti-fraud measure has worked is a positive way to advertise the message that fraud doesn't pay. Professionally qualified counter fraud practitioners understand this and will want to publicise their successes both internally and externally, which should be encouraged. As well as being a deterrent, this can also lead to an increase in fraud referrals which is a good indicator that your anti-fraud culture is working. Score: 1…2…3…4…5 ## 10. Never Take Your Eye Off The Ball Fraud is an ever-evolving threat and as the risk doesn't stand still, nor should your organisation's strategy to combat it. Professionally qualified counter fraud staff are trained to implement and manage prevention programmes to monitor the measurement and control strategies in place and make any necessary adjustments. They will also be able to recognise new threats and risks and the need for refresher training whenever this may arise. **Score: 1…2…3…4…5** ## Total Score: ……. Do You Think This Is Good Enough? Abiding By The Rules In dealing with fraud, councils need to abide by the rules in order to ensure that frauds they detect and investigate can be pursued to the most appropriate conclusion. The rules protect the rights of individuals to privacy and the right to a fair trial. Although there are frequent stories in the press about councils 'snooping' on people, the rules are in fact very strict. For example: Regulation of Investigatory Powers Act (RIPA) 2000 This was brought in to regulate the powers of public bodies who carry out surveillance and investigation and also to cover the interception of communications. Councils have access to some of these powers for the purpose of prevention and detection of a crime. Requesting information Council investigators have certain 'authorised officers' powers to request information about individuals For any other investigations, they are restricted to powers under Section 29 (3) of the Data Protection Act (DPA) 1998 which allow organisations to give such information to council investigators, assuming it is for the prevention and/or detection of a crime, but it does not compel them to do so. Consequently, some organisations choose not to give the requested information to a council. The data matching approach described earlier is also regulated under the Data Protection Act. ## More Sophisticated Frauds The landscape of fraud and corruption is everchanging, especially with the use of technology and the internet. Fraudsters never rest on their laurels and are always looking for new ways to defraud. This means council are constantly exposed to different threats and managing this risk can be extremely difficult so it's extremely important that the investigators keep abreast of emerging risks and trends and share this across the council, but in particular with key teams such as payments. The advent of 'cyber crime', whether or not it involves fraud, is probably one of the biggest challenges facing public bodies today. ## Publicising Success While it may be embarrassing for any organisation, especially a local council, to admit that it has been the victim of fraud, experts would say that publicising successful investigations, where possible, is much the best policy. When a case ends up in court it will in any case become public. Proactive publicity shows residents and taxpayers that you are taking active steps to protect their interests and it may deter future fraudsters. Press and media teams can help to make sure the message is seen in a positive light. ## Section 4 Fraud Risk Management Note: You should complete this section if you have special responsibility for audit, risk or governance. If not, you can move on to section 6. Risk management is essential for good governance within any organisation and effective fraud risk management is a vital part of that. If you have a special responsibility as a councillor for audit, risk or governance, you will need to ensure that your council has appropriate arrangements in place to manage the risk of fraud. All councils have faced and are still dealing with increased pressure on their budgets meaning that the requirement to identify fraud and reduce risk is perhaps higher now than it's ever been. The CIPFA code of practice on the management of fraud risk sets out the expected standard for public bodies in the management of fraud risk. ## Hints And Tips Code Of Practice Principles Leaders of public services organisations have a responsibility to embed effective standards for countering fraud and corruption in their organisations. This supports good governance and demonstrates effective financial stewardship and strong public financial management. The five key principles of the code are to: • acknowledge the responsibility of the governing body for countering fraud and corruption • identify the fraud and corruption risks • develop an appropriate counter fraud and corruption strategy • provide resources to implement the strategy • take action in response to fraud and corruption. 19 Implementing an effective fraud risk management framework, such as the CIPFA code of practice, will enable authorities to employ controls that help to prevent fraud from occurring in the first place, identify and detect fraud as soon as it occurs and enable a practical and efficient response to those fraud incidents. Fraud risks need to continually reviewed and managed, in the same way that other risks are managed within a council. The identification, assessment, mitigation and monitoring of risk (including fraud risks) is called the risk management lifecycle. The process works as such: • external events • new products • acquisitions • changes to business • KRI's • loss data • Issue management • Risk appetite • avoid • transfer • mitigate by controls • accept residual risk To help ensure that the fraud risk management is effective, it's important that the roles and responsibilities of all employees, members and those who act on behalf of the council are understood by all. The list below is not exhaustive but the main roles can be summarised as follows: ## Councillors ✓ ✓Have and maintain an understanding of fraud risks ✓ ✓Understand the key principles of risk management ✓ ✓Consider fraud risk in relation to the decision making process ## Directors ✓ ✓Support the council's fraud risk management strategy ✓ ✓Set the appropriate tone with regards to the council's anti-fraud and corruption approach ✓ ✓Ensure that there is a coordinated and consistent approach to the identification and management of fraud risk Senior managers/service heads • Ensure that fraud risks are appropriately managed and implement effective review and monitoring arrangements • Manage risk in their service areas in accordance with the fraud risk management strategy ## Internal Audit/Corporate Fraud Team ✓ ✓Consider the council's fraud risk assessment when developing the annual audit plan ✓ ✓Audit the internal fraud control processes across the authority ✓ ✓Coordinate and/or conduct fraud and corruption investigations ✓ ✓Assess the effectiveness of fraud prevention and detection processes ✓ ✓Provide assurance to councillors and senior management of the effectiveness of fraud risk management and controls ## All Staff ✓ ✓Have a basic understanding of fraud risks and be aware of indicators ✓ ✓Manage fraud risk in the course of their daily duties ✓ ✓Read, understand and have access to fraud related policies and procedures ✓ ✓Contribute towards the development of fraud control processes ✓ ✓Report suspicions of fraud and corruption ✓ ✓Cooperate with investigations The development and implementation of a robust fraud risk management program will reduce the opportunities for fraudsters to exploit. This, coupled with encouraging employees to actively participate in the fight against fraud will contribute significantly to the creation of a strong anti-fraud culture; helping to change the attitude towards fraud so that it is not tolerated and therefore reducing the risk of fraud happening in the first place. ## Fraud Risk Assessment The basis of an effective fraud risk management program begins with a Fraud Risk Assessment (FRA). Councils are likely to face a wide variety of fraud and corruption risks and so a FRA will help the council to understand and identify the risks that are specific to the organisation as a whole as well as those that relate to individual service areas. It will also highlight gaps or weaknesses in fraud controls allowing the council to implement a plan to ensure the best use of resources in order to tackle those risks. When conducting a FRA the questions that should be considered are: • How could a fraudster exploit weaknesses in the current system controls? • How might those controls be over-ridden or by-passed? • How could the fraudster conceal their activities? Bearing the above in mind, an effective FRA should generally consist of three main elements: • Identification of the fraud risk This will involve the gathering of information to highlight the fraud risks that could affect the council. • Assess the likelihood and impact of the fraud risk This assessment is based on historical information, and discussions/interviews with heads of services and other relevant staff. • Develop a response to those that present the highest risk Decide how best to respond to the fraud risks. ## Section 5 Assurance That Fraud Arrangements Are Effective Note: You should complete this section if you have special responsibility for audit, risk or governance. If not, you can move on to section 6. If you have special responsibility for audit, risk or governance you will wish to assure yourself that your council's fraud arrangements are effective. ## Assurance Is: 'Data or information provided to management/boards/committees to give comfort that risks are being properly managed and controls are adequate and working effectively' Institute of Internal Auditors Best practice dictates that governance, risk management and strong financial controls (called the system of internal control) are part of the daily and regular business of an organisation. The system of internal control is a key component in the prevention and detection of fraud and corruption. ## What Is Internal Control? Any action taken by management, the board and other parties to manage risk. In other words, an action taken to ensure that risks do not materialise or get worse. Some examples might be: • Expenses claims must be authorised by management before payment. This processes of checking the claim for accuracy prevents fraud or error and so controls the risk of overpayment. • The housing department carry out regular tenancy audits of their properties. This process of checking acts a deterrent to subletting and a detection if it does happen and so controls the risk of subletting. • The health and safety team carry out regular inspections of public buildings. These inspections highlight any existing problems for repair or any potential problems for signposting. In this way, the risk of slips, trips and other accidents are controlled. Councils must have a means of obtaining independent assurance that the system of internal control is adequate and working effectively. In local authorities there is usually an audit committee (sometimes called audit and risk committee) to carry out this role. Usually there is also an overview and scrutiny committee to oversee the decision-making process, ensure that it is clear and that the people taking decisions are held accountable for those decisions. The existence of an audit committee or scrutiny committee does not remove responsibility from individual members and senior managers, but provides the resource to focus on these issues. There is no 'one–size-fits-all' approach that must be applied to assurance and scrutiny in local government but council leaders and executives must ensure that the model they adopt is independent from the executive and other political influences. Fraud prevention is heavily reliant on the system of internal control being adequate and working effectively. Most councils rely on their internal and external auditors to provide these assurances but audit resources are limited and expensive and can never be relied upon to provide assurance across every activity that the local authority is responsible for. Therefore all councillors and council officers have a role to play in seeking assurance that the controls are working. After the banking crisis a model was devised to try to capture and utilise the various levels of assurance that exist within organisations. This is called the three lines of defence The majority of members will have little interaction with auditors other than when reading their report at the year-end but as the model shows, in reality the majority of assurance should come from within the organisation itself. As a councillor you will receive and review a range of information and reports from within your authority or from external sources such as regulators or inspectors. These will often be related to your areas of expertise or committees that you sit on. It will be your responsibility to inspect and challenge the information you receive to assure yourself that it is accurate, credible and evidence based and that it tells you what you need to know. When considering the fraud risks that your authority might be facing you need to consider whether the controls that you know exist are doing the job they are meant to be doing. If you have concerns that they are not then you need to raise that through the appropriate channels eg with the head of fraud, head of internal audit or through the chair of the audit committee. ## Role Of Audit Committees In Anti-Fraud And Corruption Activity The purpose of an audit committee is to provide to those charged with governance independent assurance on the adequacy of the risk management framework, the internal control environment and the integrity of the financial reporting and annual governance processes. If you sit on an audit committee you may wish to read more on the role of audit committees in relation to fraud prevention. ## Useful Links Following Publication Is Recommended. In relation to anti-fraud and corruption activities the audit committee will receive regular reports from officers and auditors on the following: • fraud cases that have occurred within the authority and financial losses • whistleblowing • current and emerging fraud risks and how they are being managed • KPIs relating to fraud prevention and detection performance • sanctions (including prosecutions and disciplinaries) and recovery actions • benchmarking data • resources spent on these activities within the authority. Activity Find and obtain the latest fraud update provided to your audit committee and consider the following? 1. Is the reported fraud in line with what you would have expected for your council? 2. Are there any areas where you would have expected fraud that have not been reported on? If so why do you think that might be? 3. In your view is the reporting adequate? If not why not? 4. Has whistleblowing been reported on? Do you have a clear understanding of the whistleblowing arrangements in your authority? If you are unclear you should obtain a copy of your council's policy. ## What Good Looks Like - The Fighting Fraud And Corruption Locally Strategy Turning Strategy Into Action The Themes - Six Cs Councils should consider their performance against each of the six themes that emerged from the research conducted. Culture - creating a culture in which beating fraud and corruption is part of daily business. Capability - ensuring that the range of counter fraud measures deployed is appropriate to the range of fraud risks. Capacity - deploying the right level of resources to deal with the level of fraud risk. Competence - having the right skills and standards. Communication - raising awareness, deterring fraudsters, sharing information, celebrating successes. Collaboration - working together across internal and external boundaries: with colleagues, with other local authorities, and with other agencies; sharing resources, skills and learning, good practice and innovation, and information. In addition to the above, the CIPFA code of practice on managing the risk of fraud (see section 4) is there to support organisations putting in place counter fraud arrangements for the first time but will also be of benefit to those seeking to assess whether existing arrangements are adequate. Councillors may wish to ascertain whether the arrangements in their own council compare favourably with the recommended best practice approach. ## Useful Links Managing The Risk Of Fraud And Corruption www.cipfa.org/policy-and-guidance/ publications/c/code-of-practice-onmanaging-the-risk-of-fraud-and-corruptionguidance-notes-hard-copy In addition to the Code of Practice the Fighting Fraud and Corruption section of the CIPFA website provides a range of free resources to support councils in their fight against fraud, such as leaflets and posters and a good practice bank: www.cipfa.org/services/counter-fraud-centre/ fighting-fraud-and-corruption-locally 25 ## Section 6 What You Have Learned And Further Reading Now you have completed this workbook you have a good understanding of the fraud risks that affect councils and some of the methods that are used by authorities to prevent and detect fraud. You should now understand the scale of the problem and the impact that fraud can have on council finances. If you completed some of the activities, you will also have found out more about the arrangements that are in place in your own authority and assessed whether you think they are adequate. If you completed sections 5 and 6 you will now hopefully feel better equipped to support your authority in the fight against fraud and also be clear on what assurances you should be receiving as committee members. If you would like to explore this subject further there are a range of materials available for free to read on the CIPFA website: www.cipfa.org/services/counter-fraud-centre Other websites that you may find interesting and useful: www.actionfraud.police.uk - a really useful site where fraud can be reported and also information on fraud scams found. www.met.police.uk/docs/little_book_scam.pdf - an excellent and really useful publication to help individuals from being scammed; helpful to keep in GP's surgeries. www.cityoflondon.police.uk/advice-and-support/ fraud-and-economic-crime/Pages/default.aspx - the City of London Police Economic Crime Directorate is recognised as the national policing lead for fraud and is dedicated to preventing and investigating fraud at all levels. ## Suggested Answers For Page 14 Activity 1. Make a detailed note of everything the resident can tell you about the situation, names, addresses, etc. Take the contact details for the resident and pass everything to the fraud manager (if you have one) or the head of audit if not. 2. You should escalate your question to the appropriate corporate director, noting your concerns with regards to the current risk levels. 3. You should notify the councils monitoring officer 4. You should agree a project plan with the fraud manager or head of audit, with yourself as a figure head or spokesperson. You may wish to include a publicity campaign including posters and leaflets. If so, talk to your council's communications team. As a councillor, you will be in a good position to conduct radio and TV interviews, newspaper quotes and articles. You may wish to concentrate on a particular area of fraud that is particularly prevalent in your area. Local Government Association Local Government House Smith Square London SW1P 3HZ Telephone 020 7664 3000 Fax 020 7664 3030 Email info@local.gov .uk www.local.gov .uk For a copy in Braille, larger print or audio, please contact us on 020 7664 3000. We consider requests on an individual basis.
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# Beis Gender Pay Gap Report Report for the year 2018 ## © Crown Copyright 2019 This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk. Where we have identified any third-party copyright information you will need to obtain permission from the copyright holders concerned. Any enquiries regarding this publication should be sent to us at: enquiries@beis.gov.uk ## Contents Background _______________________________________________________________ 4 Organisational context _______________________________________________________ 4 The data - BEIS and the Executive Agencies _____________________________________ 5 Gender make-up of the organisation __________________________________________ 5 Bonus pay _______________________________________________________________ 5 Pay by quartiles __________________________________________________________ 6 The data - Core BEIS _______________________________________________________ 7 Core BEIS gender pay gap __________________________________________________ 7 Bonus pay _______________________________________________________________ 7 Closing the gender pay gap ___________________________________________________ 8 Our processes: recruitment, retaining and developing a diverse workforce _____________ 8 Performance management __________________________________________________ 9 Flexible working __________________________________________________________ 9 Learning and development __________________________________________________ 9 Working with the D&I networks ______________________________________________ 10 Our inclusive culture ______________________________________________________ 10 Next steps ______________________________________________________________ 11 Holding ourselves to account _______________________________________________ 11 Declaration _______________________________________________________________ 11 Annexes _________________________________________________________________ 12 Annex A - BEIS group figures (including Executive Agencies) _____________________ 12 Annex B - Core BEIS (excluding Executive Agencies)____________________________ 13 Annex C - Difference since last year _________________________________________ 16 ## Background The Department for Business, Energy and Industrial Strategy (BEIS) has prepared this report as part of the legal requirement for public authorities to publish their gender pay gap on an annual basis. In 2017, the government introduced world-leading legislation that made it statutory for organisations with 250 or more employees to report annually on their gender pay gap. Government departments are covered by the Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017 which came into force on 31 March 2017. These regulations underpin the Public Sector Equality Duty and require relevant organisations to publish their gender pay gap by 30 March annually. This includes the mean and median gender pay gaps; the mean and median gender bonus gaps; the proportion of men and women who received bonuses; and the proportions of male and female employees in each pay quartile. The gender pay gap shows the difference in the average pay between all men and women in a workforce. If a workforce has a particularly high gender pay gap, this can indicate there may be a number of issues to deal with, and the individual calculations may help to identify what those issues are. The gender pay gap is different to equal pay. Equal pay deals with the pay differences between men and women who carry out the same jobs, similar jobs or work of equal value. It is unlawful to pay people unequally because they are a man or a woman. BEIS supports the fair treatment and reward of all staff irrespective of gender. In October 2017 the new Civil Service Diversity and Inclusion Strategy was published. This important document sets out new programmes and initiatives to realise our ambition to become the UK's most inclusive employer by 2020. The Civil Service, including BEIS, wants to create a diverse and representative workplace - one that will attract talented people from all backgrounds, and give everyone, including those already working for us, the opportunity to achieve their potential. We also want to ensure that we reach our vision of 'an economy that works for everyone', at the same time as being a great place to work. This report fulfils the department's reporting requirements, analyses the figures in more detail and sets out what we are doing to close the gender pay gap in the organisation. ## Organisational Context We are looking to create a culture and way of working which is truly and actively inclusive of everyone. We want to make sure our decisions, internal and external processes and polices take D&I into account from the earliest of stages. Our ambition is to become a role model for business and the Civil Service; taking individual and collective action to ensure effective outcomes for everyone in the UK and make BEIS a great place to work for our colleagues and for ourselves. ## The Data - Beis And The Executive Agencies The Gender Pay Gap regulations require BEIS to include its five Executive Agencies in the published figures as they are not separate legal entities. The data published on GOV.UK therefore includes Core BEIS, Companies House, the Insolvency Service, the Intellectual Property Office, the Met Office, and the UK Space Agency. This report provides our gender pay gap, using the Government Equalities Office methodology, on the snapshot date of 31 March 2018. For bonuses, we used the period of 1 April 2017 to 31 March 2018, which was the 12 months preceding the snapshot date. ## Gender Make-Up Of The Organisation The gender make-up of the department and its Executive Agencies is **46% female** and 54% male. The Gender Pay Gap for BEIS including Executive Agencies is a **mean gap of 11%** and a median gap of 14%. This is lower than the **median gap (17.9%)** in 2018 across the whole economy as reported by the ONS. | Mean Pay Gap | Median Pay Gap | |-----------------|-------------------| | 11% | 14% | This is an improvement compared to last year when we reported a mean gap of 12% and a median gap of 15%. ## Bonus Pay The Gender Bonus Gap for BEIS including Executive Agencies is a **mean gap of 15%** and a median gap of 27%. | Mean Bonus Gap | Median Bonus Gap | |-------------------|---------------------| | 15% | 27% | Last year, we reported a mean gap of 12% and a median gap of 15%. ## Pay By Quartiles The combined quartiles for BEIS including Executive Agencies is shown below. There has been a significant reduction in the proportion of women in the lower quartile since last year (60% to 47%) and a similar rise in the proportion in the lower middle (46% to 59%). This has been partly offset, but not outweighed, by the increase in men in the upper middle (60% to 63%). There was a small decline in the proportion of men in the upper quartile (61% to 60%). The full set of data for BEIS and the Executive Agencies is at Annex A. ## The Data - Core Beis In order to understand the picture in more detail, this section of the report provides a focus on Core BEIS only and excludes the Executive Agencies within the BEIS family. Core BEIS has asked each Executive Agency to consider their own pay gap figures in more detail and to work with the department on a plan of action on gender pay within each agency. We will encourage our Executive Agencies to publish information on how they are acting to reduce gender pay gaps. ## Core Beis Gender Pay Gap The gender pay gap figures for Core BEIS are a **mean gap of 5%** and a **median gap of 13%**. This is a significant improvement on last year when we reported a mean gap of 9% and a median gap of 15%. When pay is compared by grade, the gap reduces further. ## Bonus Pay The bonus gap shows that there is a gap in favour of women using the median average but a gap in favour of men of 1% when using the mean. Women were also more likely to receive a bonus than men. The difference in figures between the mean and the median will be driven by the differing sizes of bonuses available to those in the SCS compared to other grades and the larger proportion of men in the SCS in the department. Last year, we reported a mean gap of 3% and a median gap of 0%. The full set of figures for Core BEIS and further analysis are set out in Annex B. Additional tables showing difference since last year can be found in Annex C. ## Closing The Gender Pay Gap According to our analysis the difference in grade distribution between males and females is likely to be the main driver of the overall BEIS GPG. BEIS is committed to continuing to reduce the overall gap and this is demonstrated through the following initiatives. ## Our Processes: Recruitment, Retaining And Developing A Diverse Workforce At BEIS, we abide with the Recruitment Principles of fair and open competition with candidates selection based on merit. We are accountable to the Civil Service Commission. To ensure fairness we use the following methods: - Mandatory mixed gender sift and interview panels. - Blind Sifting: where all identifiable characteristics are removed. - Use of specialist recruitment channels, such as VERCIDA, to advertise jobs at all levels and encourage a diverse pool of applicants. - We have started a 12-month subscription with Working Mums, a jobs board that advertises part time and flexible working for parents, with a focus on mothers. Our subscription includes a profile page about BEIS and positive advertisement of our flexible working policies. - Profile established on the Civil Service careers website that was checked for gender neutral tones and representation. - Introduction of a new recruitment method (Success Profiles) which has gone through rigorous equality analysis. The Success Profiles Framework moves recruitment away from using a purely competency-based system of assessment. It introduces a more flexible framework which assesses candidates against a range of elements using a variety of selection methods. This will give the best possible chance of finding the right person for the job, driving up performance and improving diversity and inclusion. The elements that can be assessed to find the best candidate for the role are: strengths, behaviours, technical, experience and ability. Early indicators suggest this has had a positive impact on gender outcomes. - We have held focus groups and workshops investigating how we can embed D&I strategies throughout out recruitment processes. - Advertise all jobs as available for flexible working, full-time, job share or part time unless this is a very strong business case not to. We are also working on: - We are in the process of acquiring an augmented advert writing tool to be used for all our adverts that improves diversity outcomes, gender tones and attraction. This will ensure we run a full equality assessment of all job adverts. - Exploring advertising BEIS jobs on women-focused job sites such as mumsnet.com and wherewomenwork.com ## Performance Management After an extensive consultation period and engagement with the organisation, we successfully implemented a new performance management approach in April 2018 which is intended to be better, simpler, fairer and more transparent. We worked with all important stakeholder groups, including discussing the approach with the trade unions and networks chairs, who were used as a sounding board whilst designing and shaping the new approach. The performance management approach sees a focus on good-quality conversations, with a real focus on development. Running alongside the new performance management approach is a new inyear reward system, and the two have allowed us to monitor diversity of outcomes on pay and performance more easily. We are also looking at introducing technology, including Artificial Intelligence, to further improve the Performance Management and In-Year Award processes. These products will help us to gather and analyse real-time data on the diversity of those who are being nominated and who are nominating awards. ## Flexible Working BEIS offers family friendly policies including flexible working, maternity, paternity and parental leave. We also offer job share, term-time and part time working, reduced hours and compressed hours opportunities. ## Shared Parental Leave The BEIS Shared parental leave policy was introduced in May 2017. Shared parental leave provide parents with the opportunity to share the care of their baby/child in the first year following birth/adoption, while balancing their work and retaining their link to the labour market. ## Learning And Development The department offers a range of support and development opportunities for women, including a Women's Network and a Senior Women's Group which provides peer support and opportunities to influence the department's decision making. BEIS also already offers a number of central cross-government talent and positive action schemes, two of which are specifically aimed at women: - Crossing Thresholds - a 12-month career mentoring programme for women to develop their career in a structured and supportive environment. The programme is aimed at AO-G6 staff and is delivered through facilitated modules, mentoring sessions, and peer support groups. - Positive Action Pathways - a scheme for those in under-represented groups, aimed at women, and also minority ethnic, disabled, and lesbian, gay, bisexual, and transgender (LGBT) staff in all grades from AA to G6. The 1 year programme consists of development workshops, action learning sets, and on-the-job learning. These programmes aim to overcome barriers and help women compete on equal footing for progression or other Civil Service talent schemes, e.g. the Future Leaders Scheme (FLS) and Senior Leaders Scheme (SLS), which are accelerated development schemes for high potential G7s and G6s (FLS) and Deputy Directors (SLS). BEIS promotes all cross-government talent schemes through the department's diversity networks, including the BEIS Women's Network's, to encourage those from under-represented groups to apply. In addition in 2018 BEIS has also launched two internal leadership development programmes: - Aspiring Leaders programme, aimed at HEOs and SEOs with the potential for progression but who have limited line management/leadership experience. - Interdepartmental Talent Partnership, aimed at Grade 6/7s with the potential and aspiration to the senior civil service. BEIS also has a comprehensive mentoring offer in place. This comprises: - Mentoring for all with an online tool to help individuals search for a mentor and/or register to act as a mentor. - Reverse mentoring. This form of mentoring is a joint HR and the Faith and Minority Ethnic (FAME) Network venture, where a person from an underrepresented group or background mentors a senior civil servant (SCS). - Pairing for performance. This matches a member of the SCS with an upward mentor, who observes their senior partner as they undertake their work and then offers insights. The programme provides mutual benefits. Mentors gain feedback skills they can employ in many situations, and mentees receive tailored, high-quality feedback on how they act and present themselves. All grades up to G7 are eligible to participate as mentors, and SCS volunteers are welcome. ## Working With The D&I Networks The diversity networks have played an incredibly important role in helping to deliver D&I activity across BEIS. Since the department's formation, the networks have shared the desire to celebrate difference and to improve the working lives of our people. The support networks include: Age Network, Carers Network, Capability Action Network, Domestic Violence, EU Nationals Network, LGBT+ Network, Faith and Minority Ethnic, Multi-Faith, Parental Support Network, Part-Time Workers Network, Schools Outreach, Social Mobility Network, Volunteering Network, Wellbeing and Mental Health Group and Women's Network. ## Our Inclusive Culture Inclusive By Design Pledges BEIS aims to embed D&I into all our key decisions on policy, procedure and process. Last year we asked all our directorates to make D&I pledges. They are a commitment to making diversity and inclusivity part of everything we do at BEIS - how we recruit, promote and retain staff, how we treat the people around us, and how we deliver what we do. The HR team is monitoring progress of the pledges and helping in making them a reality. ## Next Steps To inform our action plan for the GPG the D&I team reviewed the paper published by the Behavioural Insight Team (BIT) and the Government Equalities Office (GEO) as well as consulting with the BEIS GPG working group. As a result of our analysis we aim to improve our recruitment and talent policies and practices. We will monitor the outcomes through ongoing collaboration with the Women's Network. ## We Will: - Analyse our recruitment and talent data to ensure we offer effective support and development opportunities for underrepresented groups - Set up internal targets for women in SCS and G7/6 appointments. Equally we will aim to recruit more men into AO-EO roles - Implement behavioural and cultural changes (through our Inclusive by Design Programme). The Inclusive by Design Programme is a key activity committed to by the BEIS Diversity and Inclusion (D&I) Strategy 2017-2020. The project aims to improve BEIS decision making processes, making it less prone to bias. ## Holding Ourselves To Account We will analyse salary, talent and recruitment data to ensure we monitor the progress on reducing BEIS gender pay gap. We believe the above actions will improve recruitment and progression of women and will help BEIS to reduce the gender pay gap. ## Declaration We confirm that data reported by the Department for Business, Energy and Industrial Strategy is accurate and has been calculated according to the requirements and methodology set out in the Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017. ## Director General Corporate Services: Sarah Harrison Beis Permanent Secretary: Alex Chisholm Annexes Annex A - Beis Group Figures (Including Executive Agencies) Mandatory Gender Pay Gap Figures Snapshot Date 31/03/2018 ## Gender Pay Gap (In Favour Of Men): | Pay gap / Bonus gap | % | |-------------------------------------------------------------------------------------|----------| | Mean gender pay gap - Ordinary pay | 11% | | Median gender pay gap - Ordinary pay | 14% | | Mean gender pay gap - Bonus pay in the 12 months ending 31 March | 15% | | Median gender pay gap - Bonus pay in the 12 months ending 31 March | 27% | | The proportion of male and female employees paid a bonus in the 12 months ending 31 | | | March: | | | Employees | % | | Male | 83% | | Female | 84% | | Proportion of male and female employees in each quartile: | | | Quartile | Female % | | Lower quartile | | | 47% | 53% | | Lower middle quartile | | | 59% | 41% | | Upper middle quartile | | | 37% | 63% | | Upper quartile | | | 40% | 60% | * There are no contractors paid via the Core BEIS payroll and therefore no contractor information was available for these calculations. We intend to review the way we store information for this group of individuals to enable their data to be included in future publications. ## Annex B - Core Beis (Excluding Executive Agencies) In order to understand the picture in more detail, this annex to the report provides a focus on Core BEIS only and excludes the Executive Agencies within the BEIS family. As stated in the main report, Core BEIS has asked each Executive Agency to consider their own pay gap figures in more detail and to work with the department on a plan of action on gender pay within each agency. We will encourage our Executive Agencies to publish information on how they are acting to reduce gender pay gaps. ## Core Beis Gender Pay Gap BEIS uses Civil Service grades ranging from Administrative Officer to Senior Civil Servant and the figures in this report are based on these grades. Grades vary according to the level of responsibility that staff have. Each grade has a set pay range with pay gaps between grades. The gender pay gap figures for Core BEIS are a **mean gap of 5%** and a median gap of 13%. This is a significant improvement on last year when we reported a **mean gap of 9%** and a median gap of 15%. When pay is compared by grade, the gap reduces further. ## Bonus Pay This year, the department offered both in year and end year performance awards, as well as reward vouchers. Awards reflect exceptional performance either consistently across the year or for delivery of specific, short term, one off achievements. The value of the award is dependent on performance level and is irrespective of gender. The bonus gap shows that there is a gap in favour of women using the median average but a gap in favour of men of 1% when using the mean. Women were also more likely to receive a bonus than men. The difference in figures between the mean and the median will be driven by the differing sizes of bonuses available to those in the SCS compared to other grades and the larger proportion of men in the SCS in the department. Last year, we reported a **mean gap of 3%** and a **median gap of 0%**. ## Pay By Quartiles Women make up 54% of the lower quartile of BEIS pay and 45% of the upper quartile. As 47% of the department's staff are women this illustrates that the pay gap is largely as a result of a higher concentration of women in more junior grades. The department's Senior Civil Servants and Grade 6 posts are made up of 44% and 42% of women respectively, whereas women make up 51% and 59% of the most junior AO and EO grades. The full set of figures for Core BEIS is set out below. ## Gender Make-Up Of The Department | Grade | Number of women (% of | |-------------------------|--------------------------| | Number of men (% of men | | | (increasing | women who work in this | | who work in this grade) | | | seniority) | grade) | | AA/AO | | | 54 (2%) | 56 (2%) | | EO | | | 144 (4%) | 204 (6%) | | HEO/SEO/FS | | | 723 (21%) | 620 (18%) | | Grade 6/7 | | | 783 (23%) | 626 (18%) | | SCS | | | 126 (4%) | 100 (3%) | | managed) | | | Total | | | 1,830 | 1,606 | In comparison, this table shows the proportion of men and women at each grade in the civil service overall: | Grade | Number of women (% of | |-------------------------|--------------------------| | Number of men (% of men | | | (increasing | women who work in this | | who work in this grade) | | | seniority) | | | AA/AO | 63,465 (15%) | | EO | 47,806 (11%) | | HEO/SEO | 53,705 (12%) | | Grade 6/7 | 24,500 (6%) | | SCS | 3,152 (0.73%) | | Total | 198,420 | * All data from ONS's Civil Service Statistics 2018 as at 31/03/17. The data indicates the main reason for the gender pay gap is that there are proportionally more men in higher grades. This then feeds through to the pay gap figures due to the relatively high proportion of more senior grades in the Department compared to the Civil Service average. The Core Department (excluding agencies) had a gender split by grade as above on 31 March 2018. Women are over represented in more junior grades where pay is lower and under-represented in more senior grades. In addition, there seem to be more men in roles that attract additional pay allowances. These are offered where there is a particular issue with recruitment and retention, and the department cannot otherwise compete in the market. There are some areas where the gender balance of those receiving such enhancements is balanced but there are others where the mix is tilted towards one gender or the other. Overall though men are more likely to receive such an enhancement. Further work would be required to investigate this fully, but the initial evidence is that this is reflective of the wider employment market (for example, the need to recruit staff with expertise in Science, Engineering, Technology and Mathematics areas where there is a long recognised gender imbalance as well as a shortage of suitably qualified individuals). ## Annex C - Difference Since Last Year Beis Group Figures (Including Executive Agencies) Gender Pay Gap (In Favour Of Men): | Pay gap / Bonus gap | 2017 | 2018 | |-----------------------------|---------|---------| | Mean gender pay gap | 12% | 11% | | Median gender pay gap | 15% | 14% | | Mean bonus gender pay gap | 12% | 15% | | Median bonus gender pay gap | 15% | 27% | ## The Proportion Of Male And Female Employees Paid A Bonus: | Employees | 2017 | 2018 | |--------------|---------|---------| | Male | 80% | 83% | | Female | 76% | 84% | ## Proportion Of Male And Female Employees In Each Quartile Beis Group Figures (Including Executive Agencies) | | | Quartile | 2017 | 2018 | |-----------------------|--------|-------------|---------|---------| | | Female | Male | Female | Male | | Lower quartile | | | | | | 60% | 40% | 47% | 53% | | | Lower middle quartile | | | | | | 46% | 54% | 59% | 41% | | | Upper middle quartile | | | | | | 40% | 60% | 37% | 63% | | | Upper quartile | | | | | | 39% | 61% | 40% | 60% | | ## Core Beis Figures (Excluding Executive Agencies) Gender Pay Gap (In Favour Of Men): | Pay gap / Bonus gap | 2017 | 2018 | |-----------------------------|---------|---------| | Mean gender pay gap | 9% | 5% | | Median gender pay gap | 15% | 13% | | Mean bonus gender pay gap | 3% | 1% | | Median bonus gender pay gap | 0% | -5% | ## The Proportion Of Male And Female Employees Paid A Bonus: | Employees | 2017 | 2018 | |--------------|---------|---------| | Male | 71% | 73% | | Female | 71% | 77% | ## Proportion Of Male And Female Employees In Each Quartile Core Beis Figures (Excluding Executive Agencies) | | | Quartile | 2017 | 2018 | |-----------------------|--------|-------------|---------|---------| | | Female | Male | Female | Male | | Lower quartile | | | | | | 58% | 42% | 54% | 46% | | | Lower middle quartile | | | | | | 48% | 52% | 43% | 57% | | | Upper middle quartile | | | | | | 44% | 56% | 44% | 56% | | | Upper quartile | | | | | | 42% | 58% | 45% | 55% | | This publication is available from: www.gov.uk/government/publications/beis-gender-pay-gap-report-and-data-2018 If you need a version of this document in a more accessible format, please email enquiries@beis.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.
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Disclosure ref: 32 Sent: 17th June 2020 ## Freedom Of Information Act 2000 Request Review Into Prosecutions And Convictions Under The Coronavirus Act 2020 And The Health Protection Regulations Request I Am Writing To You Under The Freedom Of Information Act 2000 To Request The Following Information From The Crown Prosecution Service Regarding Its Recent Review Into Prosecutions And Convictions Under The Coronavirus Act 2020 And The Health Protection (Coronavirus Restrictions) Regulations. I am requesting the details of the 12 cases that were incorrectly charged under the Health Protection Regulations. 1. What was the specific charge in each case? 2. Why was the charge overturned? Response In response to the first part of your request the specific charge in each case are as follows: Three cases- Health Protection (Coronavirus Restrictions) (Wales) Regulations 2020 {8(1), 12(1) (b) & (4)} Five cases -Health Protection (Coronavirus, Restrictions) (England) Regulations 2020 {6 and 9(1) (b) & (4)} Two cases- Health Protection (Coronavirus) Regulations 2020 {4(1), 15(1) (a) and (5)} One case- Health Protection (Coronavirus, Restrictions) (England) Regulations 2020 {9 (2) & (4)} One Case- Health Protection (Coronavirus Restrictions) (Wales) Regulations 2020 {8 (1), 12(1) (b)& (4)} In response to the second part of your request, please see below which outlines the reasoning for each of the 12 cases, where the charge was overturned under the Health Protection Regulations. One case- Wrong Section of Regulations Three cases- Welsh Regulations in England Two cases - England Regulations in Wales Crown Prosecution Service, Information Access Team, Floor 8, 102 Petty France, London SW1H 9AJ United Kingdom www.cps.gov.uk Four cases- Homeless person Two cases- Regulations Repealed Information Management Unit 020 3357 0788 IMU@cps.gov.uk
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## Cabinet Member Presentations Report of the Leader of the Council Report of the Cabinet Member for Environment Report of the Cabinet Member for Community Engagement Report of the Cabinet Member for Finance Report of the Cabinet Member for Housing Report of the Cabinet Member for Regeneration, Enterprise & Planning ## Northampton Borough Council Date: 23 April 2012 I am pleased to inform everyone that Cllr Bottwood is now doing well having received hospital treatment following his heart attack last month. I am sure all members will join me in wishing him a full and speedy recovery and a quick return to the Guildhall. On 26th March we announced that the Borough Council is working with Local Government Shared Services (LGSS), the organisation set up to share services between Northamptonshire County Council and Cambridgeshire County Council, to explore the potential of joining the partnership. LGSS was set up more than a year ago to provide a wide range of support services for both local authorities. Since the establishment of LGSS, the two founding authorities have saved £11 million and to join the partnership could pave the way for savings for Northampton Borough Council in administration and other back office costs. The Borough Council is at an early stage in negotiations with LGSS and no decision has yet been made over which services could be included in any sharing agreement. LGSS provides a full range of back-office services, including IT, HR, finance, property and asset management and other services. The Northampton Alive Roadshow meetings have started with members of the Cabinet and myself going out and speaking to the public at a series of public meetings. The meetings map out how the major regeneration projects of the town fit together to attract investment, jobs and economic growth, and cover key projects like the Grosvenor/Greyfriars development, Northampton Waterside Enterprise Zone, Castle Station, St John"s and Avon Nunn Mills. On Tuesday 13th March the Guildhall was privileged to host a meeting of the Business Innovation and Skills Select Committee. This was a real vote of confidence from the Government in the work we are doing here in Northampton to attract investment, improve skills, create jobs and improve our local economy. I was pleased to attend the celebration on 21st March at Alliston Gardens Community Centre to mark the transfer of fifteen community centres to eight different community organisations. Improved relations between this authority and community groups has facilitated this transfer, which will in turn help to secure and improve these facilities for the future. Both the Skateboard Park at Midsummer Meadow, and the proposed University student accommodation at St Johns received planning consent on 3rd April, and construction will begin on both projects in the near future. On 23rd March TS Laforey was formally awarded the Freedom of the Borough of Northampton. This was undoubtedly a proud day for them, but it was also a pleasure for this Council to be able to recognise their positive contribution and dedication to the town. The Town and County Big Jubilee Picnic will take place from 12 noon to 6pm on Sunday 3rd June. The vintage-themed event will celebrate the foods, fashions and music of the Queen's 60-year reign, with the emphasis firmly on fun. The 2012 Olympic Torch will be passing through our town on the morning of 2nd July. This is a fantastic once in a lifetime event that I hope all members of the council will attend with the public to show their support and enjoy the occasion. The Flame will start its journey through the town from Weedon Road near Gambrel Road. It will be carried into the town centre via Bridge Street, Drapery, through the Market Square, Abington Street, past the Guildhall, down Guildhall Road, on to Victoria Promenade and through Becket's Park To mark the 200th Anniversary of the death of Spencer Perceval, The Mayor will be laying a wreath at the statue in a short ceremony at The Guildhall at 5.15pm on 11th May 2012. Northampton Youth Forum has been running a campaign to tackle hate crime since last summer, and have been awarded the Northamptonshire County Council and the Children and Young People's Partnership award for "Outstanding Contribution to Anti-Bullying Work", and has also recently been nominated for a National Diversity Award. I would like to give my congratulations to everyone who received Heart of the Community Awards this year. These awards give us the opportunity to acknowledge the hard work and dedication of residents who are working hard for their communities, and represent the best of our town. Community Safety The priorities and action plan for the Community Safety Partnership 2012/13 have been agreed. Key priorities for 2012/13 are Violent Crime, Serious Acquisitive Crime, Anti-Social Behaviour & Domestic Abuse. Priority location work to tackle serious acquisitive crime and help victims of burglary in hot spot locations continues. The main focus areas are Standens Barn, Bellinge, Spencer, Kings Heath, Kingsley/Phippsville, Abington The Mounts. Leaflets have been distributed to raise awareness of Designated Public Places Order (DPPO) in five Eastern/Central European languages to raise awareness of the Order. A further awareness event to support the "Killing with Kindness" campaign took place on the Market Square on 13th April to help raise awareness around street begging. A further two sessions of Domestic Abuse training for front line staff has been undertaken. A total of eight sessions have been run in Northampton this year with a total of 176 staff from NBC, NCC, Northants Police and NHS receiving the training. An Easter "E" message has been circulated to all students providing crime prevention advice and personal safety information in partnership with the University of Northampton. Our Town Centre car parks have again been recognised with the Park Mark® Safer Parking Award. The award has been renewed at 11 Northampton Borough Council car parks and shows the council is working hard to deliver safer parking. This, along with free parking and reduced parking charges in the Town Centre, is part of a wider plan to encourage shoppers into Northampton. An awareness raising campaign to tackle issues of vehicle crime began in April 2012, focussing on theft from vehicles and vehicle security. ## Junior Wardens Another four schools have signed up to join the junior community wardens scheme being championed by Northampton Borough Council and Northamptonshire Police. Pupils from Greenoaks Primary, Sunnyside Primary, Vernon Terrace Primary and Woodvale Primary will be trained over the next few months to become junior community wardens and take an active role in the community. The group of 131 children are following in the footsteps of pupils from four other schools who have successfully completed the ten-week course and graduated as junior community wardens. Legal Services The department has maintained its LEXCEL quality accreditation and achieved a 100% pass of its core requirement. The external inspector has also noted a number of areas of good practice within the service following a three-day inspection. LEXCEL is administered by the Law Society for England & Wales and is sought by many private Practice firms. Litigation Since 15th February 2012 the department has prosecuted or taken the following court action:  £350 fine plus £400 costs for cigarette dropping  Two Hygiene Emergency Prohibition Orders  Health and Safety cases resulting in £5,000 fine to a Director and £10,000 fine to a Company.  Two ASBOs for two years each, restricting the subject from entering a certain area in Duston and from causing harassment, alarm or distress to any person in the Borough of Northampton  Unauthorised subletting £475 costs  Five year ASBO to restrict entering an area and being found drinking in the street Benefit Fraud  Twelve month Conditional Discharge - £400 costs  60 hours unpaid work - £100 costs  (s112 SSAA 1992) 80 hours Community Work and £100 costs ## Commercial And Corporate Since the last report six Right to Buy sales have been completed, three TPOs have been confirmed and eight properties have been disposed of. The Stagecoach Agreement has also been completed in connection with the Greyfriars Bus Station. Councillor David Mackintosh Leader of the Council # Northampton Borough Council # Date: 23 April 2012 Environmental Services During the month of February, over 188 tonnes of food waste were collected. Once the service has had time to bed in, figures for participation levels and tonnages collected can be more accurately assessed. Environmental Health Campaign posters and lamppost stickers have been going up across the town as the council"s Neighbourhood Wardens start a three-month crackdown on dog owners who do not clear up after their pets. Verbal warnings, written warnings and Fixed Penalty Notices of £80, which if not paid could lead to a fine of up to £1,000, will be handed out to those spotted not clearing up their dog"s mess. Patrols will take place in known hotspots, initially offering advice to dog walkers on the correct disposal of dog waste, to then be followed up by targeted enforcement. The campaign will also appeal to the public to report incidents and problem areas to the council so that action can be taken. Licensing  A driver induction course was held on 19th March and was attended by twenty applicants.  Multi agency checks on vehicles were undertaken on 15th and 16th February and 15th and 22nd March.  The Prince of Wales public house has withdrawn its magistrate"s court appeal in relation to its license revocation.  The Taxi Age Limit consultation has now closed and the findings have been analysed. Final reports are being prepared to go before the Licensing Committee in early May.  Licensing Committee informed of Governments intention to introduce changes to Licensing Act within the Police Reform and Social Responsibility Bill on April 6th (although not confirmed).  The review and restructure of Licensing has now been completed. Carbon Management Around 40 representatives of small and medium sized businesses from in and around Northampton, attended an Energy Efficiency Breakfast on 1st March. This event, run in conjunction with the Carbon Trust provided straightforward advice and useful energy saving tips to help businesses reduce their carbon footprint and save money. Air Quality Management Areas Air quality in Northampton is improving with four areas of the town where traffic pollution had exceeded target levels now well within acceptable limits. On 18th April the Air Quality Management Area (AQMAs) status of Barrack Road, Park Avenue North, A45 (Riverside) and Lumbertubs Way was considered by Cabinet. The AQMAs were established after target levels for nitrogen dioxide, associated with traffic emissions, were exceeded. Our monitoring and assessment work has confirmed that traffic emissions and pollution levels in these four areas are now within acceptable limits. We intend to build on this and are currently developing an action plan outlining the steps we will be taking to further improve air quality in these parts of the Borough. Councillor John Caswell Cabinet Member for the Environment ## Cabinet Member Report For Community Engagement # Northampton Borough Council Date: 23 April 2012 Events The 2012 Olympic Torch route was announced on the 19th March and identifies the route moving from the west of the town, through the town centre and leaving in the east via Beckets Park. The Council will be contacting and meeting with businesses and partners affected by the route. The Council has organised meetings with school coordinators and is working with Northamptonshire County Council to ensure as many local school children as possible are able to watch this once in a lifetime opportunity. The Torch relay is one of a number of significant events being planned for the town centre and our parks and open spaces this summer. Other national events coming to the town include Godiva Awakes, Lion Heart and Games Time, as well as regional and local events like Race 4 Life, Music Festival, Diwali, Olympic Sports and the Jubilee Party and others. We want Northampton to be the venue of choice for people to visit this summer. The Town and County Big Jubilee Picnic will be Northampton's main Jubilee event and will take place from 12noon to 6pm on Sunday 3rd June and will begin with a short outdoor service at All Saints' Church followed by a procession to Delapre Park and Abbey. The vintage-themed event will celebrate Her majesty"s reign with the foods, fashions and music of the last sixty years, and people are invited to bring along their own Jubilee or vintagethemed picnics, or to visit the Jubilee pub and food court while they enjoy six hours of fun and entertainment. The Big Jubilee Picnic has been organised by Northampton Borough Council and Northamptonshire County Council, and will be hosted by HM Lord Lieutenant of Northamptonshire, Lady Juliet Townsend LVO. The event will also be supported by a number of local partners and businesses. The Jubilee Street Parties pack has been launched, offering advice & guidance for anyone wishing to hold their own street party. The deadline for applications is the 4th May. Culture & Heritage Arts Council England have confirmed £119,100 of transition funding for 2012- 13. The money will be used to provide additional activity around the Cultural Olympiad "World at your feet" exhibition and other business improvement initiatives. Museum The newly refurbished Museum and Art Gallery is on target to be officially launched on 12th April, with preview tours between 4th and 11th April. Neighbourhood Working The current Junior Wardens programme has now concluded. The "graduation ceremony" will take place on 18th April and a new programme will start after Easter. Joint working with the Police and Sheltered Housing has resulted in a new Sector office being established in South-West Sector at Spencer Haven following the closure of Gladstone Road. A major public event was held in the Guildhall on 11th April to celebrate the achievements of Change of Scene participants. Community Centres A celebration took place to mark the transfer of 15 community centres to eight different community organisations on 21st March. The event at Alliston Gardens Community Centre saw around 40 members of management groups gathered to mark this new beginning The centres and their new management groups are:  Community Spaces Northampton is managing Bellinge, Briar Hill, Kingsthorpe, Rectory Farm, Southfields, Standens Barn and Vernon Terrace community centres.  Alliston Gardens and Semilong community centres are being managed by Alliston Gardens Youth and Community Centre  St James community centre is being managed by the Doddridge Centre  Spencer Dallington centre is being managed by Deafconnect  Camp Hill centre is being managed by its established management committee  Kings Heath centre is being managed by the Need to Know Centre Northampton  Abington community centre is being managed by its established management committee  Pastures centre is being managed by its established management committee Customer Services Annual Billing for Council Tax in March is traditionally the busiest time for Customer Services staff and this years performance in relation to call handling and visitors was exceptional due to effective resource allocation and proactive planning. The Customer Services and Council Tax Teams worked seamlessly together to support customers effectively through this very busy period. ## Community Governance Review The Borough Wide Community Governance Review (Cgr) Has Continued Through March With Various Community Information Events, Including:  Central Area Board briefing  Community briefings at Lings Forum, the Guildhall and in the Grosvenor Centre  Forum briefings at LGBTQ, Diverse Communities, Pensioners and Youth  CGR briefing at Parklands Residents Association  CGR consultation at Wootton & East Hunsbury Parish Council Seven CGR petitions have been set up by Councillors, which are available on the Borough Council website. The deadline for petitions is 27th April 2012, and hundreds of signatures have already been received and validated against the electoral register. After the consultation has ended any proposals will be subject to a referendum and consideration by Full Council and implemented at the local elections in May 2013. Partnership Fund 23 local charities and community groups have been given a total of £550,000 through our Partnership Fund to help them continue their positive work in our town"s communities. At this time it is more important than ever that the Borough Council supports these organisations to make our town a better place. Northampton Leisure Trust The Sport Relief Mile took place at Becketts Park on Sunday 25th March with over twenty Northampton Leisure Trust volunteers assisting on the day. The event was well attended with around 1,300 people taking part. Membership sales are continuing to do well and are currently 5% up against the same time in 2011. Trilogy memberships are at an all time record high of 6796, along with swimming lesson enrolments which are at 2033. After 3.5 years the 'Eastfield and Spencer Sport and Physical Activity Project' funded by Sport England and a range of partners finished in February 2012. The Project has exceeded all targets set by Sport England. The Big Lottery funded 'Northampton Improved Places for Play' programme finished at the end of March 2012. The Play Development Team have exceeded all of the targets set during the 3.5 years the programme was in place and has been hailed a huge success. Northampton Borough Council, Northampton Leisure Trust and the County Sports Partnership have joined together to introduce Parkrun at the Racecourse every Saturday morning. Parkrun is a national initiative which provides weekly free 5km runs, and allows competitors to record their 5km times online and compare their times nationally. Councillor Brandon Eldred Cabinet Member for Community Engagement Local Government Shared Services (LGSS) Northampton Borough Council is in the early stages of negotiations with LGSS, the organisation set up to share services between Northamptonshire County Council and Cambridgeshire County Council, to explore the potential of joining the partnership. LGSS was set up more than a year ago to provide a wide range of support services for both local authorities. Since the establishment of LGSS, the two founding authorities have saved £11 million and to join the partnership could pave the way for savings for Northampton Borough Council in administration and other back office costs. LGSS provides a full range of back-office services, including IT, HR, finance, property and asset management and legal, and has proved that it can deliver cutting edge services in a way that enormously reduces costs and allows members to focus on frontline services Finance We have now completed the financing for the buy out of the Housing Revenue account. The buy out was compulsory and as a result will mean the Council now self - finances its stock of social housing and retains the rental income collected each year. As we approach year-end we are preparing our financial management system for the production of the end of year statutory reports. These reports and other work completed during year-end will ensure we meet our statutory obligations. A meeting of Chief Finance Officers took place during the week commencing 26th March and discussed some of the Localisation reforms impacting on our financial management, and a meeting of councillors from across the county is also planned. In particular the localisation of Council Tax support, business rates retention and Council Tax discount reform were reviewed. Revenues and Benefits During March the service successfully produced and dispatched year end Council Tax bills and benefit notifications, which involved the production and processing of over 100,000 documents. As we move towards year - end we will complete the final work required to closedown the 2011/12 financial year and prepare the system for 2012 / 13. Work - loads within benefits increased in February and March, following the implementation of a new national system called ATLAS 2. We have already implemented the first phase of ATLAS, which saw changes to tax credits being loaded straight into our benefits system. The second phase picks up all changes to national benefits. Duplication and early problems with the data being received requires a review in order to ascertain if a change is required. Improvements to the system are expected following the completion of year - end. The next phase of our citizen account was completed at the beginning of March. This phase allows benefit recipients to review details of their claim online, and to review notifications electronically instead of receiving paper copies through the post. This is another step in offering the widest range of access channels to our customers and reducing costs for the Council. We are continuing to contact and offer support to benefit recipients impacted by reductions in housing benefit. In March we sent further correspondence detailing the changes and highlighting where people need to come for help. On 19th March a local resident was pleaded guilty at Northampton Magistrates Court to claiming over £4,000 in benefits she was not entitled to following an investigation by Northampton Borough Council's benefit fraud team. Northampton Borough Council will continue to take action against anyone who steals money intended to help the town's most vulnerable residents by cheating the system to get benefits they are not entitled to. Facilities Management The refurbishment of the Jeffrey Room has been completed. The new design and technology available in the Jeffrey Room will ensure that public and private meetings can run as smoothly and comfortably as possible. Two events in March worthy of note were the visit of the Business Innovation and Skills Committee and the launch of Northampton Alive. The Councils facilities team successfully supported these high profile events. ICT The Capital Project to upgrade Microsoft Office and Exchange has started. This is an essential upgrade to a critical piece of software which supports efficient services to our customers. A trial of technology which supports Councillors and staff to securely access council e-mail and calendars from any smart phone has now finished. The feedback was overwhelmingly positive and the business case recommends its roll-out to support more flexible working. The Website improvement project is underway. The team are currently reviewing website content to ensure that it is focussed on the tasks and information that our customers most often need to access. Councillor Alan Bottwood Cabinet Member for Finance # Northampton Borough Council Date: 23 April 2012 Northampton Borough Council has secured nearly £150,000 from the new Preventing Repossessions Fund to help struggling homeowners. Northampton has received the 12th largest allocation in the country, which will be used to offer small interest-free loans of less than £5,000 to those at real risk of losing their homes, or grants to help ease debt pressures and give them a chance to get back on top of their finances. The right advice and support on managing debts is crucial for homeowners who are struggling financially, and this funding will be a lifeline to those who are facing the threat of having their homes repossessed. Empty Homes Funding The Council has been awarded £1.9m to bring 105 empty properties back into use as affordable housing. This was the 11th highest funding awarded in the country. The programme to deliver the 105 properties will happen in stages over a three-year period from April 2012 to March 2015. Properties need to meet the criteria of being privately owned and vacant for more than six months. There are currently around 900 properties that fall into this category in Northampton. The council is currently identifying the 105 properties suitable for the scheme and these are likely to range from flats to family houses in different areas of Northampton. Once finished, rents will be set according to the government's new Affordable Homes programme at 80% of market rents, and the properties will be allocated to people with housing needs on the council's housing register. Property Maintenance Operatives Following a successful pilot of Personal Desktop Assistants (PDAs) the devices are to be rolled out to all housing operatives working in voids and repairs. Use of these devices will significantly reduce the amount of paper used as all jobs would be received and completed via the device, it will also enhance customer service as we will be able to communicate and reschedule works whilst the operatives are out in the field. The devices will reduce the need for the operatives to visit the depot as frequently, as they will be able to work direct from home, reducing lost time, mileage and fuel usage which will have a positive effect on environmental issues and also lower costs. De-pooling The rent notices for 2012/13 were sent out to all tenants and for the first time included details about the costs of the services they receive. Housing staff worked in partnership with Contact Centre staff to deal with the anticipated queries. Less than 50 queries were initially received but there will of course continue to be queries raised about the rent and service charges throughout the year. Tenancy Sustainment Contract In order to address low-level anti-social behaviour and other less serious breaches of tenancy conditions the Council has formally adopted a Tenancy Sustainment Contract, which is believed is the first of its kind. The contract will last for a period of 6 months but may be extended by mutual consent. It allows an achievable action plan to remedy the breach, formally recorded by the caseworker and monitored at agreed intervals. The contract is voluntary. If a tenant agrees to sign the contract then they are bound by its terms and understand that if the breach is not remedied then the Council reserve the right to commence legal proceedings. The contract can be used as evidence to demonstrate that we have attempted to work with the tenant. If the tenant refuses to sign the contract then similarly this can be used in evidence if necessary at a later date. The contract will be particularly beneficial for those tenants identified as vulnerable as it would allow for the tenant to commit to regular engagement with identified support services and to set out achievable actions aimed at remedying the breach, ensuring a greater likelihood of sustaining a tenancy that may have otherwise failed. Consultation There will be extensive consultation on a number of new and revised strategies and changes to policies such as allocations and homelessness as a result of the introduction of the Localism Act. Mary Markham Cabinet Member for Housing Town Centre Operations In February 2012, 12,627 visitors took advantage of the one-hour free parking in our pay-on-foot multi-story car parks an increase of 2.8% in comparison with January 2012. To date around 54,000 visitors/shoppers have taken advantage of the free parking offer. The number of visitors and shoppers taking advantage of the reduced 1 & 2 hour parking in the Town centre increased by 11.8% (in excess of 6,000 vehicles) in comparison with 2011 parking figures. The standardisation of car parks will be introduced by late May to enable all legislative processes to be undertaken in accordance with statutory requirements. The council continues to work closely with market traders and local businesses around the market square to help promote and build the market and Town Centre as a venue for visitors and shoppers alike. Market Advisory Group Raymond Everall, a well known local businessman, has been appointed as the independent chair of the Market Advisory Group. Northampton Town Centre Limited (BID) The BID has signed an agreement with Northamptonshire Police to provide a PCSO with specific responsibility for the BID area and the Police will provide a second PCSO to match the BID"s investment. This agreement runs from 1st April 2012 - 31st March 2013 and will be reviewed on an annual basis. The BID has partnered with the Northampton Retail Crime Initiative (NRCI) in joint funding two Town Centre Rangers to help businesses, support visitors & shoppers and provide a more welcoming experience to the town. The BID will be supporting new projects and initiatives in the town centre including Northampton in Bloom, Safari Northampton, Christmas, refurbishing street furniture, enhanced cleaning, marketing & promotion as well working with the Borough and County Councils on local matters. High Street Innovation Fund On 29th March the Government announced that Northampton would be one of nine towns and cities in the East Midlands to receive £100,000 of funding for high street improvements following the Portas Review. We are working with the BID and other partners to explore the best ways of using these funds. St James Local Development Order On 7th March Cabinet approved the creation of a Local Development Order for the St James area of the town. The Development Order will help simplify the planning process for businesses looking to build or upgrade facilities in St James, and is a key factor in making our Enterprise Zone a success. Delapre Abbey Members of the public were offered the rare opportunity to look inside the Delapre Abbey on 17th and 18th March as part of a bid by the Friends of Delapre Abbey to raise donations towards its restoration, which is being led by Northampton Borough Council with support from the Friends of Delapre Abbey and the Delapre Preservation Trust. Bus Interchange Work has started to prepare land around the site of the proposed new bus interchange that would allow for the future development of the land. Plans for the town's new bus interchange are due to be submitted soon. A week long exhibition to show the public how the results of the previous consultation exercise influenced the design was held in the One Stop Shop during the week commencing 16th April. If the Planning Application is approved, the Borough Council, County Council and WNDC will have the green light to start work on a brand new bus interchange starting in the late summer. Northampton Arts Collective vacated the Fish Market site by the due date (31 March) to enable new bus interchange proposals to come forward, and they will move into their new premises in Guildhall Road shortly. We are grateful to NAC for their co-operation throughout the process. Delapre Bell Tower and Clock The historic belltower and clock at Delapre Abbey has now been lifted back into place on the roof of the stable block following a full restoration programme to put the clock back into working order for the first time in 20 years. The roofing work has been carried out by local company Moulton Roofing, while the restoration of the clock and wind vane has been undertaken by specialist company Smith of Derby. Delapre Abbey is Northampton Borough Council"s key heritage project and this on-going programme of work is intended to bring more of the building back into public use as well as to safeguard it for the future. Abington Park Lake Work to fix the footpath that circles the middle boating lake in Abington Park and underpin the concrete beam that provides its supporting surround began on 26th March. For almost two years a 40-metre stretch of the path has been fenced off because of subsidence due to fluctuating water levels that has washed away some of the material under the lakeside footpaths. The Environment Agency, which has been instructing Northampton Borough Council on the project, has said that now is the best time to undertake the work, and we will be working with the both the Environment Agency and contractors to make sure that disruption is kept to a minimum. Planning and Regeneration The proposed University student accommodation at St Johns received planning consent on 3rd April. Construction is expected to commence in June/July, with completion and occupation in January 2014. This will be the first major development on site in the Waterside Enterprise Zone which came into force officially on 1st April. The Skateboard Park at Midsummer Meadow received planning consent on the 3rd April. Construction is expected to be completed in mid-August. Two new neighbourhood planning projects have been granted front-runner status by DCLG for Spring Boroughs and Blackthorn Good Neighbours. These projects receive £20K each to enable them to work with the Council on neighbourhood planning. The Stage 2 transfer of planning powers from WNDC was successfully completed on 31st March. NBC now has all its planning powers back from WNDC, but will continue to work closely with the Development Corporation on the regeneration of the Town Centre. The Northampton Alive exhibition is to be held in the Great Hall during the week commencing 23rd April. The exhibition is to show the progress on the regeneration of the Town Centre, to provide more information about the individual projects. Officers will be on hand to answer questions and provide information. Presentations at residents groups, Forums and the University have been successful in showing the overall vision for the regeneration of the town centre. The dedication of land for St John highways infrastructure has been exchanged with the County Council. Waterside Enterprise Zone Three expressions of interest bids for the Growing Places Fund for Enterprise Zone infrastructure and development proposals have been agreed by the SEMLEP Board to be considered at final stage in the Spring. A marketing advisor for the Enterprise Zone has been appointed. This is an important position as high quality marketing of the Enterprise Zone will be essential to ensure the required level of inward investment. SEMELP received an additional £6m growing places funding from central government during March. NEP also received additional funds and we are working with both to maximise the benefit for Northampton. Councillor Tim Hadland Cabinet Member for Regeneration, Enterprise and Planning
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## Administrative Data Taskforce What is the Administrative Data Taskforce (ADT)? The Administrative Data Taskforce (ADT) was established in December 2011 following an announcement by the Minister for Universities and Science, David Willetts. The taskforce was tasked to report to the Government on ways to enable and promote the wider use of administrative data for research and policy purposes. Who sat on it? The Taskforce was chaired by Sir Alan Langlands (HEFCE) and supported by Paul Boyle (ESRC). It consisted of representatives from the departments with the largest administrative datasets like HMRC, Department of Health and Department for Work and Pensions as well as academics, the Office for National Statistics and other experts. Their report builds on earlier work on this issue, for instance the 2008 Data Sharing Review by Richard Thomas and Mark Walport. What was the outcome? Three working groups were set up to report back to the Taskforce on; the legal & ethical issues; public engagement; and models of data access. A series of workshops were held involving HMRC representatives, their counterparts in other departments and outside experts. The outcome of the working groups was the publication of the report Administrative Data: Improving Access for Research and Policy, released in December 2012. ## What Are The Recommendations From The Adt Report? The Adt Report Makes Five Recommendations: a. An Administrative Data Research Centre (ADRC) should be established in each of the four countries in the UK; b. Single UK-wide researcher accreditation built on best national and international practice; c. Legislation should be enacted to facilitate research access to administrative data and to allow data linkage between departments to take place more efficiently; d. A strategy for engaging with the public should be instituted; e. Sufficient funds should be put in place to support improved research access to and linkage between administrative data. What would the approach suggested by the taskforce involve? The approach being recommended by the Administrative Data Taskforce, would in principle allow datasets to be linked across government in a secure manner that would preserve anonymity. The key components of this are a transparent governance process involving data controllers from each department, accreditation of researchers to consistent standards whether they are from academia or government, safe research environments with data security up to at least the level government departments use, and control of research outputs to ensure that the risk of deliberate or accidental disclosure of personal information is very low indeed. Developments since the ADT report Following publication of the report, the Economic and Social Research Council (ESRC) established a Technical Group to progress plans for the proposed Administrative Data Research Network (ADRN). This group looked into the practical issues of setting up the ADRN and made some further recommendations on the establishment of four (England, Northern Ireland, Scotland and Wales) Administrative Research Data Centres (ADRCs) co-ordinated by an administrative data information coordinating body, the Administrative Data Service (ADS). The four ADRCs and ADS are currently being procured by the ESRC, with the aim to have an Administrative Research Network set up in autumn 2013. Read-across to the current HMRC consultation If HMRC were given a general power to share anonymised individual level data for research and statistical purposes, this would remove the need for the creation of specific legal gateways for each new requirement - a process that can be resource intensive and difficult to schedule in an already heavily subscribed parliamentary/legislative calendar. It would therefore go some way to addressing the recommendation above that legislation should be enacted to facilitate research access to administrative data and to allow data linkage between departments to take place more efficiently. In undertaking any wider sharing of its data, HMRC would need to ensure that any risks of identification of personal or confidential data were minimised, as is already achieved in the HMRC Datalab (see separate briefing paper). The ADT report makes a number of recommendations about how to achieve that, including anonymisation of data, use of trusted third parties to link the data, use of state of the art safe environments with levels of security commensurate with the sensitivity of the data, accreditation of researchers using the data, and disclosure control on research and statistical outputs. The Administrative Data Research Network and associated governance framework would enable HMRC to ensure that decisions on wider sharing of its data were made in a transparent fashion and that the data sharing and access were accomplished safely.
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| SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | REF. | |------------------------------------------|--------------------------------|--------------------------------|-------------------------------|--------------|-----------|--------| | ADVANCE ENVIRONMENTAL | N'Hood & Env. Health Services | At. Poll. (Enforce & Mon) | Air Quality Analysis | 30/10/2014 | 2,450.00 | 122224 | | ALLPAY LIMITED DIRECT DEBIT ACCOUNT | Finance, Efficiency & Assets | Banking Charges | Transaction Costs - All Pay | 09/10/2014 | 1,419.75 | 121184 | | ALL TAYLOR MADE | Partnerships & Corp. Services | Chair & V-Chair Of The Council | Hospitality | 23/10/2014 | 520.00 | 121984 | | ANCHORPRINT GROUP LIMITED | Health Improvement & Leisure | Local Sports Alliance | Publicity & Promotion | 07/10/2014 | 285.00 | 120571 | | ANCHORPRINT GROUP LIMITED | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Publicity & Promotion | 21/10/2014 | 260.73 | 121632 | | ANCHORPRINT GROUP LIMITED | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Publicity & Promotion | 21/10/2014 | 477.05 | 121971 | | ANCHORPRINT GROUP LIMITED | Partnerships & Corp. Services | Community Development | Other Partnership Support | 30/10/2014 | 2,133.98 | 122316 | | APP USER GROUP | Leader | Performance Management | Seminars & Short Training | 03/10/2014 | 220.00 | 120857 | | AUDIT COMMISSION | Finance, Efficiency & Assets | Benefit Fraud | National Anti Fraud Incentive | 08/10/2014 | 2,200.00 | 121300 | | BLABY PARISH COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 09/10/2014 | 1,237.00 | 121302 | | BLABY & WHETSTONE YOUTH CLUB LTD | Community Services | Comm Safety - Substance Abuse | Other Equipment | 22/10/2014 | 242.65 | 121990 | | BLABY & WHETSTONE YOUTH CLUB LTD | Health Improvement & Leisure | Local Sports Alliance | Hire Of Rooms | 08/10/2014 | 240.00 | 121297 | | BRAUNSTONE TOWN COUNCIL | Partnerships & Corp. Services | Customer Services | Rent Payments | 16/10/2014 | 11,068.00 | 121612 | | BROOK STREET UK LIMITED | N'Hood & Env. Health Services | Building Control Division | Temporary/Casual Staff | 30/10/2014 | 264.05 | 122281 | | BROOK STREET UK LIMITED | Partnerships & Corp. Services | Local Land Charges | Gross Pay | 16/10/2014 | 295.13 | 121412 | | BROOK STREET UK LIMITED | Partnerships & Corp. Services | Local Land Charges | Gross Pay | 21/10/2014 | 307.70 | 121600 | | BROOK STREET UK LIMITED | Partnerships & Corp. Services | Local Land Charges | Gross Pay | 21/10/2014 | 325.97 | 121601 | | BROOK STREET UK LIMITED | Partnerships & Corp. Services | Local Land Charges | Gross Pay | 22/10/2014 | 257.92 | 121908 | | BROOK STREET UK LIMITED | Partnerships & Corp. Services | Local Land Charges | Gross Pay | 30/10/2014 | 334.85 | 122240 | | CANON (UK) LTD | Partnerships & Corp. Services | Reprographics | Print Mats (Int. Print Room) | 21/10/2014 | 212.40 | 121979 | | CANON (UK) LTD | Partnerships & Corp. Services | Reprographics | Printroom Copy Charge | 23/10/2014 | 1,193.74 | 121917 | | CAPITA BUSINESS SERVICES LIMITED | Partnerships & Corp. Services | Customer Services | Software Maintenance | 21/10/2014 | 265.00 | 120864 | | CAPITA BUSINESS SERVICESLTD | Finance, Efficiency & Assets | Banking Charges | Transaction Costs - Cards | 22/10/2014 | 1,489.33 | 121910 | | CAPITA TREASURY SOLUTIONS LIMITED | Finance, Efficiency & Assets | Interest On Investments | Hired Services | 16/10/2014 | 3,500.00 | 121702 | | CENTRAL DOG CONTROL | N'Hood & Env. Health Services | Control Of Dogs | Small Misc Contracts | 08/10/2014 | 6,850.00 | 120835 | | CHEMPAC SOLUTION LIMITED | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Protective Clothing/Uniforms | 16/10/2014 | 253.00 | 121645 | | CIVICA UK LIMITED | Leader | Performance Management | Seminars & Short Training | 21/10/2014 | 500.00 | 121925 | | CIVICA UK LIMITED | Leader | Performance Management | Surveys | 30/10/2014 | 4,000.00 | 122318 | | CLOCKWISE | Other | General Fund Balance Sheet | Deductions - Clockwise | 23/10/2014 | 560.00 | 121996 | | CLOUD 9 FACE PAINTING | Health Improvement & Leisure | Active Together (Oper Funding) | Hired Services | 30/10/2014 | 240.00 | 122279 | | COMMUNITY ACTION PARTNERSHIP | Partnerships & Corp. Services | Grant Aid & Access Activities | Grants - Cabd | 30/10/2014 | 2,855.25 | 122267 | | COMMUNITY ACTION PARTNERSHIP | Partnerships & Corp. Services | Youth Council | Hired Services | 30/10/2014 | 4,095.96 | 122276 | | CONNEXION 2 | Other | General Fund Balance Sheet | Control A/C - Solo Protect | 21/10/2014 | 701.80 | 121194 | | CORNFLOWERS CATERING | Partnerships & Corp. Services | Community Development | Hospitality | 01/10/2014 | 210.00 | 120845 | | COUNTY ENGRAVING UK | Other | General Fund Balance Sheet | Creditors - Dep-Citizen Of Yr | 16/10/2014 | 212.00 | 121197 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | REF. | |-----------------------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|-----------|--------| | DAISY COMMUNICATIONS LIMITED | Partnerships & Corp. Services | Ict Services | Telecoms - Calls | 09/10/2014 | 1,131.31 | 121159 | | DENNIS EAGLE LTD | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Accidental Damage Repair Costs | 07/10/2014 | 253.35 | 121202 | | DENNIS EAGLE LTD | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 16/10/2014 | 740.28 | 121256 | | DENNIS EAGLE LTD | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 16/10/2014 | 211.34 | 121261 | | DENNIS EAGLE LTD | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 21/10/2014 | 379.39 | 121659 | | DENNIS EAGLE LTD | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 21/10/2014 | 379.39 | 121672 | | DENNIS EAGLE LTD | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 30/10/2014 | -300.00 | 122219 | | DENNIS EAGLE LTD | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 30/10/2014 | 300.00 | 120271 | | DENNIS EAGLE LTD | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 30/10/2014 | 308.15 | 121992 | | DERBYSHIRE NOTTINGHAMSHIRE CHAMBER OFCOMMERCE | Planning, Econ. Dev. & Housing | Economic Development | Project/Initiatives Fees | 09/10/2014 | 430.00 | 121284 | | D H PEPPER & SON | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Composting Fees | 21/10/2014 | 7,044.43 | 121295 | | DISCLOSURE & BARRING SERVICE | Other | General Fund Balance Sheet | Misc - Criminal Records Bureau | 09/10/2014 | 357.00 | 121183 | | DISTINCTIVE PUBLISHING LIMITED | Planning, Econ. Dev. & Housing | Economic Development | Publicity & Promotion | 03/10/2014 | 240.00 | 120901 | | DODGE THIS | Health Improvement & Leisure | Local Sports Alliance | Grants - Sportivate | 30/10/2014 | 420.00 | 122278 | | DOG SQUAD | N'Hood & Env. Health Services | Control Of Dogs | Small Misc Contracts | 16/10/2014 | 669.50 | 121182 | | ELECHECK EST LIMITED | Finance, Efficiency & Assets | Council Offices & Land | Cyc: Emergency Light Testing | 30/10/2014 | 391.05 | 119489 | | ELECHECK EST LIMITED | Finance, Efficiency & Assets | Council Offices & Land | Cyc: Portable Appliance Tests | 30/10/2014 | 1,692.36 | 121972 | | ENDERBY PARISH COUNCIL | Finance, Efficiency & Assets | Open Spaces Management | Parish Councils | 16/10/2014 | 712.28 | 121597 | | ENVTEC SERVICES LTD | Finance, Efficiency & Assets | The Pavillion - Land And Build | Pla: Heating And Ventilation | 03/10/2014 | 2,017.88 | 120904 | | EQUIPMENT TRADE CONSULTANTS LTD | Other | General Fund Balance Sheet | In Year Capital Additions | 16/10/2014 | 3,694.10 | 121698 | | ESPO | Finance, Efficiency & Assets | Council Offices & Land | Gas | 16/10/2014 | 273.00 | 121595 | | ESPO | Finance, Efficiency & Assets | The Pavillion - Land And Build | Gas | 30/10/2014 | 250.01 | 121602 | | FAITHFUL & GOULD | Other | General Fund Balance Sheet | In Year Capital Additions | 30/10/2014 | 26,275.72 | 121223 | | FAROL LIMITED | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Running Costs | 07/10/2014 | 338.67 | 120915 | | FAROL LIMITED | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Running Costs | 21/10/2014 | 865.70 | 121657 | | FAROL LIMITED | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Running Costs | 21/10/2014 | 585.60 | 121936 | | FIRMSTEP | Partnerships & Corp. Services | Communications | Software Maintenance | 22/10/2014 | 6,200.00 | 122002 | | FIVE COUNTIES AUTOMATION LTD | Finance, Efficiency & Assets | Littlethorpe Depot | Rea: Building | 16/10/2014 | 598.00 | 121410 | | FORD & SLATER | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 07/10/2014 | 538.99 | 121246 | | GAP PROPERTY SERVICES LEICESTER LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 01/10/2014 | -3,085.00 | 120920 | | GENERAL TELECOM | Finance, Efficiency & Assets | Council Offices & Land | Pla: Electrical | 31/10/2014 | 230.00 | 122508 | | GHM PLANNING LTD | Planning, Econ. Dev. & Housing | Planning Delivery | Gross Pay | 01/10/2014 | 2,300.00 | 120667 | | GHM PLANNING LTD | Planning, Econ. Dev. & Housing | Planning Delivery | Gross Pay | 16/10/2014 | 5,060.00 | 121215 | | GLADSTONE MRM | Health Improvement & Leisure | The Pavilion | Computer Infrastructure | 30/10/2014 | 2,260.00 | 122217 | | GLEN PARVA PARISH COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 22/10/2014 | 735.00 | 121899 | | GLEN PARVA PARISH COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 22/10/2014 | 377.50 | 121900 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | REF. | |---------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|-----------|--------| | GLEN PARVA PARISH COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 22/10/2014 | 276.00 | 121901 | | GMB | Other | General Fund Balance Sheet | Deductions - Gmbatu | 01/10/2014 | 233.88 | 120868 | | GMB | Other | General Fund Balance Sheet | Deductions - Gmbatu | 30/10/2014 | 238.06 | 122299 | | GREENERGY FUELS LIMITED | Other | General Fund Balance Sheet | Fuel | 07/10/2014 | 18,730.80 | 120898 | | GREENERGY FUELS LIMITED | Other | General Fund Balance Sheet | Fuel | 16/10/2014 | 18,618.70 | 121635 | | GREENWORKS SOLUTIONS LIMITED | Finance, Efficiency & Assets | Council Offices & Land | Cyc: Vending Contracts | 30/10/2014 | 672.75 | 121651 | | GROUNDSMAN TOOLS & SUPPLIERS | N'Hood & Env. Health Services | Grounds Maintenance Service | Running Costs | 22/10/2014 | 253.50 | 122014 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 06/10/2014 | 656.03 | 120836 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 06/10/2014 | 675.00 | 120837 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 08/10/2014 | 646.76 | 121166 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 08/10/2014 | 676.53 | 121168 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 16/10/2014 | 674.52 | 121618 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 16/10/2014 | 646.76 | 121624 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 21/10/2014 | 534.69 | 119463 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 22/10/2014 | 329.22 | 121915 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 22/10/2014 | 282.54 | 121916 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 22/10/2014 | 646.76 | 121918 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 30/10/2014 | 688.77 | 122214 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 30/10/2014 | 282.53 | 122215 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 30/10/2014 | 646.76 | 122216 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 30/10/2014 | 545.67 | 122232 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 30/10/2014 | 282.53 | 122233 | | HAYS SPECIALIST RECRUITMENT | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 30/10/2014 | 653.29 | 122234 | | HEALTH MANAGEMENT LIMITED | Leader | Human Res. Train & Development | Occupational Health | 30/10/2014 | 550.45 | 122205 | | HINCKLEY & BOSWORTH COUNCIL | Partnerships & Corp. Services | External Legal Fees | Legal Fees | 21/10/2014 | 4,810.40 | 121969 | | HINCKLEY & BOSWORTH COUNCIL | Partnerships & Corp. Services | Local Land Charges | Hinckely & Bosworth Prop Seach | 16/10/2014 | 2,072.60 | 121278 | | HINCKLEY & BOSWORTH COUNCIL | Planning, Econ. Dev. & Housing | Local Development Framework | Consultant'S Fees | 01/10/2014 | 5,478.83 | 120681 | | HUNTERS ESTATE AGENTS | Finance, Efficiency & Assets | Council Offices & Land | Pla: Stock Condition Surveys | 22/10/2014 | 1,593.75 | 121975 | | IAN PICKERING PHOTOGRAPHY | Other | General Fund Balance Sheet | Creditors - Dep-Citizen Of Yr | 21/10/2014 | 375.00 | 121650 | | IDOX SOFTWARE LIMITED | N'Hood & Env. Health Services | Environmental Health | Seminars & Short Training | 30/10/2014 | 2,500.00 | 122077 | | IDOX SOFTWARE LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 30/10/2014 | 5,000.00 | 122076 | | INDUSTRIA PERSONNEL SERVICE LTD | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Temporary/Casual Staff | 01/10/2014 | 226.80 | 120863 | | INDUSTRIA PERSONNEL SERVICE LTD | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Temporary/Casual Staff | 07/10/2014 | 378.00 | 121259 | | INDUSTRIA PERSONNEL SERVICE LTD | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Temporary/Casual Staff | 16/10/2014 | 378.00 | 121656 | | INDUSTRIA PERSONNEL SERVICE LTD | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Temporary/Casual Staff | 21/10/2014 | 378.00 | 121940 | | INDUSTRIA PERSONNEL SERVICE LTD | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Temporary/Casual Staff | 30/10/2014 | 378.00 | 122271 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | REF. | |------------------------------------------|--------------------------------|-------------------------------|--------------------------------|--------------|-----------|--------| | INFORM CPI LIMITED | Finance, Efficiency & Assets | Nndr Billing & Coll Costs | Sundry It Purchases | 16/10/2014 | 500.00 | 120473 | | INPLACE PERSONNEL LIMITED | N'Hood & Env. Health Services | Grounds Maintenance Service | Temporary/Casual Staff | 16/10/2014 | 223.68 | 121653 | | INPLACE PERSONNEL LIMITED | N'Hood & Env. Health Services | Grounds Maintenance Service | Temporary/Casual Staff | 16/10/2014 | 372.80 | 121654 | | INPLACE PERSONNEL LIMITED | N'Hood & Env. Health Services | Grounds Maintenance Service | Temporary/Casual Staff | 21/10/2014 | 372.80 | 121965 | | INPLACE PERSONNEL LIMITED | N'Hood & Env. Health Services | Grounds Maintenance Service | Temporary/Casual Staff | 30/10/2014 | 372.80 | 122274 | | INSTANT CLEANING UK | Finance, Efficiency & Assets | Council Offices & Land | Temporary/Casual Staff | 16/10/2014 | 1,725.75 | 121753 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Cleansing Services | Temporary/Casual Staff | 16/10/2014 | 949.05 | 121649 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Cleansing Services | Temporary/Casual Staff | 21/10/2014 | 1,240.80 | 121948 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Cleansing Services | Temporary/Casual Staff | 30/10/2014 | 840.40 | 122295 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Cleansing Services | Temporary/Casual Staff | 31/10/2014 | 906.40 | 122501 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Grounds Maintenance Service | Temporary/Casual Staff | 16/10/2014 | 342.00 | 121649 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Grounds Maintenance Service | Temporary/Casual Staff | 30/10/2014 | 352.00 | 122295 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Temporary/Casual Staff | 08/10/2014 | 1,365.85 | 121407 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Temporary/Casual Staff | 16/10/2014 | 1,410.75 | 121649 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Temporary/Casual Staff | 21/10/2014 | 844.80 | 121948 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Temporary/Casual Staff | 30/10/2014 | 704.00 | 122295 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Temporary/Casual Staff | 07/10/2014 | 2,256.19 | 121241 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Temporary/Casual Staff | 09/10/2014 | 2,300.27 | 121406 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Temporary/Casual Staff | 21/10/2014 | 669.70 | 121944 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Temporary/Casual Staff | 21/10/2014 | 1,585.45 | 121944 | | JAM PERSONNEL MIDLANDS LIMITED | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Temporary/Casual Staff | 30/10/2014 | 2,360.05 | 122296 | | JIGSAW COUNSELLING | Partnerships & Corp. Services | Lpc - Commissioning | Grants - Cabd | 31/10/2014 | 360.00 | 122510 | | JOE TURNER EQUIPMENT LIMITED | N'Hood & Env. Health Services | Highway Cyclic Main Ptnership | Running Costs | 21/10/2014 | 480.00 | 121667 | | KINGS ARMOURED SECURITY SERVICES LIMITED | N'Hood & Env. Health Services | Car Parks | Security Services | 16/10/2014 | 270.92 | 121189 | | KINGS ARMOURED SECURITY SERVICES LIMITED | Partnerships & Corp. Services | Customer Services | Security Services | 30/10/2014 | 503.08 | 122313 | | LAFARGE AGGREGATES LIMITED | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Commercial Waste Fees | 16/10/2014 | 375.71 | 121677 | | LEGAL & GENERAL ASSURANCE SOCIETY | Other | General Fund Balance Sheet | Recharging - Insurance Premium | 09/10/2014 | 4,190.60 | 121216 | | LEICESTER CITY COUNCIL | Planning, Econ. Dev. & Housing | Economic Development | Project/Initiatives Fees | 30/10/2014 | 8,000.00 | 122303 | | LEICESTER MARRIOTT HOTEL | Other | General Fund Balance Sheet | Creditors - Dep-Citizen Of Yr | 09/10/2014 | 4,434.83 | 121286 | | LEICESTERSHIRE CAB | Community Services | Resident Support | Provision Amounts | 01/10/2014 | 3,195.00 | 120914 | | LEICESTERSHIRE COUNTY COUNCIL | Health Improvement & Leisure | Corporate Health Improvement | Hired Services | 22/10/2014 | 350.00 | 121985 | | LEICESTERSHIRE COUNTY COUNCIL | Health Improvement & Leisure | Leisure Development - Sports | Laa | 01/10/2014 | 6,348.00 | 120840 | | LEICESTERSHIRE COUNTY COUNCIL | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Commercial Waste Fees | 09/10/2014 | 5,410.36 | 121281 | | LEICESTERSHIRE COUNTY COUNCIL | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Commercial Waste Fees | 22/10/2014 | -2,707.93 | 121896 | | LEICESTERSHIRE COUNTY COUNCIL | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Commercial Waste Fees | 30/10/2014 | 2,707.93 | 121981 | | LEICESTERSHIRE COUNTY COUNCIL | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Commercial Waste Fees | 31/10/2014 | 4,332.32 | 122523 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | REF. | |---------------------------------------------------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|------------|--------| | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | Creditors -County-Superann Ees | 01/10/2014 | 134,857.37 | 120832 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | Creditors -County-Superann Ees | 30/10/2014 | 134,518.61 | 122251 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | Creditors-County-Superann Memb | 01/10/2014 | 1,210.82 | 120832 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | Creditors-County-Superann Memb | 30/10/2014 | 1,210.82 | 122251 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 01/10/2014 | 2,520.00 | 120917 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 16/10/2014 | 4,050.00 | 121695 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 16/10/2014 | 2,523.17 | 121696 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 16/10/2014 | 5,105.00 | 121697 | | LEICESTERSHIRE COUNTY COUNCIL | Other | General Fund Balance Sheet | In Year Capital Additions | 30/10/2014 | 4,025.00 | 122310 | | LEICESTERSHIRE COUNTY COUNCIL | Partnerships & Corp. Services | Local Land Charges | Lcc Fees | 21/10/2014 | 1,652.00 | 121598 | | LEICESTERSHIRE COUNTY COUNCIL | Partnerships & Corp. Services | Local Land Charges | Lcc Fees | 21/10/2014 | 1,839.00 | 121599 | | LEICESTERSHIRE COUNTY COUNCIL | Partnerships & Corp. Services | Local Land Charges | Lcc Fees | 30/10/2014 | 1,750.00 | 122282 | | LEICESTERSHIRE COUNTY COUNCIL | Partnerships & Corp. Services | Local Land Charges | Lcc Fees | 30/10/2014 | 2,277.00 | 122283 | | LEICESTERSHIRE COUNTY COUNCIL | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 08/10/2014 | 532.00 | 121301 | | LEICESTERSHIRE COUNTY COUNCIL | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 08/10/2014 | 644.78 | 121304 | | LEICESTERSHIRE COUNTY COUNCIL | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 22/10/2014 | 3,387.20 | 121987 | | LEICESTERSHIRE COUNTY COUNCIL | Planning, Econ. Dev. & Housing | Economic Development | Professional Fees | 08/10/2014 | 15,000.00 | 120902 | | LEICESTERSHIRE COUNTY COUNCIL | Planning, Econ. Dev. & Housing | Economic Development | Publicity & Promotion | 21/10/2014 | 620.00 | 121693 | | LOCAL WORLD LIMITED | Planning, Econ. Dev. & Housing | Planning Delivery | Advertising - Notices | 03/10/2014 | 367.20 | 120880 | | LOCAL WORLD LIMITED | Planning, Econ. Dev. & Housing | Planning Delivery | Advertising - Notices | 16/10/2014 | 244.80 | 121634 | | LOCAL WORLD LIMITED | Planning, Econ. Dev. & Housing | Planning Delivery | Advertising - Notices | 22/10/2014 | 432.22 | 121993 | | LODGE KENNELS | N'Hood & Env. Health Services | Control Of Dogs | Kenneling Fees | 16/10/2014 | 2,536.00 | 121222 | | LODGE TYRES CO LTD | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Accidental Damage Repair Costs | 07/10/2014 | 747.00 | 121282 | | LODGE TYRES CO LTD | N'Hood & Env. Health Services | Vehicle Maintenance | Tyres | 16/10/2014 | 1,343.00 | 121249 | | LYRECO | Community Services | Community & N'Hood Services | Stationery | 09/10/2014 | 388.45 | 121156 | | MACILDOWIE ASSOCIATES LIMITED | Leader | Recruitment Costs | Staff Advertising | 21/10/2014 | 6,000.00 | 121296 | | MANTA SHOPFITTERS LTD | Other | General Fund Balance Sheet | In Year Capital Additions | 30/10/2014 | -6,661.00 | 121909 | | MAST INTERNATIONAL GROUP LIMITED | Leader | Staff Training And Development | Hired Services | 01/10/2014 | 3,327.90 | 120838 | | MAST INTERNATIONAL GROUP LIMITED | Leader | Staff Training And Development | Hired Services | 09/10/2014 | 3,361.33 | 121285 | | MAYBO TRAINING | Leader | Staff Training And Development | Hired Services | 07/10/2014 | 874.00 | 121263 | | MAYBO TRAINING | Leader | Staff Training And Development | Hired Services | 30/10/2014 | 500.00 | 122275 | | MISS J E CLARK | Community Services | Homelessness | Homelessness | 30/10/2014 | 900.00 | 122312 | | NLA MEDIA ACCESS | Partnerships & Corp. Services | Communications | Publicity & Promotion | 08/10/2014 | 593.00 | 120269 | | NORTH WEST LEICESTERSHIRE DISTRICT COUNCIL Finance, Efficiency & Assets | Internal Audit | Other Local Authorities | 22/10/2014 | 12,771.88 | 121913 | | | NORTH WEST LEICESTERSHIRE DISTRICT COUNCIL Planning, Econ. Dev. & Housing | Local Development Framework | Consultant'S Fees | 23/10/2014 | 7,000.00 | 121986 | | | NOTTINGHAM CITY COUNCIL | Planning, Econ. Dev. & Housing | Development Strategy | Seminars & Short Training | 08/10/2014 | 315.00 | 121191 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | REF. | |-------------------------------------------------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|-----------|--------| | NOTTINGHAM CITY COUNCIL | Planning, Econ. Dev. & Housing | Planning Delivery | Seminars & Short Training | 08/10/2014 | 315.00 | 121191 | | NOTTINGHAM COMMUNITY HOUSING ASSOCIATION Community Services | Homelessness | Homelessness | 30/10/2014 | 1,000.00 | 122363 | | | OADBY & WIGSTON BOROUGH COUNCIL | Health Improvement & Leisure | Change For Life Project | Hire Of Rooms | 07/10/2014 | 248.40 | 121255 | | OADBY & WIGSTON BOROUGH COUNCIL | Health Improvement & Leisure | Change For Life Project | Hire Of Rooms | 30/10/2014 | 276.00 | 122266 | | OCE FINANCE | Partnerships & Corp. Services | Reprographics | Printroom Equipment Rental | 23/10/2014 | 3,406.77 | 120482 | | ONE STOP PROMOTIONS LIMITED | Health Improvement & Leisure | Community Improvements | Publicity & Promotion | 16/10/2014 | 278.50 | 121633 | | PEN GREEN RESEARCH, TRAINING & DEVELOPMENTPartnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 16/10/2014 | 3,375.00 | 121623 | | | PEN GREEN RESEARCH, TRAINING & DEVELOPMENTPartnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 22/10/2014 | 675.00 | 121914 | | | P&MM LIMITED - DIRECT DEBIT ONLY | Other | General Fund Balance Sheet | Deductions - Childcare Voucher | 16/10/2014 | 2,876.00 | 121603 | | POLYCOPY | Partnerships & Corp. Services | Reprographics | Print Mats (Int. Print Room) | 01/10/2014 | 468.90 | 120697 | | PREMIER SECURITY SERVICES | Finance, Efficiency & Assets | Blaby Joint Service Shop | Security Services | 07/10/2014 | 552.08 | 121211 | | PREMIER SECURITY SERVICES | Finance, Efficiency & Assets | Council Offices & Land | Security Services | 07/10/2014 | 552.08 | 121208 | | PREMIER SECURITY SERVICES | Finance, Efficiency & Assets | Littlethorpe Depot | Security Services | 07/10/2014 | 552.08 | 121209 | | PREMIER SECURITY SERVICES | Finance, Efficiency & Assets | The Pavillion - Land And Build | Security Services | 30/10/2014 | 552.08 | 119827 | | PREMIER SECURITY SERVICES | Finance, Efficiency & Assets | The Pavillion - Land And Build | Security Services | 30/10/2014 | 552.08 | 121206 | | PREMIER SECURITY SERVICES | N'Hood & Env. Health Services | Grounds Maintenance Service | Security Services | 07/10/2014 | 912.51 | 121210 | | PRICE WATERHOUSE COOPERS LLP | Finance, Efficiency & Assets | External Audit Fees | Audit Fees | 23/10/2014 | 12,078.00 | 122013 | | PRICE WATERHOUSE COOPERS LLP | Finance, Efficiency & Assets | External Audit Fees | Audit Fees | 30/10/2014 | 3,512.00 | 122362 | | PRINT UK | Leader | Register Of Electors | Hired Services | 09/10/2014 | 1,042.28 | 121219 | | PRINT UK | Leader | Register Of Electors | Hired Services | 09/10/2014 | -252.00 | 121220 | | PRINT UK | Leader | Register Of Electors | Postages | 09/10/2014 | 1,154.44 | 121218 | | QUADRANT EVENTS LTD | Other | General Fund Balance Sheet | Creditors - Dep-Citizen Of Yr | 21/10/2014 | 3,160.20 | 121411 | | R E BRADSHAW | Other | General Fund Balance Sheet | In Year Capital Additions | 30/10/2014 | 3,885.00 | 122366 | | RICHARD SIMMONS LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 30/10/2014 | 7,765.00 | 122365 | | RICOH UK LIMITED | Partnerships & Corp. Services | Reprographics | Mfd Copy Charge | 21/10/2014 | 251.94 | 119506 | | RISING STARS MULTI-SPORTS LTD | Health Improvement & Leisure | Change For Life Project | Hired Services | 16/10/2014 | 600.00 | 121661 | | RISING STARS MULTI-SPORTS LTD | Health Improvement & Leisure | Leisure Development - Sports | Hired Services | 16/10/2014 | 850.00 | 121660 | | RVS GROUP | Partnerships & Corp. Services | Reprographics | Printing Equipment | 16/10/2014 | 625.00 | 120479 | | SAFE START HOME SAFETY | Partnerships & Corp. Services | Lpc - Home Safety(Nhs Funding) | Hired Services | 07/10/2014 | 355.00 | 121262 | | SCARAB SWEEPERS LIMITED | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 21/10/2014 | 368.30 | 121952 | | SERVICESPORT UK LIMITED | Health Improvement & Leisure | The Pavilion | Other Equipment | 01/10/2014 | 350.00 | 120903 | | SEVERN TRENT WATER | Finance, Efficiency & Assets | Trad Services - Whet Ind Est | Water Charges | 30/10/2014 | 310.91 | 121234 | | SEVERN TRENT WATER | N'Hood & Env. Health Services | Car Parks | Water Charges | 16/10/2014 | 310.91 | 121225 | | SEVERN TRENT WATER | N'Hood & Env. Health Services | Car Parks | Water Charges | 16/10/2014 | 221.79 | 121226 | | SEVERN TRENT WATER | N'Hood & Env. Health Services | Car Parks | Water Charges | 16/10/2014 | 583.69 | 121227 | | SEVERN TRENT WATER | N'Hood & Env. Health Services | Car Parks | Water Charges | 16/10/2014 | 310.91 | 121229 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | REF. | |------------------------------------------|--------------------------------|--------------------------------|--------------------------------|--------------|-----------|--------| | SEVERN TRENT WATER | N'Hood & Env. Health Services | Car Parks | Water Charges | 16/10/2014 | 310.91 | 121231 | | SEVERN TRENT WATER | N'Hood & Env. Health Services | Car Parks | Water Charges | 16/10/2014 | 995.38 | 121232 | | SHORTLAND PARSLEY | Finance, Efficiency & Assets | Trad Services - Whet Ind Est | Management Fees | 09/10/2014 | 1,566.88 | 121288 | | SI SPORTS LIMITED | Community Services | Community Dev. - Youth Issues | Project/Initiatives Fees | 21/10/2014 | 270.00 | 121932 | | SITEIMPROVE LIMITED | Leader | Performance Management | Applications - Business | 21/10/2014 | 1,533.94 | 121921 | | SOUTHERN ELECTRIC | Finance, Efficiency & Assets | Council Offices & Land | Electricity | 09/10/2014 | 2,358.46 | 121403 | | SOUTHERN ELECTRIC | Finance, Efficiency & Assets | The Pavillion - Land And Build | Electricity | 30/10/2014 | 1,084.76 | 120480 | | SOUTHERN ELECTRIC | Finance, Efficiency & Assets | The Pavillion - Land And Build | Electricity | 30/10/2014 | 999.45 | 121907 | | SOUTH LEICESTERSHIRE COLLEGE | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 07/10/2014 | 5,252.20 | 121248 | | SOUTH LEICESTERSHIRE COLLEGE | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 08/10/2014 | 315.70 | 121169 | | SOUTH LEICESTERSHIRE COLLEGE | Partnerships & Corp. Services | Lpc - Commissioning | Lpc Expenditure | 22/10/2014 | 1,733.33 | 121974 | | SPALDINGS UK LIMITED | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 30/10/2014 | 277.22 | 122241 | | STONBURY LIMITED | Other | General Fund Balance Sheet | In Year Capital Additions | 16/10/2014 | 60,013.60 | 121699 | | SYSTON FENCING COMPANY LIMITED | Finance, Efficiency & Assets | Open Spaces Management | Open Space Development | 03/10/2014 | 880.00 | 120895 | | THE FACTORY OF FUN | Health Improvement & Leisure | Community Improvements | Publicity & Promotion | 30/10/2014 | 350.00 | 122235 | | THE KNOWLEDGE ACADEMY | Health Improvement & Leisure | Health And Recreation | Seminars & Short Training | 22/10/2014 | 895.00 | 122078 | | THE PRUDENTIAL ASSURANCE COMPANY LIMITED | Other | General Fund Balance Sheet | Deductions - Avc | 23/10/2014 | 2,986.78 | 121995 | | THE SPORTSWEB.COM | Health Improvement & Leisure | The Pavilion | Gross Pay | 01/10/2014 | 343.18 | 120905 | | THE SPORTSWEB.COM | Health Improvement & Leisure | The Pavilion | Gross Pay | 01/10/2014 | 686.35 | 120906 | | THE SPORTSWEB.COM | Health Improvement & Leisure | The Pavilion | Gross Pay | 01/10/2014 | 414.40 | 120907 | | THE SPORTSWEB.COM | Health Improvement & Leisure | The Pavilion | Gross Pay | 01/10/2014 | 433.83 | 120908 | | TRAPEZE GROUP LIMITED | N'Hood & Env. Health Services | Fleet Management | Software Maintenance | 16/10/2014 | 3,938.93 | 120680 | | UNISON | Other | General Fund Balance Sheet | Deductions - Unison | 01/10/2014 | 399.15 | 120869 | | UNISON | Other | General Fund Balance Sheet | Deductions - Unison | 30/10/2014 | 404.60 | 122302 | | UNITY RECOVERY SERVICE LIMITED | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 30/10/2014 | 239.28 | 122244 | | UNIVERSITY HOSPITALS OF LEICESTER | Finance, Efficiency & Assets | Council Offices & Land | Pla: Heating And Ventilation | 30/10/2014 | 621.00 | 120841 | | UNTAPPED ME C.I.C | Partnerships & Corp. Services | Lpc - Commissioning | Misc Fees | 08/10/2014 | 294.60 | 121217 | | UNTAPPED ME C.I.C | Partnerships & Corp. Services | Lpc - Commissioning | Misc Fees | 08/10/2014 | 521.61 | 121217 | | VENN GROUP LTD | Finance, Efficiency & Assets | C.Tax Billing, Coll & Recovery | Temporary/Casual Staff | 22/10/2014 | 919.45 | 121912 | | VMI BLACKBURN LIMITED | Health Improvement & Leisure | The Pavilion | Water&Vending Hire & Purchases | 08/10/2014 | 255.96 | 121275 | | VODAFONE LIMITED | Partnerships & Corp. Services | Ict Services | Telecoms - Internal | 21/10/2014 | 2,564.92 | 121922 | | VODAFONE LIMITED (CORPORATE) | Community Services | Community & N'Hood Services | Telephones (Mobile/Pagers) | 30/10/2014 | 210.09 | 122304 | | VODAFONE LIMITED (CORPORATE) | N'Hood & Env. Health Services | Environmental Health | Telephones (Mobile/Pagers) | 30/10/2014 | 217.22 | 122304 | | VODAFONE LIMITED (CORPORATE) | N'Hood & Env. Health Services | Refuse Coll & Domestic Recyc | Telephones (Mobile/Pagers) | 30/10/2014 | 548.41 | 122304 | | WARD WADAWAY | N'Hood & Env. Health Services | Environmental Health | Advertising - Notices | 01/10/2014 | 312.75 | 120833 | | WESTCOTES FLOORING COMPANY | Finance, Efficiency & Assets | Council Offices & Land | Rea: Building | 30/10/2014 | 275.00 | 121957 | | SUPPLIER NAME | PORTFOLIO | COST CENTRE | EXPENDITURE CLASS | POST. DATE | AMOUNT | REF. | |---------------------------------|--------------------------------|--------------------------------|----------------------------|--------------|----------|--------| | WHETSTONE JUNIORS FOOTBALL CLUB | Health Improvement & Leisure | Local Sports Alliance | Grants - Sports | 09/10/2014 | 364.00 | 121160 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 07/10/2014 | 1,262.57 | 121203 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 16/10/2014 | 435.11 | 121638 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 16/10/2014 | 528.12 | 121701 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 21/10/2014 | 1,426.48 | 121943 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 30/10/2014 | 998.21 | 122227 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 31/10/2014 | 242.82 | 122498 | | WHISTL NORTH LIMITED | Other | General Fund Balance Sheet | Misc - Postage Meter - Tnt | 31/10/2014 | 552.73 | 122499 | | XMA LIMITED | Leader | Human Resources Emp Provisions | Computer Equipment | 21/10/2014 | 1,766.61 | 121244 | | XMA LIMITED | Leader | Human Resources Emp Provisions | Computer Equipment | 31/10/2014 | 2,355.48 | 122489 | | XMA LIMITED | Partnerships & Corp. Services | Ict Services | Desktop - Printers | 21/10/2014 | 225.79 | 121196 | | XMA LIMITED | Partnerships & Corp. Services | Ict Services | Desktop - Printers | 31/10/2014 | 225.00 | 121959 | | XMA LIMITED | Partnerships & Corp. Services | Ict Services | Desktop - Workstations | 03/10/2014 | 313.05 | 120553 | | XMA LIMITED | Partnerships & Corp. Services | Ict Services | Desktop - Workstations | 21/10/2014 | 547.40 | 121958 | | ZOELLER SYSTEMS LIMITED | N'Hood & Env. Health Services | Vehicle Maintenance | Normal Repairs | 31/10/2014 | 211.95 | 122487 | | TOTAL: | 762,230.56 | | | | | |
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## Online Platforms And Digital Advertising Market study interim report You may reuse this information (not including logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit www.nationalarchives.gov.uk/doc/open-governmentlicence/ or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.goue sharv.uk. The Competition and Markets Authority has excluded from this published version of the market study report information which it considers should be excluded having regard to the three considerations set out in section 244 of the Enterprise Act 2002 (specified information: considerations relevant to disclosure). The omissions are indicated by []. [Some numbers have been replaced by a range. These are shown in square brackets.] [Non-sensitive wording is also indicated in square brackets.] Initial findings .................................................................................................... 273 7. Views on a market investigation reference ....................................................... 275 8. Next steps ......................................................................................................... 280 This consultation ............................................................................................... 280 The next six months .......................................................................................... 283 ## ## ## Appendices A: The legal framework B: A summary of responses to our statement of scope C: Market outcomes D: Profitability of Google and Facebook E: The role of data F: Consumer control over data collection G: Evidence on consumers' attitudes and behaviour H: Intermediation in digital advertising I: Potential practices to be tackled through a code of conduct J: Potential interventions in general search K: Potential interventions in social media L: Potential approaches to improving personal data mobility M: Potential interventions in digital advertising Glossary ## Summary Platforms funded by digital advertising provide highly valuable services, allowing us to find information in an instant and connect with family and friends from around the world - all at no direct cost to the consumer. Google and Facebook are the largest such platforms by far, with over a third of UK internet users' time online spent on their sites. Google enjoys a more than 90% share of the £6 billion search advertising market in UK, while Facebook has a share of almost 50% of the £5 billion display advertising market. Both companies have been highly profitable for many years. Both Google and Facebook grew by offering better products than their rivals. However, we are concerned that they are both now so large and have such extensive access to data that potential rivals can no longer compete on equal terms. These issues matter to consumers. If competition in search and social media is not working well, this can lead to reduced innovation and choice in the future and to consumers giving up more data than they feel comfortable with. Weak competition in digital advertising can increase the prices of goods and services across the economy and undermine the ability of newspapers and others to produce valuable content, to the detriment of broader society. We are consulting on a range of potential interventions to improve competition in these markets, including: a code of conduct to govern the behaviour of platforms with market power; rules to give consumers greater control over their data; and interventions to address the sources of the market power of Google and Facebook (including data access remedies, measures to increase interoperability and structural interventions). We welcome views from stakeholders on the issues we have identified and the potential interventions we are considering. ## Introduction 1. This is the interim report in our market study into online platforms and digital advertising. The report provides an update on the work we have carried out, highlights our emerging findings and ongoing lines of inquiry and sets out, for consultation, our initial views on the concerns that we have identified and potential interventions to address them. 2. Digital advertising plays an important role in the provision of hugely valuable services and content to consumers, including internet search, social media and news journalism. Consumers typically do not pay directly for these services - rather, platforms and publishers finance them by using consumers' attention and data to sell targeted digital advertising. In turn, for a wide range of firms, from the largest conglomerate to the local café, digital advertising provides a highly effective method of delivering adverts that are relevant to consumers, helping to drive brand awareness and sales. 3. The main types of digital advertising are search advertising, in which sponsored ads are provided in response to users' search queries, and display advertising, in which static or video ads are displayed alongside the content a user is interested in. Currently, Google dominates search advertising while Facebook has a strong position in display advertising. Alongside the owned and operated platforms of Google and Facebook there is also an 'open display market' in which publishers such as online newspapers compete in real time to sell advertising inventory to a wide range of advertisers. Each of these forms of digital advertising requires a relevant ad to be selected and served to an individual consumer in a fraction of a second - an extraordinary technological feat that was not possible only a few years ago. ## Scope And Objectives 4. This study aims to inform the debate on the regulation of online platforms, as explored in the recent Furman1 and Stigler Center2 reviews. These reviews each concluded that new approaches needed to be taken to regulating platforms, that relying solely on enforcing existing competition law was not sufficient and that introducing pro-competitive rules and regulations was necessary. Government is currently considering its response to the Furman Review. 5. Digital advertising provides the substantial majority of the revenues of some of the largest platforms in the world including Google and Facebook, and an important objective of our study is therefore to ensure that any proposals for the future regulation of platforms by government are based on a sound understanding of advertising-funded platforms' business models and the challenges that they may pose. The market study sits alongside parallel and complementary policy work that we are undertaking on non-advertisingfunded platforms 6. More specifically, our study aims to assess whether the markets for digital advertising - and the consumer-facing services that are funded by digital advertising such as search and social media - are working well. We have organised our work into three high level themes: - Theme 1 considers to what extent Google and Facebook have market power in search and social media respectively and the sources of this market power; - Theme 2 assesses whether consumers have adequate control over the use of their data by online platforms, by exploring the choices they are given, how easy it is to exercise those choices and whether there is adequate protection for those who do not engage; and - Theme 3 focusses on the business to business digital advertising markets, exploring a range of concerns including a lack of transparency, conflicts of interest and the leveraging of market power to undermine competition. ## Why Do These Issues Matter For Consumers? 7. Although consumers do not typically pay for the content that is supported by digital advertising, we all stand to experience harm in a variety of forms if competition in these markets is not working well. 8. First, competition problems may inhibit innovation and the development of new, valuable services for consumers. It is the threat of being overtaken by rivals that provides the spur to companies to innovate and produce new products that consumers want. If platforms are insulated from this threat - or indeed if they can stop new alternative platforms from growing - consumers will suffer from reduced innovation and choice in the future. 9. Second, while services such as search and social media appear to be free to those who use them, they are paid for indirectly through advertising revenues. The costs of digital advertising, which we estimate to amount to around £13bn in the UK in 2018, are reflected in the prices of goods and services across the economy. Therefore, if these costs are higher than they would be in a more competitive market, this will be felt in the prices that consumers pay for hotels, flights, consumer electronics, insurance and many other products that make heavy use of digital advertising. 10. Third, for content providers such as online newspapers, digital advertising represents a vital part of their business. If problems in the digital advertising market mean that such providers receive a lower share of advertising revenues than they should, this is likely to reduce their incentives and ability to invest in news and other online content, to the detriment of those who use and value such content and to broader society. 11. Fourth, limited choice and competition also means that people will be less able to control how their personal data is used and may effectively be faced with a 'take it or leave it' offer when it comes to signing up to a platform's terms and conditions. For some, this will mean they have to provide more personal data to platforms than they would like. 12. Fifth, competition problems may result in consumers receiving inadequate compensation for their attention and the use of their data. Although many online services are currently provided for free, in a well-functioning market, consumers might be paid for their engagement online, or offered a choice over the amount of data they provide. 13. Finally, we note there are many other forms of societal harm that have been linked to the behaviour of online platforms, such as online harms, fake news and the possibility of political manipulation. While these lie outside of the scope of this study, it is plausible that the competition concerns about market power and asymmetric information that we are considering may exacerbate these broader harms and that the remedies arising from this study may help to address them. Work is underway elsewhere in government to address these broader harms, and we will share with relevant government departments any insights that we gain into these issues in the course of our study. ## What Are Our Findings To Date? Size Of Market And Market Shares 14. Our current estimate is that around £13bn was spent on digital advertising in the UK in 2018. Search advertising comprised around half of these revenues, at around £6.4 bn, and display just over £5bn. The balance was made up of online classified advertising (comprising digital comparison tools and online marketplaces). This is shown in the figure below. Source: CMA, IAB / PwC for classified. Estimates for 2018. 15. Media agencies and most advertisers have told us that search and display advertising are not substitutable, mainly because they perform different roles. Search is intent-based advertising designed to encourage those consumers who have already shown an interest in buying the product to make a purchase, while display is suitable for raising brand awareness and reaching new audiences that might not yet have shown interest. 16. Google has had a consistently high share of the general search market for many years. Google has generated around 90% or more of UK search traffic each year over the last ten years and generated over 90% of UK search advertising revenues in 2018. The only fully independent competitor to Google in the core functions of general search is Bing, owned by Microsoft. Google also has a very strong position in various segments of the open display market. 17. Facebook (including Instagram, which it bought in 2012) generated almost half of overall display advertising revenues in 2018. For comparison, this was larger than the entirety of the open display market and more than four times the revenues of its next largest competitor, YouTube (owned by Google). 18. It is important to be clear that 'big' is not necessarily 'bad' in these markets. Where a platform has gained a large market share by being consistently better than its competitors and where it must respond to continued competitive pressures to maintain that position, it may be considered to operate within a competitive market even with a large market share. However, if potential competitors face substantial barriers to entry and expansion, such that the market is no longer properly contestable, then a high market share can translate into market power, giving the platform the opportunity to increase prices, reduce quality or leverage market power to undermine competition in potentially competitive markets. 19. In our study we have considered a number of characteristics of these markets that may inhibit entry and expansion by rivals and undermine effective competition. These include: - network effects and economies of scale; - consumer behaviour and the power of defaults; - unequal access to user data; - problems relating to a lack of transparency; and - vertical integration and conflicts of interest. 20. We note that these characteristics can be mutually reinforcing, and we discuss each of them below, drawing on Chapters 2 to 5 of the report which present our findings in more detail under each of themes 1 to 3. Finally, we consider the available evidence on the harm arising from these characteristics. ## Network Effects And Economies Of Scale 21. Network effects occur when the value of a service to its users increases as the total number of users increases, while economies of scale arise where average costs decrease with increasing scale. In combination, these features can mean that once a platform reaches a certain size, it can be extremely difficult for smaller new entrants to challenge them effectively. Our initial assessment is that both search and social media are characterised by significant network effects and economies of scale. 22. In relation to search, the crawling and indexing activities required to create a 'map' of the internet that can be searched in real time represent a major cost and are subject to significant economies of scale. 23. There are advantages to scale in user queries and click behaviour (known as 'click-and-query' data), since the more such data that search engines have, the more able they are to improve their algorithms.3 We understand that scale advantages are particularly high for uncommon or 'tail' queries. Both Google and Microsoft said that a substantial proportion of queries that they see are uncommon or new (around 15% of the daily queries on Google's search engine have never been seen before), which suggests that the ability to return appropriate results for such tail queries is likely to be an important factor in users' assessment of search quality. In addition, a higher volume of user search queries is of benefit to advertisers wishing to bid for keywords in the tail of less common search queries.4 24. Overall, our initial assessment is that the greater scale of queries seen by Google support its ability to deliver more relevant search results compared to its competitors, especially in relation to uncommon and new queries. In light of the importance of search relevance to consumers and keyword coverage to advertisers, a lack of comparable scale in click-and-query data is likely to be a key factor that limits the ability of other search engines to compete with Google. 25. Social media platforms are characterised by strong network effects, since the value to someone of joining a network is directly related to the other people who are already on the network. Given the high level of fixed costs, social media platforms also exhibit strong economies of scale, creating a cost advantage for larger rivals over smaller potential entrants. 26. Our initial view is that these characteristics lead to substantial barriers to expansion. We note that there have been several recent examples of entry of in the social media sector funded by display advertising, including Instagram, Snapchat, Pinterest and TikTok. However, with the possible exception of Instagram, these platforms are yet to reach a very significant scale in the supply of display advertising. In the case of Instagram, its success in achieving scale may be linked to its acquisition by Facebook and we are investigating this further. 27. Overall, rival social media platforms do not currently appear to be acting as a material threat to Facebook's competitive position. While new entry is possible, new platforms must overcome network effects and other barriers by offering a differentiated proposition that induces users to switch. No current platform offers a comparable range of services to Facebook and none can provide access to a similarly extensive user base. Even where platforms are successful in developing a user base, to be viable in the long-term, they must successfully monetise their services, and in the last ten years we note that rival platforms have struggled to do this. ## Consumer Decision Making And The Power Of Defaults 28. The digital economy has transformed the way we interact with information - the answer to a question that in the past would have taken considerable time and effort to find is now available in a fraction of a second. As access to huge reserves of information has become almost instantaneous, so our ability to filter extraneous information and focus on what is most relevant has become more important, and our tolerance for delays has fallen. Both of these factors have encouraged 'default behaviour' on the part of consumers - a propensity to avoid wasting time by accepting the default option presented to us, so that we can focus on what is important. 29. We have found that default behaviour by consumers has had a profound impact on the shape of competition in both search and social media. First, defaults play a very important role in influencing consumers' use of search engines, and second, default settings and the way in which choices are presented to consumers have a strong influence on the ability of platforms - particularly social media platforms - to collect data about their users, and the ability of users in turn to control the use of their data. 30. In search, Google has negotiated agreements with Apple and with many of the largest mobile phone manufacturers under which it pays a share of search advertising revenues to these partners in return for Google Search occupying the default search positions on the device. The scale of these payments is striking and demonstrates the value that Google places on these default positions. In 2018, Google paid $1.3 billion in return for mobile default positions in the UK alone, the vast majority of which was paid to Apple for being the pre-installed default on the Safari browser. Rival search engines to Google that we spoke to highlighted these default payments as one of the most significant factors inhibiting competition in the search market. 31. We consider that Google's extensive default positions across very large parts of the desktop and mobile landscape act as a barrier to expansion for other search engines, making it more difficult for these providers to grow their user bases and improve their search quality and search monetisation rates. In addition, there is likely to be a positive feedback loop between Google's position as the largest search engine and its ability to acquire extensive default positions that further reinforce this position. 32. It is important that consumers have control over the use of their data - allowing them to decide whether to provide or deny access and share it with others if they wish - as this will both benefit consumers directly and help increase competition between platforms. However, our work to date suggests that consumers sometimes have inadequate control over the data that is provided to online platforms. 33. Most platforms only collect limited data about consumer engagement with their privacy settings and controls, but the evidence that does exist suggests that consumer engagement is low at registration. For example, we found that only a small proportion of Facebook consumers viewed their ad settings within 30 days of registering. Because consumer engagement is low, most consumers follow the default settings set by platforms even if these do not match their preferences. 34. This behaviour can be explained in part by the fact that consumers sometimes have limited choice. In all cases across the social platforms that we reviewed including Facebook and Instagram, consumers are opted into personalised advertising by default and are unable to turn off personalised advertising while continuing to use the service. This is in contrast to search engines: both Google and Bing allow consumers to opt out of personalised advertising and some search engines such as DuckDuckGo do not use personalised advertising at all. 35. Further, in those cases where consumers do in principle have a choice, it is often time consuming and complicated to exercise this choice because of the way in which options are framed. For all of the social media platforms reviewed, we found that it is not obvious how to access privacy settings, which may only be visible after navigating through multiple menus. Again, this is in contrast to search platforms, where privacy settings are generally easier to access and control. 36. We also found that platforms' privacy terms and conditions were long and complicated, typically stretching to many thousands of words. We do not think it is reasonable for platforms to expect consumers to have read and understood all of these, often complex, terms before signing up to use a service. Research has shown that very few consumers read privacy policies when signing up to an online service and the evidence we have gathered confirms this: for example, in a recent 28-day period, the average visit to the Google privacy page was just 47 seconds, with 85% of visits lasting less than 10 seconds. ## Unequal Access To User Data 37. Data on users is highly valuable for targeting digital advertising (particularly display advertising) and measuring its effectiveness. Advertisers and publishers have told us that Google and Facebook enjoy significant competitive advantages in both targeting and measuring effectiveness because of their extensive access to user data. 38. Google collects a vast amount of user data from three main sources: its userfacing services (it provides over 50 such services, including search and Gmail); mobile devices running Android, Google's operating system; and from the analytical technology they place on third-party sites and apps (known as tags). Facebook gathers user data from the three main services it provides in the UK (Facebook, Instagram and WhatsApp) and from Facebook analytics technology placed on third-party sites. 39. Advertisers and media agencies have told us that Google offers in-depth targeting options, driven by its unique and vast sources of data, while Facebook has the advantage of offering the ability to target specific audiences based on demographic characteristics, interests and location. This creates a substantial competitive advantage for Google and Facebook, both of which have access to more extensive datasets than their rivals. The inability of smaller platforms and publishers to access user data may therefore create a significant barrier to entry. 40. The available evidence suggests that the user data used for targeting digital adverting is highly valuable to advertisers and publishers. For example, Google ran a trial in 2019 to compare the revenue publishers received from personalised advertising with revenue from non-personalised ads. The results indicate that UK publishers earned between 50% - 65% less revenue when they were unable to sell personalised advertising but competed with others who could. 41. The ability to measure the effectiveness of advertising is an important driver of advertisers' decisions on how to allocate expenditure across publishers and platforms. To measure effectiveness, advertisers need to be able to track user actions online, which is done through analytical tools such as tags. Google and Facebook tags are widely available on advertiser websites and apps: we understand that Google tags cover almost 90% of UK websites and that Facebook's cover about 50% of UK websites, both dwarfing other platforms' very limited coverage. In addition, Google's mobile data also allows it to track user actions offline (eg to identify store visits). This means that Google and Facebook are better able to track users and demonstrate the effectiveness of using their platforms relative to others, which is likely to create a barrier to entry for potential rivals. 42. We have also heard views that that aspects of the design and interpretation of data protection regulation risks creating competition concerns by entrenching these data advantages and favouring the business model of large, vertically-integrated platforms over smaller, non-vertically-integrated publishers. 43. In principle, the General Protection Regulation (GDPR) makes gaining and managing consent within a 'walled garden' to deliver a particular purpose, an easier exercise than sharing data between firms to deliver the same purpose. Large, vertically-integrated platforms such as Google and Facebook may therefore have an easier task in obtaining consent from consumers to use their data for personalised advertising compared with publishers such as newspapers involved in the supply of display advertising in the open market. 44. This risks creating a significant competitive advantage for vertically integrated platforms and could substantially reduce revenue for newspapers and others advertising in the open market. Such risks may become more pronounced as the display advertising industry moves to address concerns raised by the Information Commissioner's Office (ICO) about how widely data is shared between firms in the open display market. We have had constructive interactions with ICO on this topic and welcome the pragmatic view they have taken to date. We will continue to engage with them in the second half of the study to explore potential ways forward that could both address legitimate data protection concerns while preserving effective competition in the open display market. ## Lack Of Transparency And Asymmetric Information 45. One of the key functions of online platforms that are funded by digital advertising is to facilitate complex decision making in real time using large quantities of data. This applies equally to user-facing services such as search and social media as to the operation of programmatic digital advertising: neither of these would be possible without the use of sophisticated algorithms. Yet one consequence of this reliance on black box decision making is that market participants find it difficult to understand or challenge how decisions are made and to exercise choice effectively. 46. We have heard, for example, concerns from several newspapers about the impact of the algorithms employed by Google and Facebook on traffic to their sites. We have found that these two platforms provide just under 40% of the traffic to large publishers and have heard concerns about unexpected changes to the Google search and Facebook News Feed algorithms that have resulted in dramatic reductions in traffic to certain newspapers overnight. While we recognise that these algorithms have to be updated frequently and that too much transparency may lead to gaming behaviour, we acknowledge publishers' concerns that sudden, unexplained and significant algorithm changes can have harmful financial consequences for them which they are unable to predict or manage. 47. We have also found that advertisers and other market participants face a lack of transparency in relation to several key aspects of digital advertising, which undermines their ability to make effective decisions and drive competition, including: the quality and effectiveness of advertising; how auctions are carried out and auction outcomes determined; and how intermediaries acting on advertisers' behalf are remunerated. 48. In principle, the extensive data that is collected in the sector could address some of these concerns, but as noted above, this data is held by only a few parties, leading to concerns relating to asymmetric information. In relation to quality and effectiveness, for example, we have heard that neither Facebook nor Google allow full independent verification of their own inventory, leading to a perception on the part of advertisers and agencies that we spoke to that Google and Facebook are able to 'mark their own homework' for the measurement of viewability of ad impressions on their own inventory. This could weaken competition and potentially result in advertisers over-paying for advertising inventory. 49. The lack of transparency is particularly acute in the open display market where publishers and advertisers rely on intermediaries to manage the process of real-time bidding and ad serving but cannot observe directly what the intermediaries are doing or, in some cases, how much they are being charged. Market participants typically do not have visibility of the fees charged along the entire supply chain and are concerned that this limits their ability to make optimal choices on how to buy or to sell inventory, reducing competition among intermediaries. Lack of transparency may also give rise to rentseeking behaviour and arbitrage opportunities, ie the possibility for an intermediary to buy impressions at one price and sell them at a higher price, without its customers being aware of this. 50. Overall, the lack of transparency that we have observed has the potential to create or exacerbate a number of competition problems. Suppliers may have the incentive and ability to overstate the quality and effectiveness of their advertising inventory, for example, or to increase prices. Suppliers with market power can take steps to reduce the degree of transparency in digital advertising markets, forcing advertisers to rely on information and metrics provided by those suppliers. Asymmetric access to information across suppliers may also create opportunities for exclusionary behaviour on the part of the large advertising platforms. The upshot of all of these issues is likely to be that competition is weakened. ## Vertical Integration And Conflicts Of Interest 51. All of the advertising-funded platforms that we have considered in this study are vertically integrated in the sense that they run integrated sales functions - often based on the use of quality-adjusted second-price auctions - for the sale of their own advertising inventory. We refer to this as 'owned and operated' inventory. In contrast, in the open display market, publishers and other content providers compete to sell advertising inventory using a wide variety of third-party intermediaries and exchanges. 52. We have heard a number of concerns, particularly from publishers, about the extent of vertical integration that has taken place in the open display market. While vertical integration can allow intermediaries to realise technical efficiencies, it can also give rise to conflicts of interest and allow companies with market power at one stage of the value chain to use it to undermine competition at other stages. 53. The concerns that we have heard focus on the role of Google, which, as shown in the figure below, has a particularly strong position in advertising intermediation, controlling a share of in excess of 90% of the ad server segment5 and shares of between 40% and 60% in supply-side platforms (SSPs) and of between 50% and 70% in demand-side platforms (DSPs), according to our preliminary estimates. Source: CMA Note: We include Google AdX, Google Ad Sense and Google AdMob in our definition of SSPs and Google DV360 and Google Ads in our definition of DSPs. Share estimates at SSP/Exchange and DSP levels have been computed based on data from the intermediaries we received information from. As our coverage is not complete, Google shares may be over-estimated. 54. Google has market power in the open display market stemming from three main sources: its inventory of search and display advertising; its data on users and on advertising attribution; and its position as the dominant publisher ad server. We have heard a variety of concerns from market participants, including that Google is able to: use its market power in inventory and data to advantage its DSP services; use its influence over advertiser demand (from Google Ads) to favour its ad server and SSP; and use its market power as an ad server to favour its SSP. 55. We are still considering the concerns that have been expressed to us in relation to these practices and have not reached a conclusion on any potential anti-competitive effects or efficiency justifications. What does appear clear, however, is that there are legitimate concerns about perceived conflicts of interests for actors that operate at multiple levels of the intermediation value chain. When operating on behalf of the publisher, such a firm might have an incentive to favour bids coming through its own advertiser-side intermediaries, rather than necessarily those that are best for the publisher, and when acting for advertisers, it might have an incentive to channel an advertiser's spend to its publisher clients, rather than to the publishers that are best for the advertiser. 56. In the case of Google, the fact that it operates as a publisher ad server, with influence over which ads are served and which bidding information is provided to publishers and intermediaries, as an SSP, which sells inventory on behalf of publishers, and as a DSP, which buys inventory on behalf of advertisers, raises several potential conflicts of interest. ## Evidence Of Harm 57. We have considered the potential harmful effects of the concerns we have identified in these markets, and the extent of the evidence that these harmful effects are taking place in practice. 58. Typically, a firm with market power would be able to exploit it by raising prices. We note that advertising-funded platforms use auctions rather than setting prices directly, and therefore may be considered to have less influence over the price. However, such platforms can employ various levers within those auctions that directly and indirectly influence advertising prices. For example, search engines such as Google determine the maximum number of ads that can be shown per search query, how these ads are presented, the way in which relevance is assessed, the level at which reserve prices are set and the way in which matching algorithms work. These levers collectively influence the prices advertisers pay. 59. We have found that the profitability of both Google and Facebook has been well above any reasonable estimate of what we would expect in a competitive market for many years. In 2018 we estimated that the cost of capital for both Google and Facebook was around 9%, compared to actual returns on capital of over 40% for Google and around 50% for Facebook. This evidence is consistent with the exploitation of market power. 60. We have also considered the available evidence on price levels. Google has achieved somewhat higher prices on average than Bing over the last three years, which is consistent with evidence from advertisers, most of whom suggested that Google tended to have higher prices than Bing for similar keywords. Facebook's prices have been increasing over the last three years and are significantly higher on average than its rivals, YouTube and Instagram. However, at this stage we interpret the evidence on relative pricing with caution, as relative prices are likely to be driven by a number of factors including differences in quality. We are considering further analysis in the second half of the study that could help us make a more like-for-like comparison of price levels. 61. As noted above, a potential concern arising in the open display market is that intermediaries might be able to exploit the lack of transparency to extract excessive fees. The Cairncross report expressed concern that there is a lack of transparency about the amount paid to intermediaries along the supply chain for online programmatic display advertising and these concerns have been echoed by publishers in their engagement with us. 62. We have gathered evidence on fees from the main intermediaries currently operating in the UK. Our initial estimates suggest that the weighted average DSP fee is around 18% of advertising spend and that the overall weighted average of SSP/ad network fees is around 22%. In broad terms, our estimates to date are similar to those previously estimated by Plum consulting for the Cairncross report. We are intending to carry out further work to investigate money flows along the intermediation chain in the second half of the study, including an analysis of transaction-level data to investigate the potential for 'hidden fees' arising from arbitrage behaviour. 63. Harm could also take the form of exclusionary behaviour. Google and Facebook appear to have the incentive and ability to leverage their market power in general search and social media into other related services - both user-facing services and wider digital advertising markets. This can have the effect of making it more difficult for competitors in these markets to compete and of protecting the platforms' core market power. We have heard these types of concerns raised in relation to several user markets, and are considering how to take these complaints forward in the second half of the study. ## Which Interventions Are We Considering? 64. We have considered a range of potential interventions to address the concerns that we have identified, drawing on proposals that have been put to us by parties in the course of the study. Our objective in identifying these interventions at this interim stage is to seek the views of stakeholders on the case for, and appropriate form of, the intervention, to inform the recommendations that we make at the time of the final report. 65. Overall, the work we have carried out on the study to date has strengthened the view we expressed in our statement of scope that there is a strong argument for the development of a pro-competitive regulatory regime to regulate the activities of online platforms funded by digital advertising. In considering the appropriate nature of this regime, and the specific rules and regulations within it, we have considered three broad categories of intervention: - Rules to govern the behaviour of platforms with market power (including in particular the Furman proposal of an enforceable code of conduct for firms with Strategic Market Status). - Rules to give consumers greater control over data and to improve transparency. - Interventions to address specific sources of market power and to promote competition (including data access, consumer default, interoperability and structural interventions). ## Behavioural Rules For Firms With Market Power: Enforceable Code Of Conduct 66. The first category of intervention comprises rules to govern the behaviour of firms that enjoy a position of market power. Its intention is to address the harmful effects that can arise from the exercise of market power, rather than tackling the causes of that market power. The Furman Review proposed that there should be a code of conduct which would set rules for large platforms with 'Strategic Market Status' (SMS), the objective of which would be to address competition problems more quickly than can be achieved through antitrust enforcement. 67. Our initial view is that an enforceable code of conduct may help address a number of concerns that we have identified in digital advertising markets. Based on the submissions we have received, we consider there are a number of examples of behaviour where a code of conduct would potentially make the market work better, and where the range and complexity of issues are such that antitrust tools alone are not sufficient to resolve them. The code of conduct could work as an effective complement to competition law, addressing concerns that require rapid intervention to avoid lasting competitive harm and, for the firms captured by the code, providing increased certainty over what represents acceptable behaviour when interacting with users and competitors. 68. At this stage, our initial view is that both Google and Facebook would likely be considered to have SMS, although we note that other platforms may be considered to have SMS when considering their role in other markets outside the scope of this study. 69. We have considered the potential content and design of a code. Our initial view is that the code should take the form of high-level principles rather than detailed and prescriptive rules. Given the complex and rapidly-changing nature of the markets within scope and the issues we have identified, there is a risk that overly prescriptive rules would soon become redundant or fail to anticipate important new developments. Our current view is that, for platforms funded by digital advertising, the key provisions of the code could be summarised in the form of three overarching principles: '**fair trading**'; '**open choices**'; and '**trust and transparency**'. 70. An expert body would be required to enforce the provisions of the code, but at this stage, our assessment has focused on regulatory functions and design principles rather than on which institutions might discharge those functions. ## Rules To Improve Transparency And Give Users Greater Control Over Data 71. One of the main problems we have identified in our study is the lack of transparency and asymmetry of information between platforms and their customers. This affects both individual consumers, who lack awareness of how their data is used and the ability to control it, and businesses, who often lack the requisite information to exercise choice effectively in digital advertising markets. We have therefore considered potential interventions designed to improve transparency and address asymmetric information for both consumers and businesses. Some these interventions would likely apply only to SMS firms while others may require broader sector-wide regulation to achieve their intended effects. 72. For consumers, the problems we have identified relate to a perceived lack of control over data extraction due to: the importance of default settings and the fact that current defaults may extract more data than consumers are comfortable with; the restricted availability of choices to opt out; and difficulties in exercising those choices. The interventions we are considering are designed to facilitate informed choice and greater control for those consumers who wish to engage, while providing greater protection for those who do not. They include: - A rule that all platforms should be required to give consumers an option to use their services without requiring in return the use of consumers' data for personalised advertising. - Changes to default settings for SMS platforms, to require a default 'optin' to personalised advertising rather than the current default optout. - A principle of 'fairness by design' placing an ex ante obligation on platforms to design consent and privacy policies in a way that facilitates informed consumer choice, with additional obligations to trial and test choice architecture for SMS platforms. 73. These would be significant changes and would require careful consideration. It is plausible that in combination they would shift the balance of power between consumers and platforms, giving consumers greater control over their data and in turn encouraging platforms to offer greater incentives to consumers to provide access to their data.6 But we are also mindful of the risk that these changes would damage the business model of platforms, particularly for new entrant and challenger platforms that currently generate limited revenue, and are therefore keen to seek views on the extent to which requirements should be adjusted according to whether a platform has SMS status. 74. Regarding the risk that aspects of the design and interpretation of current data protection regulation favour the business model of large, vertically-integrated platforms over smaller, non-vertically-integrated publishers, we think it is very important for competition and data protection authorities to consider jointly the interface between consumer, competition and data protection law, as this is likely to produce the best outcomes for consumers in assessing conduct with overlaps across these regimes. Such cooperation is particularly important at the current time, when the interpretation and practical application of GDPR is still evolving. 75. In relation to the concerns about the current open display market, we welcome the pragmatic approach that the ICO has taken to date on this topic, reflecting the importance of this market for newspapers and other content providers. We also recognise the security concerns arising from the sharing of data between multiple firms and think that DPAs could enable appropriate sharing of data between firms by prioritising support for the development of codes of conduct and certification regimes under the GDPR, which would facilitate the secure sharing of a consumer's personal data. We will continue to engage with the ICO and Irish Data Protection Commission (DPC) on these issues in the second half of our study. 76. Our initial view is that regulatory reform could also improve transparency in the digital advertising markets. A new regulatory framework could include rules on the information that should be provided on certain activities which are essential for the effective working of digital advertising, including verification or attribution. It could also require increased interoperability to support a well-functioning market, where measures such as common identifiers, formats or verification could be approved by a regulatory body where the adoption of a common standard would deliver benefits of the sector as a whole. In some cases (for example, the operation of auctions) transparency to other sector participants may not be appropriate for competition or data protection reasons. A regulatory framework could address this by allowing auditability and monitoring of algorithms by a regulator, to ensure that actual behaviour matches expectations and that conflicts are managed. ## Potential Interventions To Address Sources Of Market Power And Promote Competition 77. We have also considered a range of interventions to address the sources of market power that we have identified, to address concerns on both the supply and the demand side of the markets we have reviewed. These include some very significant interventions, the costs and benefits of which would need to be considered very carefully. We welcome views of the case for, and appropriate design of, each of these options. 78. To address the concerns that we have identified in relation to Google's market power in general search, we are considering two principal interventions 79. First, we are considering a requirement that Google provide click-andquery data to rival search engines. The purpose of this intervention would be to overcome Google's scale advantages by providing data to improve the quality of rivals' search algorithms. We are aware of the potential impacts on Google's incentives to innovate and invest and are interested in views on how these risks could be addressed, and the terms on which any access should be provided. 80. Second, we are considering two proposals to address concerns relating to Google's control over Android defaults and its ability to pay more than its rivals to be the default on browsers such as Safari. The first intervention we are considering is whether there should be some form of restriction on the ability of Google to enter into arrangements to be the default search engine on devices and browsers. 81. The second intervention would be a requirement to offer choice screens to consumers on devices and browsers allowing consumers to choose their default search engine, building on Google's recent introduction of choice screens on all Android devices. We are considering proposals regarding the design of these choice screens, including the use of non-monetary criteria to allocate slots and proposals to extend the requirement to offer choice screens beyond Android devices. 82. The market power of Facebook derives in part from the strong network effects stemming from its large user base. We have therefore considered potential interventions to increase interoperability to help overcome these network effects for new entrant and challenger social media platforms. We are interested in views on whether Facebook should be required to interoperate specific features of its current network with existing competitors; the scope of any interoperability requirements, such as the ability to post content across several platforms simultaneously; the ability to view posts from friends on other social platforms; and how the standards surrounding these features should be developed and monitored. 83. Other options we are considering include whether there should be limits on Facebook's ability to impose restrictions on competitors' use of the interoperable features and whether aspects of past API access should be restored to facilitate competition. Finally, we are interested in views as to whether any rules requiring greater interoperability should apply to Facebook alone or also to other social media platforms. 84. To address concerns relating to Google's conflicts of interest in the open display market, we are considering the case for a range of separation remedies. These could include, for example, the separation of the ad server (which plays a key role in the selection and pricing of adverts and in which Google has a very high market share) from the rest of Google's business, or a requirement on Google to trade on an arm's length basis with its analytics business and offer analytics to third-party providers. 85. Separation could cover a range of options, from management separation to full ownership separation (divestiture). In relation to the former we would need to consider whether such an intervention would be effective and practical, while in relation to the latter, we recognise this would be a highly interventionist remedy and we would need to consider not only the costs and benefits but the feasibility of the UK acting unilaterally in this area. ## Provisional View On The Case For A Market Investigation 86. Since launching our market study, we have received several representations from parties for us to make a market investigation reference and we are therefore required under statute to consult on whether or not to make such a reference. 87. The CMA can make a market investigation reference when: the findings of a market study give rise to reasonable grounds for suspecting that a feature or combination of features of a market or markets in the UK prevents, restricts or distorts competition; and a market investigation reference appears to be an appropriate and proportionate response. Based on our initial findings, we consider there are reasonable grounds for such a suspicion in the following areas: - the open display advertising market, with a focus on the conflicts of interest Google faces at several parts of its vertically integrated chain of intermediaries; - general search and search advertising, with a focus on Google's market power and the barriers to expansion faced by rival search engines; and - social media and display advertising, with a focus on Facebook's market power and the lack of interoperability between Facebook and rival services. 88. Further, many of the potential interventions discussed above could in principle be implemented through the order making powers available to the CMA under a market investigation. The decision on whether to propose a market investigation reference therefore rests on whether it is the most appropriate mechanism for delivering potential reforms. 89. In our statement of scope, we indicated that we saw recommendations to government as the best mechanism for delivering reforms, as part of a comprehensive regulatory framework to govern the behaviour of online platforms. Although it is a finely balanced judgement, we remain of the view that a comprehensive suite of recommendations to government is currently the best way forward and are therefore consulting on not making a market investigation reference at this stage. There are several reasons for this position: 90. First, the government has been committed to regulatory reform in this area. We therefore currently believe that there are good prospects that any recommendations coming from our study would be implemented in practice. Further, there is a programme of work by government considering how to regulate a wider range of online platforms than those we have considered in this study and we risk complicating the landscape by seeking to implement major reforms in parallel for a narrower set of companies. We want to inform the government's work in this area rather than cut across it. 91. Second, the concerns we have identified regarding online platforms such as Google and Facebook are a truly global antitrust challenge facing governments and regulators. Therefore, in relation to some of the potential interventions we may consider in a market investigation, and in particular any significant structural remedies such as those involving ownership separation, we need to be pragmatic about what changes could efficiently be pursued unilaterally by the UK. We will continue to work as closely as we can with our international counterparts to develop a coordinated position on these issues in the second half of the study. 92. Third, we still have considerable work to do to understand the nature and extent of the issues in the market, and what the appropriate range of remedies might be to address them. We hope to test our initial findings through this consultation, gather more evidence through the second half of the study, and come to more precise judgements in our final report. 93. For these reasons, we do not propose to make a market investigation reference at this stage. Our preferred approach to tackling the problems we have identified continues to be through recommendations to government for regulatory reform. 94. We would like to receive views from a broad range of parties on this issue, and in particular on whether recommendations to government would be the most appropriate route to addressing the issues we have identified. We will make our final decision taking into account the consultation responses that we receive and any relevant developments since this provisional assessment. ## Next Steps 95. This report provides an update on the progress we have made to date in this market study. It sets out our initial findings on a wide range of potential concerns within each of our three themes and identifies the range of potential interventions we are considering to address them. In the second half of the study, we intend to gather more evidence to test and refine our thinking in these areas, and to identify which are the most appropriate interventions. This consultation is an important first step in that process. We welcome responses by 12 February. 96. We will set out conclusions and recommendations for interventions in our final report, which we will publish by 2 July 2020. ## 1. Introduction Context 1.1 The CMA launched its Digital Markets Strategy on 3 July 2019, setting out our intended approach to tackling the challenges posed by the digital economy.7 A core part of this strategy was the launch of a market study into online platforms and digital advertising in the UK.8 This report provides an update on the progress we have made in the first six months of the study. 1.2 This market study was launched in the context of concerns, raised in the UK and globally, about the powerful position held by a small number of online platforms. These have focussed, alongside a broader set of issues such as online harms and fake news, on the market power of large online platforms and their ability to extract large volumes of data from consumers to entrench that power. Several institutions in the UK raised specific concerns about the market power of platforms funded by digital advertising, and the lack of transparency and conflicts of interest in the business-to-business digital advertising market, and recommended that the CMA undertake a market study in this area (some examples of these calls are provided in Box 1.1). 1.3 We launched our market study in response to these recommendations. Its scope is broad, covering the nature of competition in both consumer-facing and digital advertising markets, while recognising the critical role that data plays in linking them. We have structured our work into three related themes that group potential sources of harm to consumers. These themes consider: 1) to what extent online platforms have market power in consumer-facing markets, and what impact this has on consumers; 2) whether consumers have adequate control over how data about them is used and collected by online platforms; and 3) whether competition in the digital advertising market is distorted by a lack of transparency, conflicts of interest or market power held by platforms. 1.4 This scope, and the nature of each theme, has remained broadly unchanged from our statement of scope. ## Box 1.1: Calls For A Cma Market Study Into Digital Advertising Digital Competition Expert Panel (Furman Review):9 'The Cma Should Conduct A Market Study Into The Digital Advertising Market Encompassing The Entire Value Chain, Using Its Investigatory Powers To Examine Whether Competition Is Working Effectively And Whether Consumer Harms Are Arising.' ## Cairncross Review:10 'The Review recommends that the Competition and Markets Authority use its information-gathering powers to conduct a market study into the online advertising industry. By looking more closely into the position of different players, their roles, costs and profitability, the CMA will be able to identify how efficiently the online advertising market is working, and what remedies, if any, are needed.' ## House Of Lords Select Committee On Communications:11 'We Recommend That The Competition And Markets Authority (Cma) Should Conduct A Market Study Of Digital Advertising To Investigate Whether The Market Is Working Fairly For Businesses And Consumers.' Which?:12 'The Competition And Markets Authority (Cma) Should Conduct A Market Study In To The Digital Advertising Industry As A Matter Of Urgency.' 1.5 As explained in our strategy document, this study aims to inform government thinking on the regulation of online platforms and to provide analysis to support the government's response to the Furman Review.13 Our aim is to ensure that any proposals for future regulation by government are based on a sound understanding of advertising-funded platforms' business models and the challenges that they may pose. The market study sits alongside parallel and complementary policy work that we are undertaking outside of the study, which includes consideration of non-advertising-funded platforms, as well as institutional questions arising from the Furman Review's recommendations. 1.6 We intend that our study should not only address concerns specific to digital advertising, but also inform the development of a new regulatory landscape that extends beyond advertising-funded platforms, here in the UK and globally. Using our information-gathering powers, we have set out to test the principles and concepts developed in previous work, to establish whether they apply in practice to some of the most significant global platforms and the markets within which they operate. ## Evidence Gathering 1.7 Since launching the study, we have consulted a large number of parties, and gathered a broad range of evidence. This has involved a high volume of submissions from parties, in response both to our statement of scope and our requests for information. We are grateful to all those who have helped us progress our work at rapid pace. Figure 1.1 summarises our progress to date in gathering evidence. Source: CMA. 1.8 A summary of the responses to our statement of scope can be found in Appendix B. ## This Document 1.9 The market study is approaching the half-way stage. The purpose of this document is to provide an update on our approach and our progress, to indicate the direction of travel our analysis is taking in relation both to concerns and potential interventions to address them, and to test these initial findings with stakeholders. 1.10 This report sets out our understanding of how the companies and markets within our scope function. We do this at the highest level in Chapter 2, which provides an overview of how the markets, platforms, and issues within our scope interrelate. The chapters that follow then provide more detailed and targeted explanations of these issues. Where there are elements that are more complex or technical, such as how the open display advertising market operates, we have sought to provide additional detail in supporting appendices.14 We hope that stakeholders will study this detail and bring any inaccuracies to our attention. 1.11 We have also set out our early findings on the key issues and concerns that may be present in each market. Building on the strong groundwork provided by the Furman Review for the UK Government, 15 the special advisors' report for the European Commission,16 and Stigler Center Committee's report on the challenges posed by digital platforms, 17 we have attempted to take the discussion forward by identifying which specific features are most relevant to each market or individual platform. Chapter 3 reviews the consumer-facing services within general search and social media markets. Chapter 4 analyses issues relating to consumer control of data on those same platforms. Chapter 5 considers issues that are specific to the digital advertising market. 1.12 In the context of our early findings, Chapter 6 outlines the range of potential interventions that we will look to assess in more detail in the second half of the study. Our consideration of reforms is in its early stages - we would like to use this consultation to gather views on the merits, risks, and practical challenges of implementing each of them. 1.13 Chapter 7 then sets out our current view on whether these potential interventions would best be delivered through recommendations to government, or by the CMA's order-making powers available under a market investigation. We conclude that, at this stage, we are minded against making a market investigation reference. We are publishing this document to inform a thorough consultation on this issue. 1.14 Consistent with our intention for this study to shine a light on these complex and opaque markets, we have attempted to reveal as much detail from our evidence and findings as possible. In doing so, we have surfaced a great deal of information that was not previously in the public domain. However, there has been some information we have chosen not to publish at this stage - in some cases because the information is highly commercially sensitive, and in others because parties that provided the information to us indicated that they wished to remain anonymous for fear of repercussions in the market if their identity were revealed. There are as a result some instances where we have anonymised parties' submissions, presented confidential numbers in ranges, or sought to make more generalised statements in order to convey the key messages while not disclosing confidential information. We indicate these instances with the use of [square brackets]. 1.15 Before we draw firm conclusions about competition concerns or potential reforms, we have further work to do in the second half of our study to refine our understanding and firm up our evidence base. Our final report will contain a more comprehensive assessment of the issues set out in this document will be provided in our final report. This will include our conclusions on the problems and challenges to be addressed, and the reforms that should be delivered to maximise the benefits to consumers from these markets and services. ## 2. Overview - Google and Facebook are the largest online platforms that are funded by digital advertising. Their business model relies on attracting consumers' attention and gathering data about them, which they use to sell targeted advertising. - The services provided by both companies are highly valued by consumers. Search engines give us instant access to information, news and a wide range of goods and services. Social media services enable us to connect with friends and family around the world, keep up with news or current trends and share creative content with one another. - Over a third of UK internet users' total time online is spent on sites owned by Google and Facebook. Both companies are also able to gather substantially more data about consumers than their rivals. - As a result, Google and Facebook have grown to dominate the UK digital advertising market. We estimate that search advertising revenues in 2018 totalled around £6.4 billion in 2018, of which more than 90% was earned by Google. Total spend on display advertising was worth £5.1 billion, of which we estimate almost half went to Facebook. - Both Google and Facebook are highly profitable. The return on capital earned by both companies has for many years been substantially higher than any reasonable estimate of what we would expect in a competitive market. - In this study we are investigating whether rival providers of search and social media services can no longer compete effectively with Google and Facebook because of their size, and a range of concerns in the digital advertising market including a lack of transparency and conflicts of interest. - These issues matter to consumers: if competition in search and social media is not working well, this can lead to reduced innovation and choice, while the resulting poor competition in digital advertising can increase the prices of goods and services across the economy, and undermine the incentive or ability of newspapers and other providers to produce valuable content, as they may not receive a fair share of revenues. ## Introduction 2.1 Our study covers three related themes relating to platforms that are funded by digital advertising: competition in consumer-facing services; consumer control over data; and competition in digital advertising markets. The aims of this chapter are to explain why we are looking at each of these three themes and how they are connected, to explain how the key consumer-facing and digital advertising markets work; and to set out at a high level why this all matters to consumers. 2.2 The chapter covers the following topics: - The business model of platforms funded by digital advertising, including an explanation of the importance of consumer attention and data. This section clarifies why we have focused on the services provided by Google and Facebook. - A high-level introduction to the digital advertising market, including the different types of digital advertising. - A summary of key market outcomes, including expenditure on different forms of digital advertising, and an analysis of the profits earned by Google and Facebook. - An explanation of how a lack of competition in these markets can result in a wide range of negative impacts for consumers. ## The Business Model Of Platforms Funded By Digital Advertising 2.3 Online platforms typically seek to attract consumers by offering their core services for free. Once they have attracted a critical mass of consumers, they seek to make money from business users on another side of the platform. In transaction-based platforms, such as Amazon Marketplace or Apple's App Store, this is predominantly through the commission that is charged to retailers or app developers respectively. 2.4 For other platform services, such as search engines and social media services, monetisation comes predominantly through serving adverts. Google and Facebook are by far the largest two companies operating with this business model - we have therefore focused heavily on these two companies within our market study. 2.5 Although consumers do not pay money for these services, they can be considered to pay for them by giving the platform their attention and data about themselves. Advertising-funded platforms are able to combine the attention of their users with contextual or personal information they have about them to serve highly-targeted adverts, which are in high demand by advertisers. These exchanges are illustrated in Figure 2.1 below. The importance of consumer attention and data in the digital advertising market is explained in more detail later in this chapter. Source: CMA. 2.6 The advertising-funded business model is not novel. Newspapers have been generating revenue in the UK through advertising for several hundred years. On television, ITV provided the first alternative to the BBC in 1955,18 when it began its ad-funded broadcasting. Similarly, commercial radio stations have been generating revenue through advertising in the UK ever since the market was liberalised in 1973.19 These services have added substantial value to our society. 2.7 The same is true of many services provided by digital platforms. Search engines give us instant access to information, news, directions, and other websites with minimal effort. Social media services enable us to connect with friends and family around the world, make new friends, keep up with news or current trends, and share creative content with one another. These services, which are funded by digital advertising, are highly valued by consumers (see Box 2.1). ## Box 2.1: The Value Of Online Platform Services Platform services that are funded by digital advertising bring substantial benefits to consumers, while being provided free of charge. Research published in 2018 demonstrated that consumers place great financial value on a range of online services, with values of multiple thousands of dollars being assigned to search engines and digital maps. Video streaming services such as YouTube, and social media more broadly received lower, but still significant valuations that by far exceed the price that is paid.20 The fact that these services are so important to consumers and valued so highly is precisely why it is critical that competition is effective in these markets. Through our work in this area we want to ensure that current consumers are reaping the maximum potential rewards from these services, and that future consumers will continue to benefit from new innovative services that can transform our lives. 2.8 The targeted nature of digital advertising can add value to both advertisers and consumers. For consumers, targeted adverts will be more relevant to them, which can make them less irritating and more likely to provide genuinely useful information about products and services they may be interested in. For advertisers, improved targeting should deliver a greater return on their investment as their adverts will be viewed more often by their intended audience. Overall, more relevant and better targeted adverts can be expected to result in more purchases, increasing consumer and producer welfare as a result. 2.9 Despite these benefits that online platforms have undoubtedly delivered, the markets within which they operate contain a range of features that mean they frequently tend towards a 'winner-takes-most' dynamic with limited competition 'in' or 'for' the market. This may result in sub-optimal outcomes for consumers over the longer term. These features, which have been wellarticulated in existing reports, including the Furman21 and Stigler Center22 reviews, are summarised in Box 2.2. ## Box 2.2: Key Features Of Online Platforms While the precise characteristics of each platform varies from market to market, they tend to share a set of general features that collectively support a 'winner takes most' dynamic: - Online platforms typically have very low marginal costs and significant economies of scale in delivering the core service. - Network effects mean that the value of a service to existing users of a platform increases as the total number of users increases. The nature of the network effects can vary significantly between platforms. - The fact that consumers do not pay directly for the platform's services limits their incentives to switch, and means that new entrants must attract users through demonstrably better quality or innovative features, rather than being able to undercut on price. In this report we have set out our initial assessment of how important these and other features are in general search and social media - the two most significant platform markets funded by digital advertising. ## Google'S And Facebook'S Positions In Respect Of Consumer Attention And Data 2.10 There are two key factors that influence the revenue that online platforms and publishers can generate through digital advertising: - Capturing consumers' attention: this is an essential requirement for selling any form of advertising inventory.23 The more of consumers' attention platforms can capture, whether that is through increased reach or keeping consumers online for longer periods, the more attractive the platform's inventory is to advertisers, and the more inventory they will ultimately have to sell. - Understanding preferences and purchasing intent: understanding the wants and needs of specific consumers at any point in time is valuable to advertisers as they can target their adverts towards those individuals that they suspect are most likely to make a purchase. This targeting results in a higher return on investment for advertisers, and a willingness to pay higher prices. Platforms are therefore rewarded by advertisers for having extensive and up-to-date knowledge of their consumers' characteristics, preferences, and intentions. The key input to this knowledge is data.24 2.11 The following sections of this chapter explain how Google and Facebook lead the race to capture online consumers' attention and to gather data on their preferences and intentions. ## Consumer Attention 2.12 UK internet users spend an average of three hours 15 minutes each day online,25 with the majority of this time spent in a relatively narrow set of sites and services, including social media, information, news, shopping, and entertainment such as videos, music, and games. 2.13 The characteristics of many of these markets mean that they tend to tip towards high levels of concentration. With a narrow set of highly concentrated markets, the majority of internet users' attention is captured by a small number of very large companies, and in particular, mainly by Facebook and Google. 2.14 In terms of reach, around 95% of UK internet users access at least one Google site each month. Facebook's reach is around 85%. Of the total time spent by users online, just over a third is on sites owned by either Google (including YouTube) or Facebook (including Instagram and WhatsApp).26 2.15 This success by Google and Facebook in attracting consumers' attention is illustrated by Figure 2.2 below, which shows consumer time spent on the top 1000 properties. Consumers spend around 86% of their total time online on these top 1000 properties, with the remaining 14% split between an extremely long tail in excess of 16,000 websites.27 Source: Comscore, MMX MP, Total Digital Audience, Desktop aged 6+, Mobile aged 13+, June 2019, UK. Notes: The 1000 properties account for 86% of total user time spent online. * Where 'Google Sites' includes all Google owned properties eg YouTube and Google Search. †Where 'Facebook' includes Facebook, Instagram and WhatsApp. ## Consumer Preferences And Purchasing Intent 2.16 While there are important differences in the data-gathering practices of Google and Facebook, both companies are able to combine various sources and types of data to build up a profile of an individual, which can be used to make inferences about the types of products and services that they are likely to purchase. These profiles can include information on a consumer's individual characteristics, likes and dislikes, political views, income, frequent locations and journeys, and so on. They can pool this information from a number of sources, including: - information that consumers volunteer when registering for a service, such as name and contact details; - observed contextual information such as information about a device being used to access the service or the precise location of the consumer at a particular time; - observed data from tracking users' activity across the web, from which inferences can be drawn based on the articles they read or the websites they visit;28 and - conclusions about a consumer's characteristics and preferences that are inferred from observing their activity within the services, such as posts they like or click on within Facebook, or videos they view on YouTube. 2.17 The ability to target an advert at a specific individual with a particular set of characteristics, or even where an individual has revealed a demand for a particular product or service, is highly valuable to advertisers. Similarly, the ability to demonstrate a link between exposure to an advert and consumer purchasing behaviour is key in attracting and retaining advertisers. Both require data and this is why platforms are incentivised to gather as much data as they can on as many consumers as possible. ## Regulations To Protect Privacy 2.18 There are tensions between these incentives to compete for consumer data, and the legal framework that is in place to protect consumers' privacy. Box 2.3 highlights some of the key elements of the law that governs the use of personal data for advertising purposes, while a more detailed description of the legal and voluntary framework can be found in Appendix A. We explore the synergies and trade-offs between data protection regulation and competition in Chapter 4. ## Box 2.3: Data Protection Law There are several aspects of law in the UK that relate to the protection of consumers' personal data. These include: - **The General Data Protection Regulation 2016/679 (the 'GDPR')** - the GDPR provides the general framework for the protection of personal data that applies in the UK. Coming into effect in May 2018, it built upon similar principles derived from the Data Protection Directive 95/46/EC and in the Data Protection Act 1998. Amongst other things, it sets out the range of circumstances in which processing of an individual's personal data can be lawful. - **The Consumer Rights Act 2015 (CRA)** - part 2 of the CRA requires the terms in consumer contracts and consumer notices to be fair and, if written, transparent. - Unfair Contract Terms Directive (2005/29/EC) / Consumer Protection from Unfair Trading Regulations 2008 (SI 2008/1277) (CPRs) - broadly speaking, they prevent businesses (described as 'traders' in the CPRs) from treating consumers unfairly. Businesses are also responsible for the commercial practices of anyone who acts on their behalf or in their name. Both the business and those acting on their behalf may be held liable for breaches of the CPRs. ## Search And Social Media 2.19 Google and Facebook's advantage in attracting consumers' attention and collecting their data, and their resultant high share in digital advertising revenues, has been achieved primarily through their core services in general search and social media respectively. These consumer facing markets are therefore the primary focus of our analysis in Chapter 3. ## Understanding General Search The Demand-Side 2.20 Web-based search engines are a tool to help consumers to navigate the Internet and find useful information in response to a broad range of search queries. They make money by serving these consumers with paid-for adverts. 2.21 Research by Ofcom shows that search engines are consumers' preferred method for finding what they are looking for online: 29 - 97% of UK adults reported using a search engine in the past year to look for information online; and - for 50% of UK adults, the first place they usually go online is a search engine. 2.22 Consumers access search engines in several ways: - Web-browsers - web browsers have default search engines in the navigation bar; some consumers may choose their browser and search engine at the same time. - Web-navigation - in the course of a session, consumers may navigate to one or more search engines, and many have a search engine as their home page. - Search apps - on mobile devices, consumers tend to access search engines via apps such as widgets. They may use default search apps that come installed on mobile devices, or choose to download their preferred search app from an app store. - Voice assistants - via smart speakers such as Amazon Echo and Google home. ## The Supply-Side 2.23 General search engines work by maintaining an index of the websites that are available on the internet and returning a set of ranked, curated search results when consumers enter search queries. 2.24 Google's general search results pages return different categories of search results, including generic search results and specialised search results. In addition, Google Search may return a third category of results, namely online search advertisements. ## Understanding Social Media The Demand-Side 2.25 Social media platforms facilitate interaction between their users, allowing them to communicate with each other, and share and discover engaging content. Social media platforms are generally available through a mobile app, with some also available via a web browser.30 As with general search, providers of social media services make money by serving their consumers with paid for adverts. 2.26 Features commonly provided by social media platforms include: user profiles or accounts; user 'friends' or connections; a personalised 'feed' of news or other content; content sharing features; comments; private messaging features; and likes or 'reactions'.31 2.27 A survey by Ofcom asked users what was important to them when they accessed Facebook, Twitter, Snapchat, Instagram and YouTube. The factors that were most often rated as very or fairly important were the following:32 - keeping in touch with friends and family; - browsing to pass the time; - sharing photos and videos; - keeping up-to-date with news and current affairs; and - watching videos. ## Box 2.4: What Is Social Media? This box sets out attempts by a selection of other institutions to define social media. ## The Accc33 Social media platforms are 'online services that allow users to participate in social networking, communicate with other users, and share and consume content generated by other users (including professional publishers). Social media platforms generally display content for consumption as linear 'feeds', curated by algorithms or displayed chronologically. Examples include Facebook, Instagram and Snapchat. Platforms may also offer additional functions including instant messaging services.' ## Ofcom'S Online Nation (2019)34 'Social Media' Is Often Used Generally To Refer To A Set Of Popular Online Services, Encompassing A Range Including Facebook, Twitter, Snapchat, Instagram, Youtube, Reddit, Tumblr, Pinterest And Whatsapp. Attempting To Map The Exact Boundaries Of The Social Media Sector, However, Is More Difficult. Communicating with others through user-generated text, photos and videos might be considered the central function of 'social media' in its most basic terms - but, many online platforms facilitate these kinds of interactions. Further, whether a service is considered 'social media' can often depend on the individual using it - for instance, Reddit or YouTube could have primarily 'social' functions for some users but not others. Some companies even reject the 'social media' label - Snapchat, for instance, refers to itself as a camera company, while Pinterest' recent IPO filing emphasised its uniqueness as a 'media-rich utility'. Consequently, the concept of 'social media' has blurred boundaries that intersect with video-sharing services, blogging sites, messaging apps and forums. ## Bundeskartellamt Facebook Decision (2019)35 'It can be assumed that there is a specific demand for social networks, which is fundamentally different from the demand for other social media. The key purpose of social networks is finding and networking with people the users already know, and to exchange on a daily basis experiences, opinions and contents among specific contacts which the users define based on identity. Providers meet this demand by offering the corresponding core functionalities which grant users a "rich social experience".' ## The Supply-Side 2.28 The social media sector is generally understood to include a range of online services, including those offered by Facebook, Twitter, Snapchat, Instagram, YouTube, Reddit, Tumblr, Pinterest and WhatsApp.36 2.29 A differentiated service to consumers appears to be the main way in which social media platforms compete for consumer attention. Differentiation can incentivise consumers to access multiple platforms, allowing for the coexistence of platforms. 2.30 To create a service that is attractive to consumers, social media platforms must be able to present their users with relevant content. Successful social media platforms feature a vast quantity of content that may be shown to consumers. To prevent congestion and maintain consumer attention, platforms must determine the most relevant content for a given consumer, and the order in which to present it. They do this using an algorithm, which makes decisions based on a range of data about the consumer and the content. ## Digital Advertising Markets 2.31 Digital advertising is the largest and fastest growing segment within the UK advertising sector. According to estimates by the Internet Advertising Bureau (IAB) report,37 the UK digital advertising market was worth £13.4bn in 2018, up from £11.7bn in 2017, and now accounts for 57% of total advertising revenues.38 2.32 This increasing importance of online channels for advertising campaigns has created opportunities as well as challenges. Entirely new businesses and markets have developed in response to technological advancements offered by online advertising. And small businesses now have much improved access to flexible and targeted advertising opportunities. But on the other hand, there are many existing businesses, such as newspapers, that previously relied on traditional forms of advertising revenue that have had to adapt. 2.33 There are three broad types of digital advertising: search, display, and classified. We explain these at a high level below, and consider the markets in more detail in Chapter 5. ## Search Advertising 2.34 Search advertising is where an advertiser pays for its advert (typically in the form of a text link) to appear next to the results from a consumer's search on an internet search engine, although adverts may also appear in other forms of search, for example on maps. The selection and targeting of these adverts is based primarily on keywords entered by the user. Advertisers will pay for their adverts to be displayed when consumers enter particular keywords or phrases. 2.35 The advert shown to a consumer may also be influenced by data about the person making the search, such as their previous search history or location at the time. For example, if a consumer is searching for a 'coffee shop near me', the advert displayed will depend on a combination of which companies have purchased impressions for the keywords 'coffee shop', and on which of them are closest to the location of the user. 2.36 Consumers can then click on the text link, as they can with the other organic search results (ie those that have not been paid for). In search advertising, advertisers or their agencies generally buy direct from search providers using the providers' self-service online sales interfaces, such as Google Ads. Search advertising is aimed at driving consumers to take a particular action such as clicking a link. It is therefore used for direct response campaigns and is normally paid for on a cost-per-click (CPC) basis. ## Display Advertising 2.37 Display advertising enables advertisers to place ads on websites or apps in a variety of formats, including banner-style adverts, 'native' advertising, sponsored content, and video advertising.39 The space that the website or app owners - referred to in this context as publishers - sell for this advertising is referred to as inventory. 2.38 The display advertising sector is segmented into two channels: owned and operated platforms; and the open display market. 2.39 The owned and operated channel is primarily made up of large social media platforms, which sell their own advertising inventory directly to advertisers or media agencies through self-service interfaces. For example, an advertiser can purchase inventory directly through Facebook Ads Manager or Snapchat Ads Manager. 2.40 In the open display market, a wide range of publishers (for example, including online newspapers) sell their inventory to a wide range of advertisers through a complex chain of third-party intermediaries that run auctions on behalf of the publishers and advertisers. In practice, some of the most important intermediaries in this complex chain are owned by a single company - Google. This is particularly the case for publisher ad servers,40 supply-side platforms (SSPs)41 and demand-side platforms (DSPs).42 2.41 Though some direct deals for display advertising continue to be made through traditional channels (ie involving human interaction), the use of programmatic technology has increased over time, with the result that almost all display connecting to multiple DSPs, collecting bids from them and performing the function of exchanges. They can also facilitate more direct deals between publishers and advertisers. advertising is now sold programmatically (ie ad selection, pricing and delivery of ads is automated by computers using complex algorithms). 2.42 Programmatic display advertising provides an opportunity for businesses and other organisations to target their marketing messages to particular audiences on the basis of detailed consumer profiles. It is particularly associated with raising brand awareness and shifting brand perceptions.43 Display advertising may be sold on a CPC basis, but is more commonly sold on the basis of how many times it is viewed, referred to as cost per impression, and typically measured as cost per thousand impressions (CPM). ## Classified Advertising 2.43 Classified advertising involves advertisers paying online companies to list specific products or services on a specialised website serving a particular vertical market. Payments for classified advertising will typically consist of listing fees or commissions. 2.44 We did not find that there was a consistent industry definition for what should be included within classified advertising. For the purposes of our study, we note that there are a broad range of online platforms focused on specific sectors that provide the ability for advertisers to list specific products and services and the functionality for consumers to then make comparisons across these listings. Sectors where classified advertising is common include recruitment, ecommerce, consumer finance, travel, property and cars. We have considered the role of classified advertising previously in our Market Study on Digital Comparison Tools.44 2.45 As set out in our statement of scope, classified advertising is not a central focus of our study. ## Demand For Digital Advertising 2.46 Unlike traditional advertising channels such as television and print media, digital advertising has increasingly opened up flexible and affordable opportunities for smaller companies. The scale of the large platforms, such as Google and Facebook, provides the possibility for small advertisers to reach out to potential customers on a national scale. These platforms provide selfservice interfaces that automate and simplify the complex process of buying advertising. This makes advertising accessible to businesses with very small budgets, or even to individuals. The 2018 expenditure of the median UK advertiser on Google is £[200-300] and on Facebook only £[0-100]. 2.47 The use of media agencies is still common among larger advertisers running large multi-channel campaigns. Based on information provided by media agencies, we estimate that around a quarter of all digital advertising expenditure in the UK was channelled through media agencies in 2018. Decision-making by larger advertisers is becoming increasingly data-driven and sophisticated. The use of technology tools provided either by the platforms or intermediaries to target audiences and measure advertising outcomes at a granular level is becoming increasingly common. ## Market Outcomes 2.48 As noted in Chapter 1, several bodies and independent reviews called on the CMA to undertake this market study. One of the key motivations they cited for doing so was the fact the we have information-gathering powers, allowing us to collect data on issues and concerns where there is currently a lack of evidence. 2.49 We have used these powers to gain a more detailed understanding of how these markets work and of key outcomes within them. This work is ongoing, and in this section we set out some of our key findings to date, and highlight some of the further work we intend to do in the second half of the study. We consider three main areas: overall revenues in digital advertising; the fees charged by intermediaries in the open display market; and the profitability of Google and Facebook. ## Digital Advertising Revenues 2.50 Search advertising is the largest category of digital advertising in the UK, with our estimates of total ad spend of £6.4 billion in 2018, of which we found Google earned more than 90%. 2.51 Total spend in display advertising was worth £5.1 billion, of which we estimate more than half went directly to either Facebook or Google. Over a third was sold through the open display market. Video advertising accounts for the largest share of the display advertising market at £1.9 billion. 2.52 These estimates, based on data provided by market participants, are comparable with other publicly-available estimates. For example, the most recent IAB/PwC Digital Ad Spend report estimated that total spend on UK search advertising was around £6.7 billion in 2018, spend on display advertising was around £5.2 billion, and spend on classified advertising was around £1.5 billion over the same period.45 2.53 These splits are illustrated in Figure 2.3 below. 2.54 We have used information in Chapter 5 to estimate shares of supply for different platforms. We are continuing to extend and refine our analysis, as described in more detail in Appendix C. ## Fees Charged By Intermediaries 2.55 Several publishers have expressed concerns that a lack of transparency and competition in ad tech intermediation allows intermediaries to extract a large share of advertisers' expenditure, reducing the amount that is ultimately paid to publishers. The difference between what advertisers pay and publishers earn from digital advertising is sometimes referred to as the 'ad tech tax'. If publishers earn lower revenues than would be the case in a more competitive and transparent market, this would reduce their ability and incentive to fund quality content that ultimately benefits consumers. 2.56 Past estimates of the 'ad tech tax' vary, but they all suggest that intermediaries capture a significant portion of advertisers' expenditure. For example, research by Plum consulting indicated a range between 43% and 72%, with an average of 62%.47 Similar research by the Association of National Advertisers (ANA), the Association of Canadian Advertisers (ACA), Ebiquity, and AD/FIN found a range between 54% and 61% in relation to advertising sales in the US and Canada.48 In both cases, the estimates did not account for the possibility of arbitrage and hidden fees, nor for the potential effects of ad fraud. 2.57 We have gathered our own evidence on revenues from the main intermediaries currently operating in the UK. An advantage over previous studies is that these revenue figures should cover the vast majority of sales in the open display advertising market. Our initial estimates suggest that the weighted average DSP fee is around 18% of advertising spend (with a wide range of fees charged from 8% to 40% depending on the service provided - for example, whether there are additional fees for third-party sources of user data). We estimate that the overall weighted average of SSP/ad network fees is around 22%. These figures do not include ad server charges or other elements of the 'buy side' fee, such as agency charges and trading desk fees. In broad terms, our estimates are similar to those previously estimated by Plum and the ANA/ACA. 2.58 We have also carried out analysis of Google and Facebook's advertising revenues based on information in their management accounts. This suggests that, where small publishers use Google's AdSense for Content product to monetize their advertising inventory, Google retains on average 32% of the revenues earned from advertisers. Similarly, where small publishers use Facebook Audience Network to monetize their advertising inventory, Facebook retains on average 27% of the revenues earned from advertisers. 2.59 We are intending to carry out further work to investigate money flows along the intermediation chain in the second half of the study. We plan to extend our aggregate analysis of intermediary revenues to better understand fees in other parts of the value chain, including demand-side fees. We also intend to analyse transaction-level data from Google to understand better where Google earns its revenues from different parts of the intermediation chain, and to investigate claims that Google is able to earn 'hidden fees' by arbitraging its position on both the buy side and sell side of the ad tech stack. ## Profitability Of Advertising-Funded Platforms 2.60 As highlighted in the sections above, Google and Facebook's strong positions in the general search and social media markets respectively have translated into substantial revenues in the digital advertising market. This section summarises our initial analysis of the profits earned by Google and Facebook from these core services. 2.61 We have focused on a few standard reporting metrics to inform our analysis of these companies' revenues, costs, and profits. In particular: - We have assessed the amount of profit each company has earned in absolute terms using the metric 'earnings before interest and taxation' (EBIT). - We have analysed the level of their profits with reference to the 'return on capital employed' (ROCE). This approach compares accounting profit with the size of investment made by firms to achieve those profits. - We have compared our findings against the companies' weighted average cost of capital (WACC), which is a widely used benchmark for returns on an investment. The WACC is essentially the minimum return required on an investment or asset to satisfy the owners and creditors. 2.62 We summarise the main findings of this analysis below, while a more detailed explanation can be found in Appendix D. ## Revenues And Costs For Google And Facebook 2.63 Figure 2.4 shows the revenues and costs for Google and Facebook from 2010 to 2018. ## Profits Earned By Google And Facebook 2.64 Figure 2.5 shows their profits (measured using EBIT) in absolute terms from 2009 to 2018 for each company at the group-level based on published information. Figure 2.6 then compares our estimates of the two companies' ROCE with our estimates of their WACC - this analysis looks at the profitability of individual segments within the groups (ie the profitability of Google Search, compared to Alphabet). This is based on information supplied to us by the companies. Source: CMA analysis of Alphabet Group and Facebook financial data submissions. 2.65 We have found through our profitability analysis that the return on capital employed for both Google and Facebook has been well above any reasonable benchmarks for many years. We estimated that the cost of capital for both Google and Facebook in 2018 was around 9%, whereas their actual returns have been substantially higher, at least 40% for Google's search business and 50% for Facebook.49 This evidence is consistent with the exploitation of market power. 2.66 We explain this analysis, including sensitivities, and our full range of findings in more detail in Appendix D. ## Impacts On Consumers 2.67 Competitive markets have the potential to deliver good outcomes for consumers when sellers are incentivised to differentiate themselves from their rivals through lower prices, higher quality, or innovative new offerings. 2.68 In this study, we are assessing whether problems such as market power, lack of transparency and conflicts of interest mean that competition is not working as well as it should. There are multiple ways in which consumers could be harmed by weak competition in digital platform markets, both directly and indirectly. These are shown in Figure 2.7 and explained in more detail below. 2.69 On one side of a platform, consumers face a range of potential direct impacts from a lack competition, felt through the transactions between them and the platform. These could affect the following outcomes: - Reduced innovation - barriers to entry and expansion could weaken the incentives of new entrants, and more importantly their investors, to come forward with disruptive innovation. Instead, they might be limited to investing in innovations that complement the incumbents' services. These dynamics will also limit the incentives of incumbents to innovate themselves. The result is that the range of new features and services being brought to market is more limited than it might otherwise have been. - Poor returns to consumers - the price charged by Google and Facebook to access their services is currently zero. It's plausible that the price charged in more competitive circumstances would be negative, with consumers rewarded, financially or otherwise, for entering a search query or scrolling through their news feed. - Excessive extraction of data - consumers pay for using search and social media services through the provision of their attention and their data. In a more competitive market, consumers might not need to provide so much data in exchange for the services they value. - Lower quality of service - there are various ways that the quality of services offered by platforms might be enhanced if they were subject to more intense competition. Looking beyond the immediate quality of the core services provided (eg relevance of search results or ease of communication with friends) the platforms might be judged on a range of other factors, such as: the extent to which they protect consumers' privacy; the volume and density of adverts that they carry; how clearly and easily the adverts can be distinguished from organic content; and how easily the services can interoperate with other complementary ones. 2.70 On the other side of the platforms, a lack of competition may result in direct harm to business users. In the case of platforms funded by digital advertising, these businesses could include advertisers, publishers, advertising intermediaries, and content creators. Absent effective competition, these various businesses could expect to face lower quality services, higher prices, or a lower share of the revenues than they might otherwise expect in a more competitive market. Ultimately, we can expect these effects to be passed through to consumers with the following indirect impacts: - Price of goods and services being advertised - online platforms with market power may be able to exploit advertisers through high prices and increasing the cost of advertising. If the costs of digital advertising are higher than they would be in a more competitive market, we would expect this to be felt in the prices that consumers pay for hotels, flights, consumer electronics, insurance and many other products that make heavy use of digital advertising. - Quality and range of creative content, including journalism - for content providers such as online newspapers, digital advertising is a vital source of revenue. If problems in the digital advertising market mean that such providers receive a lower share of advertising revenues than they should, this is likely to reduce their incentives and ability to invest in news and other online content, to the detriment of those who use and value such content. At a broader social level, a thriving and competitive market for independent news and journalism is essential for an effective democracy. - Price, quality and choice in adjacent markets - a powerful platform may seek to leverage its strong position in its core market into other adjacent markets, ultimately giving itself an advantage over its rivals. The effects of limited competition for consumers discussed above are then potentially spread out to a wider range of markets. Importantly, this could act as a handbrake on innovation right across the ecosystem of online services and related technology. 2.71 This document sets out our initial findings on the level of competition faced by Google and Facebook, both in their consumer facing markets, and in digital advertising. This informs our assessment of the potential of the above harms to consumers arising in practice. ## 3. Competition In Consumer Services - Google has significant market power in the general search sector, having had a share of supply of around 90% or higher in the UK for more than a decade. - Google's strong position is primarily maintained by three key barriers to entry and expansion: economies of scale in developing a web index, access to click-and-query data at scale, and Google's extensive default positions across desktop and mobile devices. - Facebook has significant market power in the social media sector. Strong network effects mean that entry over the last decade has only been successful where platforms have provided a sufficiently different service. The evidence that we have reviewed suggests that entrants place only a limited constraint on Facebook. - By controlling (and sometimes degrading) the level of interoperability that it offers to other social platforms, Facebook may have further insulated itself from competitive pressure. ## Introduction 3.1 Online platforms that are funded by digital advertising serve multiple user groups, including consumers and advertisers.50 3.2 As discussed in the previous chapter, the high revenues that Google and Facebook generate from digital advertising are linked to their success in capturing consumers' attention and understanding their characteristics and preferences. They achieve this primarily through their search and social media platforms. 3.3 This chapter sets out our initial research and findings in relation to: - the extent of market power enjoyed by Google and Facebook on the consumer side of their search and social platforms; and - the key barriers to entry and expansion in these sectors. ## Competition In Search 3.4 Web-based search engines play an important role for consumers in the modern world, helping them to navigate the Internet, and quickly and easily find useful information in response to a broad range of search queries. 3.5 Figure 3.1 below shows the key elements of a search engine results page. When users enter queries into the search box, the search engine returns a set of organic links and may also return search adverts and other content and features. Source: CMA. 3.6 Search engines such as Google and Bing (which is owned by Microsoft) maintain an index of websites and use algorithms to determine which results to serve in response to a query. These steps can be summarised as follows: - Crawling - search engines use automated bots to crawl the web for new or updated webpages and bring data about those pages back to the search engine's servers. These bots follow links from known webpages and use known webpages' URL addresses. Search engines also make use of crawl requests and sitemaps submitted by webmasters (ie people who are responsible for maintaining websites) who want their website to be found. - Indexing - search engines record and organise data and metadata collected from crawling into an index. This data can include the title of a webpage, the words it contains and their location within the webpage, as well as metadata on the author of the page and the time the page was last updated. Search engines supplement data derived from crawling with other information. This may include, for example, local business databases or live feeds of sports scores or exchange rates. - Ranking and returning results - when users enter a search query, search engines use a series of algorithms in order to assess the intent behind the query and instantly select and return the most relevant and useful information from the index. Source: CMA. 3.7 Aside from Google and Bing, other English-language search engines do not maintain their own at-scale index of webpages, but instead buy organic links and search adverts through syndication agreements. For example, Yahoo Search (owned by Verizon Media), Ecosia, and DuckDuckGo access Bing's organic links and adverts through syndication deals.51 ## Box 3.1: History Of Search In the 1990s, at least fourteen search engines launched their services for the first time, deploying a range of different approaches to indexing and ranking webpages. - JumpStation (which launched in 1993) used a web-crawling technology to build an index of the web, 52 whereas Yahoo (which launched in 1994) relied on staff categorising websites into a hierarchical structure. - Other early launches included Lycos in 1994, Ask Jeeves (which would later become Ask.com) in 1997, and Google and MSN Search (which would later become Bing) in 1998.53 By the early 2000s, Google had established itself as one of the top search engines in the world, alongside Yahoo and MSN Search.54 - Google said that the initial innovation that drove its success was its proprietary PageRank algorithm, which judged relevance based on the number of websites linking to potentially relevant pages. - Google received a capital injection in 199755 and by 2000 it had developed the world's largest search index.56 Through the 2000s, search engines innovated through the addition of features. - By 2005, Google, MSN and Yahoo all offered web, news and images search features. Google also had shopping sites (Froogle) and Maps. MSN search had Encarta. Yahoo's features included Video, Directory and Products.57 - Google was the first search engine provider to launch a mapping product, with Maps for desktop launching in 2005 and Maps for mobile following in 2007.58 There is a long history of search providers other than Google and Bing choosing to outsource some or all of their search engine activities. - As early as 2000, Yahoo agreed to make Google its default search results provider. Yahoo's president said that 'Google will provide its underlying Web search engine to serve as a complement to Yahoo's popular Web directory and navigational guide'.59,60 - By late 2010, Yahoo had outsourced its search results and advertising to Microsoft61 and Ask.com had refocused away from developing its own search engine technology.62 - This left Google and Microsoft as the only two large web-crawling Englishlanguage search engines, which remains the case today. 3.8 We refer to Google, Bing, and the search engines that syndicate from them as 'general search' providers. These are platforms that are used by consumers to answer a broad range of search queries. 3.9 General search engines are not the only online platforms that help consumers to find information online. Online marketplaces (such as Amazon and eBay) and price comparison sites (such as Booking.com and Comparethemarket.com) also help consumers to search for certain types of information. We refer to platforms that specialise in a subset of consumer queries as 'specialised search' providers. 3.10 We first set out below how general search platforms compete, before presenting shares of supply and outlining competitive constraints faced by Google Search. We then discuss potential barriers to entry and expansion. Finally, we present our initial findings on the extent to which Google Search may hold market power. ## Parameters Of Competition 3.11 Search engines compete for consumers directly by seeking to provide highquality services. They also compete over access to consumers, through the default search positions on web-browsers and devices.63 3.12 Search engines compete for consumers over the following dimensions of quality: - Relevance of results - the ability of a search engine to return useful, relevant results in response to a range of queries is a key dimension of quality. Activities such as crawling and indexing, developing additional features, and refining algorithms each play a role in search relevance.64 ## Box 3.2: How Search Engines Measure And Improve Search Quality Search engines engage in several types of experimentation and testing in order to iterate and improve search quality.65 Firstly, search engines may conduct **live experiments**, where they direct a proportion of user traffic to a new trial version of the search engine. For example, one group of users may be served results based on the current ranking algorithm, while another group is served results based on a modified algorithm. The search engine analyses interaction data (for example, data on what links the user clicked and whether they hit the back button following a click) in order to build a picture of which version works better for users. Secondly, some search engines seek qualitative feedback from dedicated panels of human reviewers who have agreed to evaluate the product. For example, reviewers may be asked to compare two candidate sets of search results (or two candidate ways of presenting the results) and state which one they prefer. Some search engines also use human reviewers to judge various aspects of web-page quality and trustworthiness. - Ease of use - consumers also want to be able to conduct their searches effectively and efficiently. Many search engines have built 'instant answer' boxes into the search results page, reducing the need for consumers to click through to other web pages. Features such as autocomplete and voice search also contribute to ease of use. - Attractiveness of interface - search engines also compete to provide visually attractive interfaces, which can be another aspect of quality from the perspective of consumers. - Privacy and trust - some consumers prefer to accept less personalised (and potentially less relevant) search results and adverts, in return for their search engine collecting and storing less data about their searches. - User rewards and incentives - price is not a key parameter of competition in search; none of the general search engines that we heard from charge users or pay them for searches undertaken. However, some consumers value the non-monetary rewards for searches (such as promotional points or contributions to good causes) offered by certain search engines. 3.13 The evidence that we have reviewed suggests that search engines and consumers generally see relevance of results as the most important aspect of quality.66 This suggests that, in addition to any points of differentiation that they offer, competitive search engines need to at least offer a similar level of relevance to that of the market leader (Google). 3.14 Competition over quality in search plays out through various mechanisms, including in-house innovation (for example, to improve search algorithms), the acquisition of innovative companies and the signing of commercial partnerships with third parties that offer databases, maps or other features (to supplement organic links). 3.15 However, competition over access to consumers is also a very important feature of the search sector. For example, Google makes very large payments to Apple in particular in return for being the default search engine on its devices. We discuss access to consumers later in this chapter. 3.16 Search engine providers also compete to attract advertisers to their platforms, in order to fund the services that they supply to consumers. Google and Bing own and operate their own search advertising infrastructure. Other search engines rely in part or whole on search adverts that they access through syndication agreements. We discuss search advertising in Chapter 5. ## Shares Of Supply 3.17 Google has persistently had a very high and stable share of general search in the UK over the period for which data is available. As shown in Figure 3.3, based on Statcounter data on website referrals, Google's share of supply has been between 89% and 93% throughout the last ten years.67,68 Source: Statcounter Global Stats. Notes: UK data for June 2009 - June 2019. * Bing's share represents that of Bing and MSN Search. MSN was rebranded as Bing in 1998. † 'Other' consists of: AlotSearch; AVGSearch; Babylon; Baidu; Conduit; NortonSafeSearch; Snapdo; Webcrawler; WindowsLive; Yandex; and 'other'. 3.18 MSN (now known as Bing) overtook Yahoo Search in 2009 and these search engines have continued to be the second and third biggest providers in the UK throughout the subsequent ten years. 3.19 After Google, Bing and Yahoo Search, DuckDuckGo and Ecosia are among the next most popular search engines in the UK as of 2019. DuckDuckGo was launched in 2008 and Ecosia launched in 2009. Both of these search engines use Bing search results and adverts and had a share of less than 1% of general search as of 2019.69 3.20 Google's share of supply is very high in desktop search and close to 100% in mobile search. Bing has a larger share of desktop search than mobile search. As of 2019: - Google's share of supply in search is 92% overall, 97% on mobile devices and 86% on desktop devices. - Bing's share of supply in search is 5% overall, less than 2% on mobile devices and 11% on desktop devices.70,71 3.21 Overall, the evidence we have seen suggests that many consumers mostly use one general search engine per device. For example, research by Google into the desktop sector in the US found that around 70% of consumers use either Google or Bing exclusively, and around 30% use both. Google's very high share of supply in mobile search suggests that the proportion of consumers using only one search engine is higher still on mobile devices. 3.22 Several factors may explain why consumers do some searching on a second search engine. Firstly, they may face different defaults on different devices. Secondly, some consumers may actively choose to use a different search engine for certain tasks.72 3.23 In the section below, we consider sources of competitive constraint on Google Search, including from rival general search platforms and specialised search platforms. ## Competition Between General Search Platforms 3.24 Google Search has played an important role in helping consumers to navigate the Internet since its launch in 1998 and is well-known for introducing innovations to web-based search, including its 'PageRank' algorithm. 3.25 As by far the most-used general search engine in the UK, Google handles a larger volume of UK search queries and operates a larger volume of UK search advertising inventory than its competitors. Microsoft indicated that Google's greater scale enables it to more easily deliver more relevant results for users and to attract more advertisers. Other general search engines identified Google as their main competitor or as one of their main competitors (alongside Microsoft Bing). 3.26 As discussed above, relevance of results is widely viewed as the most important aspect of quality for consumers. Relevance is subjective and there is no single measure that is used across the sector to compare different search engines. However, the evidence that we have reviewed to date, which includes internal documents and consumer research submitted by parties, suggests that consumers generally view Google's English-language search results as being more relevant than those of other search engines. For example: - Google submitted UK consumer research in which Google search results were rated more highly than those of other search engines, including in relation to 'random queries'. - Google also submitted research showing that a sample of US consumers had identified 'quality and relevance', along with 'familiarity and habit', as their top reasons for using Google Search. - Microsoft submitted internal documents stating that Bing was 'trailing' Google on relevance in a number of regions outside of the US. - Microsoft told us that Google's perceived advantage on relevance among consumers especially applies to uncommon queries (also known as 'tail queries') and that Google has richer local and specialty results. Tail queries account for a significant proportion of the traffic seen by search engines. For example, Google said that about 15% of its daily traffic is comprised of queries that it has never seen before. - Microsoft submitted qualitative research that indicated that the perceived relevance of results was a source of relative weakness for Bing in the UK. This study was based on discussions with a small number of Bing users. 3.27 The 'Google' brand is closely associated with the act of web-searching and several competitors highlighted this as a source of strength. DuckDuckGo submitted that 'users have come to expect Google as the default and think of it synonymously with search. Even die-hard DuckDuckGo users still say they "Google it."' 3.28 Google's competitors also cited its search default positions as a source of strength. As discussed in the sections below, Google Search holds extensive default positions across nearly all UK mobile devices and a large proportion of UK desktop devices. Meanwhile, Bing holds default positions on Windows PCs, through Microsoft's agreements with Windows PC manufacturers. 3.29 Google submitted that Bing was the main competing general search engine to Google Search in the UK. Aside from Google, Microsoft is the only other search engine provider that maintains an at-scale English-language index and produces its own organic search results and search adverts. 3.30 Microsoft said that Bing's strengths relative to Google are that it is a good alternative for consumers for most of their likely search queries (ie common queries) and for those who dislike Google. One way that Bing differentiates from Google is through Microsoft Rewards. Under this scheme, signed-in Bing users receive promotional reward points for undertaking searches.73 3.31 In addition to their general search functions, both Google Search and Bing offer a wide range of search features. For example, both allow consumers to make specific searches for images, videos, maps, shopping and flights.74,75 An internal document from Google comparing its own business to other search engines including Bing, DuckDuckGo and Ecosia stated that 'Google leads in search features (coverage and utility)'. 3.32 Google highlighted its recent innovations in areas such as 'activity cards',76 visual previews and artificial intelligence. It said that the actions of its general search engine competitors were not a significant consideration behind these investments, because its main focus is innovating to improve the user experience. We consider that Google's investments in search features may have several motivations. While some may be motivated by retaining search customers, others may in part reflect a desire to expand into new markets. 3.33 Other general search engines used by UK consumers include Yahoo Search, Ecosia and DuckDuckGo. As explained above, each of these relies on search results and adverts from Bing.77 DuckDuckGo has a focus on privacy and describes itself as 'the search engine that doesn't track you',78 while Ecosia is a 'purpose company', whose advertising profits are reinvested or used to plant trees.79 3.34 Downstream search engines with syndication business models appear to provide some fringe competition to Google.80,81 However, we consider that competition to Google from platforms that do not produce their own organic links and adverts is likely to be limited in scope. 3.35 In summary, Google has been by far the most-used search engine in the UK for at least a decade. We consider that Bing is Google's closest competitor in general search. However, as discussed later in the chapter, several barriers to expansion appear to limit the degree of competition to Google from Bing and other search engines alike. ## Competition Between Google Search And Specialised Search Platforms 3.36 Google submitted that it also faces competition from a range of vertical or specialised search platforms in relation to different types of product query, including Amazon in retail and Booking.com in travel. 3.37 We note that, from a consumer perspective, there are substantial differences between general search and specialised search. Firstly, general search engines help consumers with a wider range of queries including many that are not served by specialised providers. Secondly, general search engines can lower transaction costs for consumers, by reducing the need for them to manually navigate between multiple websites and apps. 3.38 In practice, Google Search often serves as a gateway to specialised search rather than an alternative.82 As discussed in Chapter 5, there is some evidence that Amazon is less heavily reliant on Google than other specialised search providers and may compete directly with Google in relation to retail search advertising. However, retail queries only represent one element of what consumers want from general search. Overall, we consider that Amazon is likely to provide only a limited competitive constraint to Google Search on the consumer side of the platform. 3.39 We also note that competition between general and specialised search has been looked at before by the European Commission in its Google Search (Shopping) investigation, which found specialised search and general search services to be in distinct markets.83 3.40 Overall, we consider that specialised search providers are likely to provide only a limited competitive constraint to Google Search on the consumer side of the platform. ## Barriers To Entry And Expansion In Search 3.41 Having considered sources of competitive constraint on Google Search, we now discuss potential barriers to entry and expansion that may prevent other search engines from acting as an effective constraint. ## Web-Crawling And Indexing 3.42 In order to return relevant search results, search engines must be able to draw on an index that provides an up-to-date picture of a very wide range of relevant webpages (or else syndicate results from a provider that does so). 3.43 Google and Microsoft are the only two search engine providers that maintain at-scale English-language web indices.84 The main way that they acquire information for their index is through their automated web-crawling bots. These bots follow the links between webpages and bring data about those pages back to the search engine's servers. 3.44 Based on submissions from these parties, Google's index contains around [500-600 billion] pages and Microsoft's index contains around [100-200 billion] pages. Our understanding is that the total number of pages in a web index is only one measure through which indices can be assessed; the relevance of the pages in an index is also important, as is the extent to which an index is up-to-date. 3.45 Crawling and indexing the web represents a significant cost for those search engines that do it. Microsoft estimated that its indexing investments added up to billions over time, while other estimates have suggested that Google and Bing spend hundreds of millions of dollars a year on this activity.85 3.46 Developing a web-index is subject to economies of scale; the costs associated with crawling and indexing do not increase proportionally with the number of users of the search engine. It is difficult for smaller search engines to invest in at-scale crawling and indexing, since their ability to repay these costs and earn a return on investment is contingent on their ability to secure the other inputs necessary to compete effectively in search. For example, they would also need to achieve scale in both search queries and search advertising, in order to offer relevant results and monetise effectively. 3.47 Some parties suggested that crawler-blocking is an issue for web-crawling search engines. The mechanism for crawler-blocking is that webmasters (ie people who are responsible for maintaining websites) place robots.txt86 files on their websites, requesting that some or all crawlers do not access all or parts of the website. We heard that website owners may have legitimate motivations for doing so. For example, motivations can include fraud prevention and avoiding the increased running costs that can result from a large number of automated bots crawling a website. 3.48 We heard that, when web-crawlers encounter blocking, search engine providers can contact webmasters to seek a change of policy. However, the effort and cost of doing so means that search engines that are subject to fewer blocking instructions may have an advantage. 3.49 Microsoft submitted that while, overall, its index was competitive with Google's, a small fraction of sites have robot.txt files that enable Google to crawl the site but prohibit Bing. Microsoft gave several examples of websites that allow crawling by Google but prohibit crawling by Bing over all or part of the site. These include eBay's UK website,87 the UK Passport Service website,88 and the London Stock Exchange website.89 Its main concern was that user impression of Bing search quality would be harmed if several high profile websites were not properly searchable. 3.50 Yandex (which has a more-than 50% share of search in Russia) and Mojeek (a small UK-based search engine) indicated that crawler-blocking was not the main barrier to them expanding their English-language web-indices. Rather, economies of scale and other issues were more important. However, Cliqz said that it had incurred 'significant business development expenses' over the last 5 years by having to contact popular publishers to gain permission to crawl their websites. 3.51 Our own research into this issue found that the web-crawler bot of a new search engine that honoured all robots.txt would have access to approximately 0.2% fewer sites compared to Google and Bing. We found that the difference between the proportion of sites providing access to Google and the proportion providing access to Bing was smaller still. Therefore, differences in access levels provided to search engines appear to be small in numerical terms. However, if even a small number of popular sites cannot be crawled by some search engines, this could limit the ability of those search engines to return high-quality search results to certain queries. Our research, which is based on a limited sample of domains, is set out in Appendix E. We would welcome further evidence and views on whether crawler-blocking is a significant barrier to the development of at-scale web-indices. 3.52 In summary, Google and Microsoft are the only two providers that undertake English-language web-crawling and indexing at a scale that can support a competitive search engine in the UK. We consider that this reflects substantial scale economies in crawling and indexing, plus uncertainty for other search engines as to whether they can secure the other inputs (including sufficient scale in search queries and adverts) needed to earn a return on these investments. In combination, these factors represent a barrier to entry and expansion for English language web-crawling search engines. We discuss scale-effects in search queries and adverts in the sections below. ## Scale Effects In Click-And-Query Data 3.53 Network effects occur when the value of a service to its users increases as the total number of users increases. Search engines are subject to same-side network effects, in the sense that users benefit from increased quality as the search engine acquires a greater number of users.90 3.54 The main mechanism for this is that search engines can improve their ranking algorithms, and return more relevant results to a user, when other users have entered similar search queries in the past. 3.55 Search engines collect and store aggregated 'click-and-query' datasets containing information about what users searched for and how they interacted with the results that they were served. They collect this data from searches others to crawl and index the website. It could also include prioritising submitting updated site maps and crawl requests to popular search engines but not others, which helps popular search engines have more up-to-date results. Second, the more websites optimise their website to be more easily found by a search engine, the better its quality of search results which helps it to attract and retain more users. The evidence that we have reviewed so far suggests that this cross-side network effect, which is discussed in the section on web-crawling and indexing above, is not as significant as the same-side network effect from improvements to returning more relevant results to a user detailed in this section. undertaken on their own platforms and, where applicable, searches undertaken on the platforms of their downstream syndication partners. 3.56 Click-and-query data plays an important role in helping search engines to improve the relevance of results. It helps search engines to understand how well their product is performing and to identify and test potential improvements, such as changes to ranking and spelling correction algorithms.91 3.57 This data is particularly important to search engines that produce their own organic links (for example, Google and Bing), but certain click-and-query data is also collected by syndicator search engines, for example, to test how well instant answers and other features that they control are performing. 3.58 The evidence that we have reviewed so far suggests that: - There are advantages to scale in click-and-query data - in general, search engines that see more queries (and more consumer responses to those queries) can engage in increased experimentation and learning about what consumers want, and have greater possibilities to iterate and improve their service. - The marginal benefit of additional data depends on how common and fresh the queries are - where a search engine sees a search query very frequently (sometimes referred to as 'head queries') and where the user intent behind that query is static, then the marginal benefit from seeing that query more often is likely to be relatively low. Conversely the marginal benefit of seeing a query more often will be higher for uncommon queries (sometimes referred to as 'tail queries') and for queries where the user intent changes over time (these are known as 'fresh queries').92 3.59 Both Google and Microsoft said that a substantial proportion of queries that they see are uncommon or new: queries'). - Google submitted that the proportion of its daily traffic which are queries that it has never seen before 'has remained constant at about 15% for many years'. - Microsoft submitted that roughly 36% of the search queries run on Bing are entered 10 or fewer times in a month. 3.60 This indicates that, for a substantial proportion of search queries, there is a material benefit to both Google and Bing from receiving additional queries of the same type. 3.61 As the most-used search engine, we expect that, on average, Google sees each uncommon query more times than Bing in a given time period. We consider that, in particular, this is likely to support Google's ability to serve more relevant results to uncommon queries compared to Bing. Given the importance of relevance to consumers, even if this advantage for Google is only substantial for a modest proportion of search queries, it is likely to further reinforce consumers' perceptions of Google as the highest-quality search engine and make them less inclined to consider alternative providers. 3.62 Importantly, any search engine seeking to improve its relevance and compete with Google faces a chicken-and-egg problem; clicks help improve relevance, but relevance is needed to attract clicks. Overall, our initial assessment is that the greater scale of English-language queries seen by Google is likely to support its ability to deliver more relevant search results compared to its competitors, especially in relation to uncommon and fresh queries. Given the importance of search relevance to consumers, lack of comparable scale in click-and-query data is likely to limit the ability of other search engines to compete with Google. ## Syndication Agreements 3.63 As highlighted above, search engines including Yahoo Search, DuckDuckGo and Ecosia access Bing search results and adverts through negotiated syndication agreements. 3.64 Under syndication agreements, the upstream provider (Google or Bing) agrees to provide search results and adverts, and the downstream provider incorporates these into its own search engine product, under its own branding.93 The downstream provider may supplement the syndicated results and adverts with additional information and features. ## Box 3.3: The Role Of Syndicators From A Consumer Perspective Search engines that rely on syndications agreements present organic search results produced by Bing or Google. So how do these syndicators differentiate themselves? At present, we understand that sources of differentiation include: - Social purpose - some syndicators spend part of their search advertising revenues on social or charitable causes. - Privacy - some syndicators say that they do not log or store information about user searches. - Search features - when users enter search queries, syndicators and their upstream partners alike often serve additional features (such as map extracts, news clippings and weather forecasts), alongside organic links and adverts. Some syndicators serve different features compared to their upstream partner. It is possible that syndicators could play a more distinct role in the sector in future. For example, we are not aware of any current syndication agreements that allow syndicators to re-rank the organic search results that they receive from Google or Bing. If this were to change, then syndicator search engines may be able to differentiate themselves more strongly. 3.65 In the agreements that we have seen, advertising revenues arising from clicks on search adverts on the downstream search engine are generally shared between the two parties. In addition, or instead, the downstream provider may be charged a fixed fee per 1,000 search requests and certain additional fees. 3.66 From the perspective of upstream providers, syndication agreements act as a distribution channel for their search results and adverts and help them to achieve greater scale. This may lead to direct benefits, in the form of revenueshare and other payments made by the downstream partner. In addition, these agreements help upstream providers to build greater scale in click-andquery data and in search advertising, which may in turn help the provider to improve its search relevance and search advertising monetisation.94,95 3.67 From the perspective of downstream providers, syndication agreements can provide them with a viable means of competing in search. As highlighted above, competitive web-crawling search engines have to overcome a series of interrelated challenges including developing sufficiently relevant search results (through at-scale crawling and indexing and at-scale access to customers and clicks) and developing an at-scale advertising platform (which also requires at-scale access to customers and clicks). By contrast, syndication strategies appear to be lower cost and lower risk.96 Several downstream providers indicated that, in combination, the barriers to developing their own competitive results and adverts were not surmountable, leaving syndication as the only viable option. 3.68 As the only at-scale English-language web-crawling search engines, Google and Bing will naturally have a strong bargaining position in discussions with downstream search engines. As a result, they may choose not to offer agreements to some providers, or may insist on terms that limit the ability of downstream providers to compete. For example, Ecosia said that it had approached Google many times over the years but that Google had always declined its request. In addition, none of the syndication agreements that we reviewed allows downstream providers to re-rank the search results that they received. Several downstream providers said that they would like to be able to modify search results, in order to improve their ability to differentiate. 3.69 We consider that downstream search engines with syndication business models have provided some fringe competition to Google, by taking Bing's organic results and adding their own selling points and features. However, there are limits to the degree of competition that can come from businesses that do not produce their own organic links and search adverts. In particular, search engines that rely on Bing's organic links (including Yahoo Search, DuckDuckGo and Ecosia) are likely to be constrained in their ability to compete with Google on search relevance. In addition, the syndication terms currently available appear to be further limiting the ability of search engines with syndication business models to differentiate from their upstream partners and play a more substantial role in the competitive process. ## Other Supply-Side Barriers 3.70 Some parties highlighted additional supply-side barriers to entry and expansion. 3.71 Microsoft suggested that accessing at-scale location data from user devices is a critical input to providing relevant, localised results. It indicated its belief that Google has unique advantages in this area, due to the location data that it receives from the Android operating system and the location data it receives when users access Google Search or other apps like Google Maps/Waze. As noted above, Google Search accounts for almost all of the mobile search sector in the UK (97%). 3.72 We consider that limited access to consumer location data may limit the ability of search engines other than Google to return relevant results to local queries. We would welcome further submissions on this point. 3.73 Some parties highlighted broader economies of scale in search, in addition to those that relate to investments in a web-index. For example, Ecosia said that developing additional content around the organic links that it syndicates from Bing is subject to clear economies of scale, because the product development effort is fixed, regardless of the number of consumers served. Google said that, 'apart from limited economies of user data scale, Search does not enjoy significant benefits from its scale in other areas'. ## Consumer Access To Search And Default Arrangements 3.74 Consumers generally access search engines on mobile and desktop devices through web-browsers or search widgets.97 In many cases, mobile and desktop devices come with a default browser and widget which, in turn, feature a default search engine.98 3.75 In their submissions to the CMA, a range of search engines indicated that defaults play an important role in influencing consumers' usage of search engines.99 3.76 Google owns the popular web-browser Chrome, which has Google Search set as the default search engine. Google has also negotiated default agreements with Apple and with many of the largest Android mobile phone manufacturers and mobile phone networks. Google pays a share of search advertising revenues to these partners in return for Google Search occupying the default search positions on devices. 3.77 For example, Google's agreement with Apple means that, by default, any search queries typed into the Safari explorer bar are executed by Google Search. 3.78 In relation to desktop devices, Microsoft pays Windows PC manufacturers to pre-install Microsoft web browsers which have Bing set as the default search engine. 3.79 Several pieces of evidence indicate the importance of default positions in the general search engine sector. 3.80 Firstly, we have viewed internal documents submitted by Google which suggest that at least part of the rationale for entering into default agreements is to make Google's search advertising revenues more secure. For example, an internal document referred to search advertising revenues as being 'exposed' where these came from mobile devices for which Google did not have a default agreement in place. 3.81 Secondly, the high level of default payments, known as 'traffic acquisition costs', made by Google in particular demonstrates that it values these default positions highly. In 2018, for mobile devices alone,100 Google paid around $1.3 billion USD for default positions in respect of UK consumers. This was around 16% of Google's total annual UK search revenues. The vast majority of these payments were to Apple. The default payments that Microsoft made to Windows PC manufacturers in the same year in respect of UK consumers were significantly lower and equated to a lower proportion of Bing's annual UK search revenues. 3.82 Thirdly, there is positive correlation between the defaults held by search engines and the search traffic that they receive. For example, while Google is the largest search engine in the UK across mobile and desktop devices, its share of search is relatively higher in mobile, where it occupies default positions across a relatively greater proportion of the UK browser sector. Source: CMA Analysis of Statcounter Global Stats. Notes: UK data for June 2019. Laptops are included in desktop devices. Tablets are included in mobile devices. 3.83 As shown in Figure 3.4, Google holds default positions across a relatively larger part of the UK mobile browser sector (99%) than the UK desktop browser sector (84%). In turn, Google has a relatively higher share of supply in mobile search (97%) than it does in desktop search (86%). A similar correlation can be observed for Bing. Bing holds default positions across 16% of the UK desktop browser sector and almost none of the UK mobile browser sector. Bing's share of supply is much higher in desktop search (11%) than in mobile search (less than 2%).101 ## Box 3.4: Android Choice Screens Following the European Commission's Android decision in July 2018, Google announced that users would be provided with a choice screen of general search providers on all new Android phones and tablets in the European Economic Area, including the UK, where the Google Search app is pre-installed.102 The choice screen will appear during initial device setup for new devices distributed in the EEA on or after March 1, 2020. It will feature multiple search providers, including Google, and users will be required to choose one search provider from the choice screen during setup. The effect of a user selecting a search provider from the choice screen will be to (i) set the search provider in a home screen search box to the selected provider, (ii) set the default search provider in Chrome (if installed) to the selected provider, and (iii) install the search app of the selected provider (if not already installed). Stakeholders' views regarding the likely effectiveness of this choice screen at improving competition are described in Appendix J. 3.84 The power of default settings is an area of behavioural economics that has been well researched and is well-evidenced across a wide range of settings, such as pension savings, medical insurance and food consumption. There is a general recognition that the presence of status quo bias means that individuals will often stick with the default choices they are presented with. 3.85 The influence of defaults in general search is likely to be underpinned by several factors. Firstly, consumers may not understand that they can change the default search engine on a device or in a browser. Secondly, they may be put-off by complexity or other hassle factors. For example, Ecosia told us that Google displays a warning notice when consumers seek to change the default search engine in Chrome or on Android devices and that this discourages consumers from following through with a switch. Thirdly, consumers may perceive little benefit to changing defaults, especially if the default search engine is the market leader (Google) and the alternatives are not well understood. Finally, when consumers do seek to change the default search engine on their browser or device, their choice may be reversed following software updates. 3.86 Several providers told us that they were unable to compete with Google for default positions due to the scale of payments required. Microsoft suggested that Google has been able to secure default placement on Android and Apple devices and that this was likely due to its ability to share large amounts of search revenues resulting from its market position in search. 3.87 Google indicated that the level of revenue share payment that it offers was a secondary consideration for mobile phone manufacturers and mobile phone networks and that it primarily competes for default positions on the basis of search quality. Apple told us that it selected Google as the default search engine on its products because that is what most consumers want. 3.88 Overall, we consider that Google's ability to conclude default agreements across very large parts of the desktop and mobile landscape acts as a barrier to expansion for other search engines, making it more difficult for these providers to grow their user bases and improve their search quality and search monetisation rates. 3.89 In addition, we consider that there is likely to be a positive feedback loop between Google's position as the largest and most revenue-generating search engine and its ability to acquire extensive default positions that further reinforce this position.103 ## Scale Effects In Search Advertising 3.90 Search engines are also subject to cross-side network effects. Search engines become more valuable to advertisers as the number of consumer queries and clicks increases. Therefore, more popular search engines may be able to use their higher advertising revenues to fund improvements in search quality and, in turn, attract more consumers. We heard that smaller search engines running their own advertising platforms would not be able to monetise effectively unless they attract a critical mass of consumers. This may further impede their ability to grow and compete with larger incumbents. We discuss barriers to entry and expansion that relate to the advertising-side of search in Chapter 5. ## Initial Findings In Search 3.91 Search engines play an important role for consumers in the modern world, helping them to navigate the web, and quickly and easily find useful and interesting information. Google Search in particular is well-known for providing a high-quality search product and for introducing a series of search-related innovations, from PageRank to Google Maps. 3.92 The evidence that we have reviewed so far suggests that Google has significant market power in general search. 3.93 Google has had very high and stable shares of supply in both mobile and desktop search in the UK for at least the last ten years. We consider that innovation played an important role in helping Google to build its customer base in the early years of web-based search: it grew by offering a high quality product that consumers valued. However, general search is now subject to significant barriers to entry and expansion, which together limit the current and potential competitive threat faced by Google. 3.94 In order to compete effectively, search engines must be able to access consumers and deliver relevant results to a wide range of queries. The key inputs to achieving relevant results include click-and-query data and a webindex. 3.95 Web-index development is subject to economies of scale; search engines with a web-crawling business model need to make substantial server and engineering investments against a backdrop of uncertain returns. 3.96 Click-and-query data is also subject to scale effects. Google's greater scale supports its ability to iterate and improve quicker than other search engines and maintain a lead on search relevance. By contrast, rival search engines seeking to improve their relevance face a chicken-and-egg problem; clicks help improve relevance, but relevance is needed to attract clicks. 3.97 We consider that Google's extensive default positions across the desktop and mobile landscape act as a significant barrier to expansion for rival search engines, by limiting their ability to grow into stronger competitors over time. As the market-leader, Google is able to pay more for these default positions than other search engines. This makes it more difficult for other search engines to get their products in front of potential users and to iteratively grow their scale and improve their search quality and search monetisation. 3.98 Scale effects also apply on the advertising-side of search engine platforms. In particular, we heard that smaller search engines running their own advertising platforms would not be able to monetise effectively unless they attract a critical mass of consumers. This creates an additional barrier to expansion. We discuss this further in Chapter 5. 3.99 Syndication agreements enable search engines that lack scale in consumers and advertising to participate in the search sector. However, the most-used syndicating search engines in the UK (such as Yahoo Search, DuckDuckGo and Ecosia) rely on Bing's organic results and appear to represent only a fringe source of competition to Google. 3.100 The combination of barriers to entry and expansion above may negatively affect consumers in several ways. Firstly, Google is likely to face weaker incentives to keep improving Google Search in the interests of consumers, compared to a scenario where it faced a stronger competitive threat. For example, Google may choose to invest less of its profits in further improving search relevance compared to a more competitive scenario. Secondly, Google may be able to collect more consumer data (or offer consumers worse terms in return for their data), compared to a scenario where it faced a stronger competitive threat from other search engines. We discuss consumer control over data in Chapter 4. Finally, consumers may be harmed indirectly through higher prices for other goods and services, if Google is able to use its market power over consumers to raise search advertising prices above competitive levels. We discuss competition in digital advertising in Chapter 5. ## Competition In Social Media 3.101 As set out in Chapter 2, we use the term 'social media' to describe a range of online platforms that allow consumers to communicate with each other and share and discover engaging content. 3.102 In general, social media platforms have some common features such as: consumer accounts or profiles, which allow consumers to create an online persona; messaging features allowing consumers to communicate directly with others; and a 'feed' or homepage where consumers can engage with organic content including posts, photos and videos. In addition to featuring this organic content, most social media platforms also feature adverts, as shown below in Figure 3.5. Source: CMA. 3.103 We consider a sample of the largest platforms that meet this description in this chapter, specifically: YouTube; Facebook.com; Snapchat; WhatsApp (owned by Facebook Inc.); Instagram (owned by Facebook Inc.); Twitter; LinkedIn; TikTok; Pinterest; Reddit; Tumblr.104 Of these, Facebook.com and YouTube have had by far the greatest shares of supply for at least the last five years.105 In this chapter we assess the competitive positions of Facebook and YouTube and the competitive constraints that each faces. 3.104 A key aspect of competition amongst social media platforms is their ability to offer consumers a different experience from the others. Social media platforms differentiate by focusing on different functions and delivering these in different ways. Relatedly, there is some debate as to whether platforms that are closely focused on either direct communication (for example, direct messaging services such as WhatsApp) or content consumption (for example, video platforms such as YouTube) should be considered social media platforms. We have included these platforms in our analysis in order to support a more extensive assessment of the positions of Facebook (which includes the Facebook.com, Instagram and WhatsApp platforms) and Google (which owns YouTube). 3.105 We first set out below how social media platforms compete, before presenting shares of supply and outlining the current state of competition in the UK's social media sector. We then discuss potential barriers to entry and expansion. Finally, we present our initial views on the competitive constraints faced by Facebook and to what extent it may hold market power. ## Parameters Of Competition 3.106 Generally, consumers access social media platforms to communicate or interact with other consumers and to view content. 3.107 Social media platforms compete for attention along the parameters listed below: - Innovation - offering innovative new ways to communicate or consume content may attract consumer attention. Platforms therefore compete to offer new features that will attract consumers. Platforms may also innovate by improving on existing features. - Size and type of user base - generally, a social media platform with a larger consumer base is more likely to be attractive to consumers as there is a greater chance that other consumers they want to interact with are on the platform.106 Advertisers are also more likely to want to advertise on platforms with a larger user base as this gives them access to a wider audience. Platforms may also choose to differentiate by focusing on attracting particular types or groups of consumers. - Content featured - successful social media platforms must be able to show consumers interesting content to keep them engaged, with platforms competing to provide this content. The type of content displayed by platforms can vary. All social media platforms allow consumers to share their own content, known as 'user generated content'. Content may be personal to consumers eg photos of themselves or their friends. Other content may be related to consumers' interests, such as posts on sports or current events. Many platforms also feature professional content produced by third parties. - Ad load and quality of advertising - social media platforms need to monetise to be successful in the long-term. Typically, they do this by displaying adverts. However, greater levels of advertising are generally disliked by consumers, so platforms typically self-enforce rules on the quantity and quality of advertising that may be displayed. Platforms may also provide consumers with controls over the advertising they are shown. - Price - social media platforms generally offer services to consumers at zero monetary cost. However, some services can also be provided on a subscription basis.107 - Privacy - consumers may wish to control the extent their activity on platforms can be viewed by other users and external parties. Platforms may therefore compete to offer better privacy controls to consumers.108 - Platform 'governance' - as social media platforms allow consumers to share content, it is possible that negative or harmful content may be uploaded and displayed. Platforms must therefore moderate content posted to prevent negative content from degrading consumers' experience.109 3.108 As noted above, consumers access social media platforms to communicate with other consumers and experience engaging content. A wide range of platforms provide features that allow consumers to do a combination of these activities, and many offer similar functionalities as shown by Table 3.1 below: Followers/ Subscribers Photo Sharing Video Sharing Comments Messaging Profile/ Account Friends/ Contacts/ Connections Curated/ Personalised Feed YouTube  Recommended       Facebook.com  News Feed       Snapchat  Discover      WhatsApp      Instagram  Explore       Twitter  Timeline    Replies  LinkedIn         TikTok  For You      Pinterest     *   Reddit  Front Page       Tumblr  Dashboard      Source: Adapted from Ofcom (2019), Online Nation. * Available on iOS only 3.109 Social media platforms sometimes also offer consumers features that allow them to interact with the services of other social media platforms, through 'open source APIs'. We discuss these features further in the 'Barriers to entry and expansion' section below. 3.110 While they have similar broad functionalities, as shown by Table 3.1, social media platforms are differentiated in some important ways. An important aspect of platforms' differentiation appears to be the extent to which they emphasise promoting communication between their users as opposed to the consumption of content: - Snapchat, a more recent entrant, is an example of a communicationfocussed platform. Snapchat emphasises communication amongst close friends, through visual rather than text-based messages. See more information in Box 3.5. - Content-focused platforms include TikTok and Pinterest. TikTok allows consumers to create and share content in the form videos of up to 15 seconds.110 Pinterest offers features allowing for consumer communication, but as a visual 'discovery tool' is more commonly used for its content offerings. - Facebook.com offers a range of services across the communicationcontent spectrum, from its communication focused 'Messenger' product to the more content-oriented 'Facebook Watch'. Facebook-owned Instagram is primarily used by consumers for viewing and sharing visual content. Facebook-owned WhatsApp is generally used for private communication between (groups of) consumers. Therefore, Facebook offers a broad spectrum of communication and content-based differentiation through multiple platforms. 3.111 As well as positioning themselves differently with respect to a balance of communication and content, social media platforms often also differentiate on the basis of one or more of the characteristics described earlier in the chapter. For example: - LinkedIn is positioned as a social media platform for consumers' professional networks. In this respect, LinkedIn has differentiated itself by focussing on a particular type of consumer. - Pinterest is particularly popular with consumers seeking to experience content relating to specific interests, including food and drink, travel, style and beauty, and fitness. - Snapchat's ephemeral features mean that it is generally considered a more 'private' platform than its competitors, encouraging its users to present themselves more authentically. - Twitter originally differentiated itself by limiting the length of its users' posts, with consumers only being able to make text posts of 140 characters or less.111 3.112 Consistent with social media platforms' differentiated strategies, consumers access different platforms for different reasons. For example, a platform that is oriented more towards communication may be more commonly accessed by consumers to have conversations with friends than a platform oriented more towards content. Social media platforms compete more closely (on the consumer side) if they are generally accessed by consumers for similar reasons. Facebook's platforms will therefore likely face the greatest constraint from platforms accessed by consumers for broadly similar reasons. Box 3.5: Recent entrants In the last ten years only Instagram and Snapchat have entered the social media sector and grown to account for a share of more than 5% of consumer time spent on social media platforms in the UK. Both entered by offering consumers differentiated experiences and features: - **Instagram** began as a photo sharing app in 2010 and differentiated itself to consumers through its emphasis on visual content. Though Instagram has the second largest consumer base it is not a competitive threat to Facebook.com, having been acquired by Facebook Inc. in 2012. As well as growing its user base, Instagram has been successfully monetising its services. However, it is unclear whether Instagram would have been as successful in monetising without Facebook's wider resources. Facebook told us that it has experienced economies of scope resulting from Instagram using Facebook.com's advertising infrastructure, but that these do not serve as a barrier to entry. - **Snapchat** entered in 2011 with a then-unique offering that allowed consumers to send contacts photos that would disappear after a specified period of time. Snapchat has been successful in generating consumer engagement and is particularly popular with younger demographics. However, Snapchat has been less successful than Instagram at monetising its services, despite achieving comparable levels of consumer engagement in terms of consumer time spent on the platforms.112 This is suggestive of Facebook's wider resources having contributed to Instagram's success. We note that both Instagram and Snapchat remain significantly smaller than Facebook.com. ## Shares Of Supply 3.113 Facebook.com and YouTube (owned by Google) are by far the largest social media platforms in the UK, both in terms of the number of consumers accessing them and the amount of time that consumers spend on them. 3.114 As shown by Figure 3.6, both Facebook.com and YouTube seem to be consistently growing their user bases. Facebook.com has an audience of over 42 million users in the UK, accounting for 83% of the British online population.113 YouTube is even larger, with an audience of almost 46 million users accounting for 91%. In contrast, Instagram with the next largest audience, reaches only 56%. Source: Comscore MMX MP, Total Digital Population, Desktop aged 6+, Mobile aged 13+, July 2015 - June 2019, UK Notes: In November 2018, Comscore altered its methodology which contributes to the discontinuities in the data around this date. * Including Messenger. 3.115 Facebook.com and Google-owned YouTube also account for the greatest share of consumer time spent on social media platforms in the UK. As illustrated by Figure 3.7, both have had consistently high shares for the entire period for which we have data. Source: Comscore MMX MP, Total Digital Population, Desktop aged 6+, Mobile aged 13+, July 2015 - June 2019, UK Notes: In November 2018, Comscore altered its methodology which contributes to the discontinuities in the data around this date. *Including Messenger. 3.116 As above, YouTube is a content-focused platform and appears to compete more closely with providers of audio-visual content (including music streaming platforms and video streaming platforms) rather than Facebook's social media platforms. We have therefore also calculated shares of supply based on consumer time spent on the platforms, excluding YouTube. 3.117 When YouTube is excluded, Figure 3.8 shows that Facebook.com had a share of 58% of time spent on social media platforms in the most recent period. Therefore Facebook.com has by far the greatest share of consumer attention amongst the social media platforms we considered. Snapchat, a recent entrant that holds the next greatest share, had only 13% of time spent. Facebook.com's share has declined over the last five years, having fallen from 80% in July 2015. However, we note that the number of users accessing Facebook.com has increased throughout the period and the absolute time spent by users on Facebook.com has increased in the last two years. Combined, Facebook's platforms (Facebook.com, Instagram and WhatsApp) had a share of 75% as of June 2019.114 Source: Comscore MMX MP, Total Digital Population, Desktop aged 6+, Mobile aged 13+, July 2015 - June 2019, UK. Notes: In November 2018, Comscore altered its methodology which contributes to the discontinuities in the data around this date. *Including Messenger. 3.118 Consumers can choose to access multiple social media platforms over a period of time. We analysed Comscore's 'cross-visiting' data to assess the extent to which consumers access multiple social media platforms. A consumer is described as 'cross-visiting' between two platforms if they access both of the specified platforms within a calendar month. However, the crossvisiting data does not allow us to assess consumers' intensity of use. To be counted as a consumer that has cross-visited, an individual must simply access both platforms once within the month.115 3.119 The majority of every social media platform's audience 'cross-visits' with Facebook.com. For example, as shown by Figure 3.9 below, 97% of Instagram's audience cross-visited with Facebook.com and 95% of Snapchat's audience cross-visited with Facebook.com. In contrast, 66% of Facebook.com's audience cross-visited with Instagram and 68% cross-visited with Snapchat. The lowest proportion of a social media platform's audience cross-visiting with Facebook.com was TikTok at 70%, demonstrating that each social media platform we analysed is generally used in conjunction with Facebook.com. Source: Comscore MMX MP, Total Digital Population, Desktop aged 6+, Mobile aged 13+, June 2019, UK *Including Messenger. ## Competition Between Facebook And Existing Social Media Platforms 3.120 Since Facebook and YouTube account for a significantly larger portion of time spent online than other social media platforms (as shown in Figure 3.7 above), we have considered first the degree of competition between them, and second the extent to which other platforms appear to act as a competitive constraint on Facebook. ## Competition Between Facebook And Youtube 3.121 We note that of the platforms we considered, consumers seem to access YouTube for particularly distinctive reasons. As a result, YouTube does not currently appear to compete closely with Facebook's platforms, despite its comparable reach and levels of consumer engagement. We further note that: - YouTube is heavily oriented towards content, rather than communication. Consistent with this, consumers tend to view YouTube as a platform for video consumption, with only a minority emphasising its communication features.116 Internal documents submitted by Google indicate that the most common reasons consumers in the UK access YouTube are for entertainment and to view 'how-to' videos on the platform.117 - 'User generated content' is a key feature of social media platforms, including YouTube. However, YouTube also provides access to a wider range of content, including through its paid-for 'premium' music and video streaming services. Such services are not available on the other social media platforms in our sample. - Finally, Google told us that YouTube does not have a social graph. Social graphs give social media platforms the ability to identify connections between consumers. Therefore, YouTube cannot recommend videos based on consumers' 'friends' viewing behaviour or recommend content users may like based on friends' activity, as done by other social media platforms such as Facebook.com and Instagram. 3.122 As a result of these differentiating characteristics, YouTube seems to face closer competition from other providers of audio-visual content than from social media platforms.118 Consistent with this, we have received evidence indicating that YouTube competes with firms outside of the social media sector, both from these firms' submissions and from Google's internal documents. 3.123 Additionally, we have received some evidence demonstrating that social media platforms seem to view YouTube as a competitor in its capacity as a provider of content rather than as a provider of the wider communication services offered by social media platforms. Again, this suggests that YouTube may not currently be a close competitor to Facebook, or to the other social media platforms we have considered as part of this Study. ## Competition Between Facebook And Other Social Media Platforms 3.124 Aside from YouTube, the next two largest platforms to Facebook in terms of number of users are Facebook-owned WhatsApp and Instagram. These platforms are therefore not a competitive threat to Facebook.com. 3.125 None of the other social platforms currently offer a comparable portfolio of services to Facebook.com. Instead, each provides a specialised offering that competes with some aspect of Facebook's services. For example: - Snapchat is used as a platform for interacting with close friends and therefore seems to compete most closely with Facebook.com's Messenger product that allows consumers to communicate privately. - Reddit is a 'network of communities' and in this respect appears to compete most closely with Facebook.com's 'Group' features. - TikTok is used to create and share short form videos that are set to music. It seems to compete most closely with Facebook.com's 'Facebook Watch' offering. 3.126 The high proportions of other platforms' audiences that cross-visit with Facebook.com, and the substantively lower proportion of Facebook's audience that cross-visits with each of the other platforms, seem consistent with this. Other platforms may be used by sub-sets of users, but nearly always in combination with Facebook.com. 3.127 We consider that the wider breadth of services offered by Facebook.com and the scale of its consumer network mean that it can fulfil a wider variety of consumer needs compared to other social media platforms. 3.128 The wider 'family' of Facebook platforms reinforces Facebook's competitive position, as consumers may choose to 'switch away' from Facebook.com but remain within the Facebook 'ecosystem' of apps.119 Facebook's 'family' of apps also gives it a very strong competitive position with respect to certain consumer uses of social media platforms. For example, both WhatsApp and Facebook Messenger are private messaging platforms. 3.129 While the Facebook.com platform has a relatively lower share of time spent for younger consumers, 18-24 year olds still spend the greatest proportion of their time on social media platforms within the Facebook 'ecosystem'.120 3.130 Overall, Facebook appears to have significant market power. Facebook.com is a 'must have' platform for social media users. While other platforms have been able to enter the market and grow their user base, users of these platforms almost all still use Facebook.com. While Facebook.com's overall share of time spent has been declining slowly over time, it remains significantly the largest player, and its number of active users has not declined. Facebook's platforms (Facebook.com, Instagram and WhatsApp) had a combined share of 75% of time spent on social media platforms as of June 2019.121 ## Barriers To Entry And Expansion In Social Media 3.131 Having considered the current state of competition in the social media sector, we now discuss potential barriers to entry and expansion that may prevent other social media platforms from acting as an effective constraint on Facebook. ## Network Effects 3.132 Social media platforms are characterised by same-side and cross-side network effects. Here we discuss how social media platforms are affected by network effects and the extent to which these impose a barrier to entry and expansion for a platform seeking to compete with Facebook. 3.133 All of the social media platforms we contacted as part of the study agreed that network effects are important to their services in some way. However, the nature and importance of network effects appears to vary between different platforms. This seems to be influenced by the platforms' differentiated strategies and the purpose for which consumers access their services. ## Same-Side Network Effects 3.134 Social media platforms, particularly those focussing on communication, will become more valuable to consumers if other consumers they want to interact with join the platform. Consumers access social media platforms for different reasons and need to interact with different (groups of) people for each of these reasons. For example: - Snapchat is primarily used to communicate with close friends and family members. Snapchat's services will become more valuable to a given consumer if more of their close friends join the platform. In this case, the network effects are 'identity-based' because Snapchat only becomes more valuable to the consumer if specific people join the platform. As people tend to only have a few close friends, each consumer's network is small, but every connection is highly valued. - LinkedIn's services are used to interact with professional networks. Consumers will likely have a larger professional network than network of close friends. To offer a valuable service, LinkedIn must be able to offer its users access to this wider network. Consumers may value the presence of specific individuals, but generally value that their wider industry is represented on the platform. - YouTube is used to consume and share video content. Consumers do not seem to access YouTube to interact with people they know personally before watching their videos.122 Therefore, these same-side network effects do not appear to be strongly 'identity based'. Instead, the presence of other consumers may be valued to the extent that they contribute either content or reactions. 3.135 Strong same-side network effects lead to feedback loops. More users joining the platform leads to still more users joining, whilst users leaving the platform leads to still more users leaving. See Box 3.6 for an example of this. Box 3.6: Myspace Myspace launched in 2004 and was once the largest social media platform. However, in 2008 Myspace was overtaken by Facebook.com. Myspace then quickly lost its user base, with numbers falling to 73 million users by January 2011 and then to 63 million users in February 2011.123 This rapid and increasing decline in users shows the power of the network effects affecting social media platforms. Facebook told us that Myspace lost a significant proportion of users due to its focus on maximising short-term revenue through advertising rather than delivering long term value to its users. Facebook has argued that this shows that the largest social media platforms' competitive positions are not unassailable. However, we consider that Myspace's position in the early 2000s was materially different to Facebook's current position: - Facebook.com's current scale of two billion global monthly active users is far greater than Myspace's peak of 100 million global monthly active users. This implies that Facebook.com is currently much further away from a 'tipping point' in its user base than Myspace was at its prime. - it is not clear that the market had fully 'tipped' to Myspace in the first place. Myspace was the most popular platform for only a couple of years. Facebook.com has been the most popular social media platform for over a decade.124 3.136 Strong same-side network effects can also act as a barrier to entry and expansion by restricting platforms' ability to grow their consumer networks. 3.137 If a new entrant does not have a suitable consumer network, consumers may not be able to use its services for the same reasons they access the incumbent's services. Individual consumers may therefore be unable to replace the services they receive from large incumbents such as Facebook.com by switching to the new entrant. In particular: - consumers may be unable to communicate with a comparable network by accessing the new platform; and - consumers may not have access to a similarly extensive or high-quality body of 'user-generated-content' by accessing the new platform. 3.138 In this way, consumers may be 'locked in' to incumbent platforms. Absent a mechanism facilitating switching amongst groups of consumers or the capability to interact with consumers active on a different social media platform, this may restrict new entrants' ability to grow their consumer networks. 3.139 Platforms' submissions outlined some strategies that new entrants could use to try to facilitate switching amongst groups of consumers: - Importing contacts from user devices - this helps consumers find friends on the platform or invite friends to the platform.125 However, this strategy seems limited to platforms that seek to enable consumers to interact with close friends. Consumers are unlikely to have access to wider networks on their devices. - Entering from adjacent markets - where the entrant has already developed a digital audience. In this case, the platform will have access to a network of potential users upon entry. However, the new platform will still lack a social graph. If the entrant has a large enough digital audience in the adjacent market, all of the people that a given consumer wants to interact with will be present on the new platform. However, they will not be linked as 'friends' or 'connections' on the platform. Instead, consumers will have to develop this network of connections themselves over time. See Box 3.7 for a discussion of Google+, one of the most prominent examples of this strategy. - 'Social graph' APIs - these can give new platforms access to incumbents' social graph data. For example, an API could allow users to export lists of 'friends' from an existing platform and invite them to join the new platform. In this way, a new entrant could gain access potential users and their valued networks.126 In 2011, Google tried to launch its own social media platform 'Google +' as a direct competitor to Facebook.com. Google+ offered its users a range of features including: video chat; photo sharing; 'circles', a feature for connecting with social groups; a '+1' feature similar to Facebook's 'like' button; and a 'check-in' feature allowing users to log their location. However, ultimately Google+ failed to engage users, with the vast majority of consumers' sessions on Google+ lasting less than five seconds. Google told us that its users 'spent many more minutes on Facebook than they did logged into Google+'. The failure of Google+ to successfully enter the social media sector is particularly notable given the extensive resource that was available to it through Google. Specifically, we consider that Google+'s failure: - demonstrates that access to a wide network of potential users and consumer data, as held by Google, is not determinative of successful entry to the social media sector. and - indicates that entry with a service similar to that provided by Facebook.com is very difficult indeed. ## 3.140 In the absence of a mechanism facilitating switching amongst groups of consumers, new entrants attract consumers by providing a sufficiently differentiated proposition. Consistent with this, platforms told us that the most important 'input' to a new social media platform is a compelling idea.127 This may persuade consumers to switch despite the new service having a more limited consumer base, thereby mitigating network effects as a barrier to entry. However, there also seem to be some limitations to this strategy: - entering by providing consumers with a specialised service may limit the scale of the consumer base that new entrants can develop in the longterm; and - existing platforms, such as Facebook.com, may experience an incumbency advantage through their ability to copy the innovations of new entrants and deliver those new services to a larger consumer audience. As a result of their pre-existing audiences, they are likely to be better able to monetise the new innovation than the entrant. In turn, this may reduce incentives for new entrants to innovate.128 3.141 In markets characterised by network effects, consumer multi-homing can increase the competitive pressure faced by incumbents such as Facebook.com and prevent the market from 'tipping'. 3.142 Consumers do appear to 'cross-visit' across multiple social media platforms. However, this does not in itself demonstrate that multi-homing behaviour acts as a genuine competitive constraint on Facebook, ie that the different platforms accessed are substitutes, drawing time and attention away from Facebook. Based on the evidence gathered regarding social media platforms' highly differentiated strategies and the variety of consumer purposes for which they can be used, these other platforms do not appear to act as close substitutes to Facebook. In turn, the consumer cross-visiting behaviour we described previously appears to impose more limited competitive pressure on Facebook.com, compared to a scenario where the other social platforms were close substitutes to Facebook. 3.143 There also appear to be some barriers to consumer multi-homing in the social media sector, especially when it comes to multi-homing between platforms that are relatively closer substitutes. Examples include: - The 'opportunity cost' to consumers of the time they spend accessing one platform rather than another. - The process of setting up an account on a new platform. - That social media platforms are not interoperable. Friends on one platform cannot be contacted from another platform, nor can the content from one platform be consumed on another platform. As a result, consumers have less of an incentive to 'multi-home' with smaller platforms.129 3.144 We have heard that features sometimes offered by social media platforms may help to address these barriers and encourage consumer multi-homing. These include: - Single sign-in tools - these allow consumers to sign-in to multiple platforms using the same username and password.130 By removing the need for consumers to remember multiple usernames/passwords, the service encourages consumers to access multiple platforms. However, we also heard some concerns relating to these services: - Access to data about the platform receiving the sign-in tools may be given to the platform providing the sign-in tools. Submissions explained that this may allow the provider to replicate the service of the platform being provided with the sign-in tools. This may reduce the incentives of the platform receiving the single sign-in service to innovate. - The service may create a dependency upon the provider of the signin tool, which often operates a rival social media platform. The service's discontinuation may potentially lead to a decline in consumer engagement for the platform receiving the service. - Consumer 'cross-posting' - in some cases, consumers can post content from one social media platform to a different social media platform using open APIs. Competitors to Facebook told us that this feature encourages consumers to create and share content on platforms where they do not have developed networks, as it allows them to share the content with networks outside of the platform. In this way, cross-posting mitigates the barriers to consumer multi-homing imposed by platforms' lack of interoperability.131 Cross-posting may also increase the quantity and diversity of content available on social media platforms, making them more attractive to consumers. We discuss potential issues with current cross posting functionality below. 3.145 Same-side network effects reinforce Facebook.com's competitive position. As previously noted, Facebook.com's consumer base is significantly larger than that of its competitors.132 As of June 2019, its audience was roughly 1.7 times larger than Twitter's, the next largest social media platform not owned by Facebook.133 Internal documents note that the breadth of Facebook.com's user base is a key differentiator of the platform. As noted by a Facebook internal document, Facebook.com is the 'network for everyone you know'. 3.146 The breadth of Facebook.com's user base and its highly developed social graph, combined with the comparatively more limited consumer networks of all the other social media platforms, mean that consumers may be unable to use other social media platforms for the same reasons they access Facebook.com. As a result, consumers may be unable to replace Facebook.com's services with another social media platform. ## Cross-Side Network Effects 3.147 The value of a social media platform to its users may also depend on the number of customers active on another 'side' of the platform: - Content providers - social media platforms often feature content created by third-party providers. This content is often displayed alongside the 'user generated content' and is typically of a similar format. Content providers can include businesses, celebrities or users that acquired mass audiences on the platform.134 Featuring greater quantities of high-quality content may make a platform more valuable to users. - Third-party developers - platforms may allow third-party developers to develop apps, such as games, for their platform. This increases the features available on the platform and can make it more valuable to users.135 3.148 Content providers and third-party developers value social media platforms more if they can provide access to a wider audience of consumers. However, content also helps to attract consumers. The platforms we contacted explained that content is a 'key input' for their services and vital to gaining consumer engagement. There are therefore cross-side network effects acting between third-party content providers and consumers which may act as a barrier to entry and expansion. 3.149 The extent to which the cross-side network effects described above affect social media platforms varies, with some platforms submitting that they are not important to their services.136 Facebook.com features games and apps developed by third parties, facilitated by the Facebook Platform for Consumer Apps. This allows third-party content providers to 'build and create valuable content for Facebook's users', thereby enriching users' experience on the platform. 3.150 As Facebook is able to offer its users access to this wider range of content this may impose even greater barriers to any platform seeking to compete directly with its services. ## Api Access And Interoperability 3.151 As noted previously, social media platforms sometimes 'interoperate' or allow their users to interact with the services of other social media platforms. This is achieved through the use of open source APIs. Facebook told us that it operates in a largely open source environment, and that this has 'unlocked innovation and enriched users' online experiences significantly'. 3.152 As well as improving consumers' experiences by increasing the range of services they can access through social media platforms, greater API access seems to promote competition by mitigating the barriers imposed by network effects. Specifically, as discussed earlier, cross-posting and social graph APIs may encourage consumers to access multiple platforms. 3.153 However, the importance of these APIs in mitigating the effects of network effects may create a dependency between the platform receiving the services, and the platform providing access. 3.154 This dependency may also allow incumbents to worsen smaller competitors' offerings to consumers. By either degrading the functionalities enabled by the APIs or removing the service entirely, large incumbents may be able to affect the level of competition that they face. As shown by the examples below, this may be done on a targeted basis or as part of a general policy change on the part of the platform providing access. Facebook refers to such changes as 'deprecation' of the APIs.137 3.155 For example, in 2013 Twitter acquired a video sharing platform called Vine. Prior to the acquisition Vine users were able to find friends they already knew on Facebook.com through Facebook's 'Find Contacts' API. However, following its acquisition by Twitter, Facebook disallowed Vine's access to this API. In doing so, Facebook was able to degrade consumers' experience of Vine and reduce the platform's competitive threat. Vine was discontinued by Twitter in 2016.138 3.156 Additionally, the functionalities enabled by APIs may not be reciprocal. For example, prior to 2018, Facebook.com featured a 'Publish Actions' API which allowed consumers to post content onto Facebook.com from other social media platforms. However, consumers were unable to post content from Facebook.com onto other social media platforms. This asymmetry in consumers' cross-posting abilities may favour Facebook.com by leading to greater and more varied content being shared on Facebook.com compared to the social media platforms from which content is shared.139 3.157 Cross-posting capabilities between Facebook.com and other social media platforms remain asymmetric, as shown by Figure 3.10. Source: The CMA has created this image by taking a screengrab of the Facebook platform for the background and adding ## Access To Data For Personalisation And Targeting 3.158 Successful social media platforms feature a vast quantity of content that may be shown to users. To prevent congestion due to a large amount of content and maintain user attention, platforms must be able to determine the most relevant content for a given user and help users to locate this content quickly, which they do using algorithms. For example, platforms may: select and rank the content showed in each users' feed; make recommendations as to what content users may wish to consume next; or suggest new connections they may wish to make.140,141 Platforms also use data to target advertising. 3.159 The vast majority of this data held about consumers' likely demographic attributes, preferences and behaviours is sourced from their interactions with the platforms. It includes data submitted by users, data on users' interaction with a platform, and inferred data. See Appendix E for further discussion of the types of data used. 3.160 As well as access to content, access to data used for targeted advertising and personalisation can act as a barrier to entry and expansion: - Social media platforms that offer greater targeting capabilities are more valuable to advertisers. Platforms with greater quantities of consumer data are better able to target advertising and may be better able to successfully monetise their services. - Consumer data is an important input to social media platforms' personalisation functionalities. By providing better recommendation and personalisation functionalities, platforms may become more appealing to consumers and lead them to spend more time on the platform. However, as demonstrated by the case studies described earlier in this chapter, limited access to data does not seem prohibitive of entry. Additionally, access to data does not appear to be determinative of successful entry. ## Economies Of Scale 3.161 Social media platforms seem to experience some economies of scale, that may make it difficult for new entrants to compete. These occur on both advertiser 'sides' of the platform. 3.162 On the consumer side, these occur because platforms must offer basic features and functionality irrespective of the number of users on the platform. However, some costs to a social media platform increase with the number of users accessing it, as platforms must invest in infrastructure to support a greater number of users. Google submitted that YouTube has not experienced substantive economies of scale. Facebook submitted that it has experienced limited economies of scale and only in the early years of development, as costs per user have increased along with user base. 3.163 On the advertiser side, these occur because of the role that consumer data plays in targeted advertising and the cross-side network effects between advertisers and consumers. We have received evidence showing that platforms need to achieve a 'critical mass' of consumers in order to monetise sustainably. These issues are discussed further in Chapter 5. ## Initial Findings In Social Media 3.164 Social media platforms offer consumers a range of differentiated experiences. However, in general, consumers access social media platforms to communicate with each other and view content. 3.165 The evidence we have gathered so far suggests Facebook has significant market power in social media. None of the platforms currently active in the UK's social media sector appear to impose a strong competitive constraint on Facebook.com. No existing social media platform offers a comparable range of consumer services, has access to as extensive a consumer network or has a similarly well-developed social graph. Consumers are unlikely to be able to replace Facebook.com's services entirely with another platform's unless that platform can offer access to each of these components. 3.166 Additionally, entry does not appear to act as a meaningful threat to Facebook's competitive position. Network effects act as a strong barrier to entry and expansion in the social media sector, because consumers value the presence of other consumers and an array of relevant, high-quality content. A platform that lacks these may struggle to attract consumers. 3.167 Recent entrants appear to have responded to the barriers imposed by network effects by inducing consumers to multi-home with differentiated offerings. However, the nature of this strategy implies that the constraint placed on Facebook by such an entrant will be limited. In particular, we note that there has been no successful entry in the last 10 years by a platform competing directly with a comparable set of services to those provided by Facebook.com, with Google's attempt having failed. 3.168 We have also seen some evidence indicating that, even with a differentiated business model, new entrants may struggle to monetise their services. To do so successfully, platforms seem to require a 'critical mass' of users. Additionally, we note that Instagram has been far more successful than Snapchat in monetising, despite similar levels of consumer engagement. This suggests Instagram's access to Facebook's wider resources may have contributed to its success. 3.169 The Facebook 'family' of apps further insulates Facebook.com from competitive pressure. We have also received some evidence demonstrating that new entrants may, in some circumstances, be reliant on Facebook. This appears to primarily occur through the provision of open source APIs eg providing access to the Facebook social graph, or cross-posting capabilities. By permitting and then restricting other social media platforms' access to these APIs, Facebook may be able to affect the competitive constraints it faces. 3.170 In combination, we consider that the factors above limit the competitive pressure on Facebook. This may have several negative impacts for consumers. Firstly, Facebook may have weaker incentives to innovate and to develop its platforms in ways that are valued by consumers, compared to a more competitive scenario. In addition, Facebook may be able to extract more consumer data, or worsen the terms that it offers consumers for this data. We discuss consumer control over data in Chapter 4. Finally, consumers may be harmed indirectly through higher prices for other goods and services, if Facebook is able to use its market power over consumers to raise the prices its charges to display advertisers above competitive levels. We discuss competition in digital advertising in Chapter 5. ## 4. Consumer Control Over Data - Online platforms offer a range of services that are valued by consumers for no monetary cost in return for their attention and data. - It is important that consumers can make an informed decision over whether to accept the terms of this exchange and that they receive the right level of protection where they are not able to engage. Equally, it is important that consumers have control over the use of their data, so that they can decide whether to provide or deny access and share it with others if they wish. - In surveys, most consumers say they place value on their ability to control access to their data, and only a minority are happy to share their data in return for relevant adverts. However, we found that engagement with platforms' privacy policies and privacy controls is generally very low. There are several reasons for this. - First, there is in some cases a lack of choice: social media platforms such as Facebook do not allow consumers to turn off personalised advertising. - Second, where choice does exist, it can be difficult to exercise due to a strong tendency to accept default settings presented by platforms. For example, most platforms we assessed served consumers with personalised advertising by default, and we found that engaging with privacy settings was complicated, particularly for social media platforms like Facebook. - Terms and conditions are also long and complex. We have found that a consumer may need to read 10,000 words before signing up to a service if they are to understand how their data will be used, yet the average visit to the Google privacy page was just 47 seconds. - Effective regulation that puts consumers in control of their own data is essential in the modern digital economy. However, we have heard concerns that aspects of data protection regulation risk creating competition concerns by unduly favouring the business model of large, vertically-integrated platforms over smaller, non-vertically-integrated publishers. We are working constructively with the ICO to consider how to address these concerns. ## Introduction 4.1 Many consumers use a range of online platforms every day. They may use Google to find a local restaurant, access Facebook to see what their friends are doing and buy a book on Amazon. When they use these services, platforms collect and use information about them to serve personalised advertising. In return, these services are typically free to use and allow them to do a range of things such as search the web, connect with friends, share content and receive more relevant advertising. 4.2 While platforms provide services that are free to consumers when they use them, they also generate very large revenues - and are extremely profitable. This is because people pay for them indirectly when they buy goods or services from the businesses who pay to advertise on the platforms. 4.3 This is not a new phenomenon. Many newspapers have been provided free to readers for some time, covering their costs by the advertising revenues. While, other things being equal, some people might prefer these services to be ad-free, the truth is that without ads, people would either have to pay directly for the services - or the services would disappear. What is new, however, is the ability of digital platforms to collect and use personal data. This allows them to target advertisements - or indeed provide other services - on the basis of what they know about the particular circumstances of the individual consumer. 4.4 We recognise that, if consumers want high quality content and services without paying money directly for them, platforms need to be able to generate enough revenue to fund them. However, it is important that consumers can make an informed decision over whether to accept the terms of this exchange offered by platforms and that they receive the right level of protection where they are not able to engage. Equally, it is important that consumers have control over the use of their data, so that they can decide whether to provide or deny access and share it with others if they wish. Getting this balance right can both protect consumers and benefit them by increasing competition between platforms. Finally, it is important that the design of regulation in this area is mindful of competition effects, and that in particular regulation is not designed in such a way as to entrench further the market power of incumbents. 4.5 The regulation of data protection and privacy in the EU is the responsibility of national data protection authorities (DPAs) such as the ICO in the UK and the DPC in the Republic of Ireland. However, competition and consumer authorities are increasingly carrying out work in this area,142 reflecting the close links between consumer control over data and competition and consumer concerns more generally. We have worked closely with the ICO during the course of this study. 4.6 It is within this complex landscape that we have sought to understand how consumers' data is used, the controls they have and how they use them, and the impact of both consumer behaviour and data protection law on competition in the markets within the scope of the study. This chapter discusses: - the role of data, how it is collected and its value to publishers, advertisers and platforms; - the importance of data protection legislation; - consumers' attitudes to data collection; - the controls that consumers have over the collection and use of their data for personalised advertising; - how consumers engage with the information they are presented with, the choices they make and the platforms' use of default settings; and - barriers to effective engagement by consumers. 4.7 We conclude with a summary of our initial findings on this theme. ## The Role Of Data In Digital Advertising And Consumer Services 4.8 In order to understand the extent of any problems regarding consumers' control of their data, we have first sought to understand the role of data for online platforms funded by digital advertising. The data is used to provide services to consumers as well as digital advertising services to advertisers. In the following sections, we have assessed what data is collected, how it is collected, and why it is collected. ## What Data Is Collected? 4.9 Data is collected online by a wide range of market participants, including platforms, advertisers, publishers and data brokers. This data can include a consumer's behaviour online such as their search history, what they click on, the content they create and share, and their location through device information. 4.10 The data collection by some platforms can be extensive. For example, Google collects consumer information such as name, contact details, consumer name and passwords provided voluntarily by consumers when creating a Google account. It also collects information that the consumer may be unaware of, such as device and browser information, IP addresses, operating system versions; information on the consumer's activity such as preferences, interaction data (eg clicks and mouse hovers), search history and location data. This means that by, for example, using their mobile phones during the course of a day, consumers transfer a large number of valuable information to Google such as where they are and have been, what they like and are interested in and if they are looking to buy any product or service. 4.11 Advertisers, publishers, online platforms and data brokers also collect data from a range of services. In addition to data about consumers, they can collect and share data once the ad is placed, such as: contextual data (the context in which the ad is served, such as knowing the consumer is on a sports website); campaign data (information on the reach and success of an ad campaign); and search data (eg what is being searched for, the number of clicks and purchases they generate). 4.12 The individual level data collected by platforms such as Google, Facebook and Twitter remain under the control of these platforms and it is generally not shared with other market participants.143 However, outside of these 'walled gardens', data is shared between publishers and advertisers through a large number of intermediaries in order to identify consumers and provide personalised advertising. ## How Is Data Collected? 4.13 Data can be collected in several ways, but the main ways are: (a) through consumer-facing services that platforms offer to consumers; and (b) through services offered on third-party websites and apps. 4.14 Online platforms, such as Google and Facebook, can collect large datasets because they operate platforms used by a large number of consumers. For example, Google collects data from more than 50 consumer-facing services, including Google Search, and Android phones. Facebook collects data from Facebook, Instagram and WhatsApp.144 Both companies reach a large majority of online consumers through one or more of their services. 4.15 Platforms also collect data through services they offer on other websites and apps. This allows them to gather information about consumers and how they interact with third-party sites, therefore extending their reach and data collection beyond their own services. There are several ways in which they do so, but at this stage we understand that there are four main sources of this data: - Advertisers, publishers and data brokers can provide data they collect about consumers visiting their platforms to enable a better targeting of digital advertising. - Advertisers and publishers can allow platforms to collect observed and volunteered data from their own online services through a range of technologies such as pixels, tags and cookies. In this way, platforms collect large amount of data about consumer preferences and behaviours on other websites and apps and add it to the information they already possess about how consumers interact with their own services. - Platforms collect data when consumers sign into an app or website using their sign in functionality, whereby consumers can securely sign in to third-party apps without having to create, authenticate and remember new usernames and passwords. This means that, when a consumer signs into a website to, say, purchase something using her Facebook login details, Facebook collects data about the behaviour and interaction of the consumer with that website and adds it to the information it already has about that consumer. - Platforms collect information such as device and browser information, bid information and event information (impression, click or conversion data) from the ads placed on publisher websites. 4.16 Finally, Google is able to gain data from mobile devices running the Android operating system, which gives Google a significant advantage in relation to specific types of consumer data such as location data. 4.17 The figure below provides a high-level illustration of our current understanding on the amount and types of data that Google, Facebook and other large platforms and a group of smaller platforms possess. Google and Facebook collect a large amount of data from their leading consumer-facing services, including Google Android, and tags placed on publishers' and advertisers' websites. Compared to them, other platforms' data and targeting capabilities are relatively limited to user data from their own services and are extremely limited in their ability to collect data about consumers on third-party websites and apps and combine it with their own first-party data. 4.18 While we recognise that this assessment is to a certain extent subjective, the overall conclusion that Google has more data than the other platforms is recognised in an internal Google document, which states 'Google has more data, of more types, from more sources than anyone else […] Google is a big part of this scaling machine with massive reach across the internet.' Source: CMA. Note: Small platforms include Twitter, Snap, TikTok and Pinterest. ## Why Is Data Collected? 4.19 Data is valuable to advertisers, publishers and platforms as it helps them generate revenue from personalised advertising and deliver consumer-facing services. In turn, consumers tend to express a preference for adverts that are relevant to them. For instance, Harris Interactive found that 54% of consumers would prefer to see adverts that were relevant to them rather than seemingly random adverts.145 ## For Digital Advertising 4.20 Data on consumers is highly valuable for targeting digital advertising and measuring its effectiveness. 4.21 There are many types of targeted advertising which can fit into two broad groups - contextual and personalised advertising - according to the degree of targeting and the use of consumer data. Contextual advertising targets ads on the basis of the content of the page viewed and only requires some very limited types of consumer data such as device, location and language. Personalised advertising, on the other hand, uses personal data, including demographic and interest-based data alongside data inferred from other consumers, to provide advertising targeted on the basis of consumers' characteristics. The main types of personalised advertising are audience segmentation (the grouping of consumer profiles into 'audiences' characterised by intent, demographics and interests) and retargeting (the serving of targeted ads to specific individuals whom advertisers identify as customers or potential customers). 4.22 The second main purpose of data in digital advertising is to provide verification, measurement, and attribution. Consumer data is particularly important for measuring attribution (the extent to which exposure to an ad leads to a 'conversion' of some sort such as a sale) as it requires the matching of data on consumers' exposure to adverts with data on the consumers' subsequent actions. 4.23 The importance of data, and consumer data in particular, depends on the type of advertising used and, in turn, on the campaign objectives and KPIs that advertisers want to meet. In general, we have heard that personalised advertising is more important in display than in search advertising (since the contextual information provided in a search query is highly valuable in itself for targeting without the need for consumer data), while the use of consumer data to demonstrate attribution is often more important in search (where sales are often the key KPI) than display (which aims to meet a wider variety of objectives, including greater brand awareness). 4.24 More information can be found on the role of data in Appendix E. ## For Consumer-Facing Services 4.25 The use and importance of certain types of data differs between search and social media. 4.26 As explained in Chapter 3, a high-quality search engine requires access to a web index, click and query data, and certain contextual data. Web indices are created by collecting large amounts of data on websites and webpages, and the information that they contain. This is drawn from by a search engine to generate relevant and useful results in response to queries. Click and query data includes what consumers search for, which results they select, and whether they spend time on the web page. This data is used by search engines to train their algorithms on the most relevant results to serve in response to particular queries. They also use data on the context in which the consumer is making a search (eg the time or date) to return relevant search results. Other data that search engines use to tailor search results is location data which is becoming increasingly important with the increased use of mobiles. 4.27 Social media platforms fundamentally rely on enabling the sharing of information through peoples' posts, comments and 'likes' - consumers are attracted to particular platforms because of the ability to access other consumers' content. The platforms can also make use of consumer data to improve their services to consumers. The most important data for this purpose is content data (consumer generated information such as consumers' photo, videos and posts), profile data (consumer information provided when setting up an account) and interaction data (such as likes, shares and comments). ## The Importance Of Data Protection Legislation 4.28 The role of data protection legislation is to protect the fundamental rights and freedoms of consumers and their right to the protection of their personal data. The General Data Protection Regulation ('GDPR'), the Data Protection Act, and the Privacy and Electronic Communications Regulations, provide the framework for the lawful, fair and transparent processing of personal data, setting overarching data protection principles and providing data protection rights.146 4.29 Integral to this framework is enabling consumers to have effective control over the processing of their personal data and to be empowered to make informed and granular choices over its processing (who, what, when, for what purpose(s), for how long etc.), underpinned by a regime that enables the protection of their fundamental rights by design and default. 4.30 In this study we have encountered a variety of interpretations of the GDPR and we note that, as the GDPR has been in effect for a little over 18 months, there is some genuine uncertainty on where the precise contours of the regulatory landscape lie. However, the GDPR's core principles are not new and were reflected in the preceding legal framework. Further in many areas there has been detailed guidance from the ICO, and also the European Data Protection Board (EDPB) on the GDPR, which also adopted the guidance of its predecessor Article 29 Working Party, on the matters relevant to this to this study. 4.31 We think that greater understanding of the views that data protection authorities will take on these matters is likely to emerge during the course of this study. For example, the ICO has been doing detailed policy work in the online advertising space,147 and the first wave of statutory inquiries by the Irish DPC, the lead supervisory authority for many of the multinational platforms of relevance to this study, are expected to conclude soon.148 Greater clarity is also likely to emerge in due course as specific enforcement action taken under the GDPR will in turn lead to appeals through the domestic and European court systems, with resulting judgments that clarify certain points of legal interpretation. 4.32 In this context, we believe this study can play a role to support a conversation on how the GDPR can be effectively interpreted in its implementation, to have due regard to wider market impacts, to ensure that the fundamental rights and freedoms of consumers and their right to the protection of their personal data is protected in the long term. 4.33 For processing of personal data to be lawful under the GDPR, it requires a lawful basis. Under the GDPR, the lawful basis applies in the context of generally applicable prescribed 'data protection principles' such as fairness, transparency, purpose limitation and data minimisation which apply to all processing of personal data. The main legal basis identified by market participants for the lawful processing of personal data by in this market study have been consent, contract and legitimate interests.149 4.34 A short description of the three legal bases identified are: - Art. 6 (a) Consent - which means a freely given, fully informed, specific and unambiguous indication of the consumer's wishes by way of a statement or clear affirmative action, which signifies agreement to the specific processing of their personal data, and is as easy to withdraw as to give.150 For consent to be valid it has to be a genuine, free and appropriately granular choice the consumer. It must be 'opt-in' not 'opt-out' and the consumer must have ongoing control over the specific processing of their personal data which is taking place. - Art. 6 (b) Contract - which means the processing is necessary for the performance of a contract with the consumer, which means the processing is necessary to deliver the purpose of the contract with the consumer, rather than simply what is in the terms of the contract. - Art. 6 (f) Legitimate interests - means processing can be lawful if it is necessary for the legitimate interests pursued by the controller. To rely on this basis the controller must properly carry out a three-part legitimate interests assessment that includes a balancing exercise to establish whether the interests and fundamental rights and freedoms of the consumer override the controller's own interests in that situation. 4.35 The GDPR does not contain a 'hierarchy' of lawful basis. The ICO's guidance clarifies that no single basis is 'better' or more important than the others - the one that is most appropriate depends on the controller's purpose and its relationship with the individual. However, in some circumstances it will be more appropriate to rely on one lawful basis over another. 4.36 We note that in the context of real-time bidding, the ICO observes that consent is likely to be the most appropriate lawful basis for the intensive processing of personal data for personalised digital advertising in the UK. This is due to the requirements of PECR, which prescribe the basis in respect of the processing activities it governs. This is explained in the ICO's Update Report into Adtech and RTB: 'In [the ICO's] view, the only lawful basis for 'business as usual' RTB processing of personal data is consent (ie processing relating to the placing and reading of the cookie and the onward transfer of the bid request).'151 4.37 In respect of the other two lawful basis we have encountered in the study, the ICO has observed either in its guidance or RTB interim report, that they are not likely to be suitable basis for personalised advertising. 4.38 In relation to performance of a contract, ICO's view is that this can be a suitable basis for processing a consumer's personal data where the objective purpose for which a consumer enters into a contract with an online service provider, eg a shopping platform, is to process their data to provide the core service. An example may be a contract with an online shopping platform whereby the platform needs to process the consumer's data, like address, in order to deliver the purchased product to the consumer. In contrast, the further processing of their personal data for ancillary purposes, such as personalised advertising based on the consumer's observed preferences, is not necessary to provide the core contracted service, and so contract is not an appropriate legal basis for that additional processing.152 The ICO's view is consistent with the EDPB's view.153 4.39 In relation to legitimate interests, while serving advertising is legitimate in principle, the ICO's view is that in the context of the intensive processing of personal data involved in personalised digital advertising, it is unlikely that the legitimate interests of a data controller to process consumers' data to serve personalised advertising would override the data protection interests of the consumer.154155 However, where personalisation of advertisements does not involve the processing activities to which PECR applies (ie the use of cookies and similar technologies) the ICO has indicated that legitimate interests may, in principle, be considered as an appropriate lawful basis on a case by case basis. 4.40 We note that using consent as the legal basis for processing personal data for personalised advertising, rather than contract or a 'legitimate interests' balancing exercise, puts the emphasis on informing the consumer of the proposed processing of their personal data and puts them in control.156 ## Consumer Attitudes To Data Processing 4.41 Consumers place importance on their ability to control access to their data: a 2016 survey by the European Commission found that 96% of UK consumers thought that it was important that their personal information on their computer, tablet or smartphone could only be accessed with their permission.157 Whilst many people see data collection as a part of everyday life, the majority of people are still uncomfortable with it.158 impact, and individuals would not be surprised or likely to object. We believe that the nature of the processing 4.42 As indicated above, recent research suggests that many consumers prefer advertising on websites to be relevant to them. For instance, Harris Interactive found 54% of participants in an online survey would prefer to see adverts that are relevant to them rather than seemingly random adverts.159 Similarly, Which? found that in focus groups, most participants preferred targeted advertising and personalised discounts to non-targeted advertising and generic discounts.160 4.43 However, only a small minority of all consumers are happy to share their data to receive relevant advertising. For example, Ofcom found that only 15% of respondents were happy for online companies to collect and use their data to show more relevant adverts or information.161 Further, research conducted by Ofcom, the ICO and Which? all showed that the more consumers understood about how targeted advertising works, the more concerned they became about it, and began to feel less in control of their data and that, in addition, consumers can become less willing to receive personalised advertising.162 4.44 More generally, consumers' acceptance of data processing is heavily influenced by demographic factors, the nature of the data involved, and with whom the data is being shared. - Overall, younger consumers and those who describe themselves as confident internet users are more likely to be comfortable with data processing. In 2019, Ofcom found that 28% of respondents aged between 16-24 were unhappy with companies collecting and using personal information for any reason, compared to 56% of those between 55-64.163 - Consumers tend to be reluctant to share sensitive personal information. The Open Data Institute ('ODI') found that while 53% of respondents were comfortable sharing their name with an organisation they knew, only 22% were comfortable sharing their medical records. - Consumers trust public organisations more than many private sector organisations. The European Commission asked UK respondents who they trusted to protect their personal information and found that 81% trusted health and medical institutions compared to 32% that trusted online businesses. 4.45 We interpret this research to mean that, if consumers had more information about what data is collected and how it is used, they might wish to make different choices. 4.46 It is important to consumers that they can control what data they share and that they can trust the platforms that they share it with. However, the survey evidence we have reviewed suggests that very few consumers feel they have complete control of their data. For instance, Ipsos Mori found that 69% of consumers felt they had little or no control over their online data.164 Similarly, in 2019 a survey by the European Commission found that 84% of UK respondents felt that they had only partial or no control over their online data.165 4.47 While it appears that some consumers believe they can manage some aspects of data processing, such as who initially has access to their personal data, these same consumers still feel that their scope to act meaningfully is very limited. For example, Ipsos MORI found that some respondents felt like the only way to control who initially has access to their data is to choose whether or not they enter a website. One their data has been handed over, these same respondents feel they have lost control over who has access to their data. 4.48 We have also found that consumers lack trust in online platforms, with only a minority saying they would trust an online platform with their data. Social media platforms are consistently ranked as the least trusted platforms in surveys. For example, a survey by Ipsos MORI in 2016 found that only 9% of respondents trusted social media platforms with their data.166 Low trust can lead to consumers not sharing their data and realising the possible benefits of doing so, which also affects the ability of platforms to monetise their services using targeted advertising. 4.49 Some surveys have sought to understand why consumers do not feel they have control. In one survey, most consumers reported that they did not find it easy to access and change the personal information held by businesses,167 so their feeling of a lack of control arose out of difficulty with navigating to the choices available and exercising them. In other survey evidence, consumers reported that it was hard to effectively engage with companies who collect and use their data because they feel: - disempowered by their lack of knowledge and transparency about how companies collect, use and share their data;168 - reliant on data-driven services which they do not believe they can give up,169 and - there is a perceived lack of alternatives if they want to stop using specific companies whose data collection they are concerned by.170 4.50 Our initial view from the available literature is that consumers value their data and think it should only be used with their permission, and that the market does not meet their expectations by putting them in control. 4.51 See Appendix G for more information on consumer attitudes to data processing. ## How Consumers Can Control Their Data 4.52 We have carried out a review of the controls available to consumers on a sample of key search engines and social media platforms.171 We set out below the controls available to consumers over the use of their data, including in particular whether consumers are able to decide whether they receive personalised advertising while continuing to use the platform's services. In the following section, we consider the extent to which consumers engage with those controls and the use made by the platforms of default settings. ## The Controls Available To Consumers On Search Engines 4.53 Search engines allow consumers to search and make sense of a vast number of websites across the internet and find what they are looking for. In return for this service, many search engines collect data about consumers to improve the functioning of their search algorithm and to target them with relevant advertising which, in turn, pays for the service. 4.54 Both Google and Bing use consumers' data to display personalised advertising, but they allow consumers to opt out of this, irrespective of whether a consumer is logged in or not. Personalised advertisements are based on consumers' previous activity such as searches and site visits, demographic information and interests, as well as other information such as location, time of day and interactions (for example agreeing to receive updates from an advertiser). Consumers have differing controls depending on whether or not they are logged-into an account and we discuss these in detail below. 4.55 Not all search engines we examined use personalised advertising. Some platforms, such as DuckDuckGo, market themselves as a 'privacy friendly' search engine and do not store personal information, including IP addresses, and have no associated user account. DuckDuckGo claims to be an 'Internet privacy company that empowers you to seamlessly take control of your personal information online, without any tradeoffs.'172 Instead of personalised advertising, DuckDuckGo serves contextual ads to consumers, based on their searches. It follows that it does not offer consumers any controls for personalised ads. ## Non-Logged In Consumers 4.56 Search engines can be used without the need for consumers to create an account or log in - they can simply use the engine to browse the web. This does not, however, mean that no data is collected about them. For example, whilst Google does not require any information to be volunteered by the consumer to use their search engine, they do observe the consumer's behaviour and store this against unique identifiers along with interests and inferred characteristics. This can include browsing history, location data, IP address, devices the consumer uses, device characteristics such as its operating system and battery life, and engagement with third-party sites using Google's advertising services. 4.57 We found that both Google and Bing allow consumers to opt out of personalised advertising. For Google, logged-out consumers can control whether they are shown personalised advertisements both on the Google search engine and across their ad network including YouTube and the millions of websites that partner with Google to show ads. 4.58 Location information is available to search engines by default.173 This enables basic country, language and security features, as well as tailored search results and advertising. By default, a non-logged in consumer on Google will receive ads based on their location and this is unaffected by whether the consumer has elected not to see personalised advertising. This may include information drawn from their device, their web/App activity and their IP address. ## Logged-In Consumers 4.59 For some search engines, such as Bing and Google, consumers can set up an account to which they can log in and then use a range of services, such as email and document storage. This involves the consumer volunteering some additional information to open an account, but in return this also gives them more granular controls over their data. 4.60 Opening an account with Google or Bing is a simple process. For both platforms, consumers need to provide a name and date of birth. In addition, Microsoft requires a country. In creating the account, the consumer will generate an email address, if they did not already provide one, and password information. Consumers may also provide information such as gender and phone details. - Both Google and Bing allow consumers to opt out of personalised advertising, but consumers that are logged in have more granular controls. For instance, logged in consumers can adjust the interests, and in some cases demographic information, that the platforms have assigned to them and which are used to tailor the advertisements shown. - As for non-logged in consumers, location data is collected by default. The Google account settings includes one for 'Location History', which is a feature that provides personalized maps and other information to consumers. However, while data from this feature can be used to influence the ads shown to a consumer, it is just one of a number of sources of location information. This means that, although this setting is set to pause by default, it does not stop location information being collected or used. 4.61 For logged-in consumers, Google and Bing offer a set of more granular controls in addition to the option to turn off personalised advertising. For Google, we found that the main 'Privacy Checkup' control area provided around 39 options within six areas. These cover activity controls,174 ad settings (where interest categories can be amended, or personalised advertising can be turned off), information displayed about the consumer and shared endorsements settings, phone numbers, Google Photos settings, YouTube settings, plus a review reminder. 4.62 Bing's 'Privacy Dashboard' provided 10 main options that allow consumers to view and clear data.175 Eight further options linked to other privacy settings,176 including an ad preferences area where interest categories can be amended, or personalised advertising can be switched off. 4.63 In summary, we found that by default, the most popular search engines use a range of consumers' data for personalised advertising services. Both Google and Bing allow consumers to opt out of personalised advertising, whether they were logged-in or not. ## The Controls Available To Consumers On Social Media Platforms 4.64 We have explored whether consumers can turn off personalised advertising when using these platforms, and instead receive ads that are not based on their personal data. We found that consumers have to accept personalised advertising to use the social media platforms we examined, but to differing degrees: - Facebook and Instagram users cannot turn off personalised advertising. They can, however, see what interest segments they are placed in and manually switch these off, such as removing ads based on a particular football team. Consumers can opt out of seeing ads on other websites and apps that are based on their Facebook activity. - On Snapchat, consumers cannot turn off ads based on their personal data gathered by Snapchat when using their services. However, they can turn off ads based on information collected about them on third-party services.177 - Twitter always uses information it gathers from consumers' activity on the platform, including information from consumers' devices, the location where they signed up and their current location, to personalise the ads they see and their experience on the platform. Twitter users can customise their settings to prevent Twitter from combining their on- platform activity with personal information obtained by Twitter from its partner organisations. 4.65 Below we set out the differences in control that consumers have depending on whether or not they are logged into a social media account. ## Non Logged-In Consumers 4.66 Unlike search engines, social media platforms are predicated on sharing some amount of personal information with friends and families, interacting with businesses and sharing content. It follows that for most social media platforms, the consumer can do very little without setting up, and logging into, an account. For example, on Facebook a consumer who is not logged in can only see a limited range of Facebook's pages, for example those of businesses that are publicly viewable. By contrast, Twitter allows slightly more functionality as consumers can view public tweets and replies. 4.67 Facebook, in addition to Facebook.com and Facebook Messenger, is the owner of other social media platforms, including Instagram and WhatsApp. Unlike the services offered by Google, the various social media platforms offered by Facebook do not have to be integrated into a consumer's single account and a consumer will not automatically be provided with, for example, an Instagram account when they create a Facebook.com account. Consumers are able to choose which of these platforms they want to use and will be required to complete the process of opening an account for each (although consumers are able to use their Facebook.com account details to create accounts for Facebook Messenger and Instagram). ## Logged-In Consumers 4.68 Like search engine accounts, social media accounts require consumers to provide certain pieces of personal information to create an account. Generally, all platforms require that consumers provide at least a mobile number or email address for identification. 4.69 Other data may be voluntarily provided by consumers during their use of the platform, for example, content, liking pages and engaging with brands. This data can be used to infer consumers' interests for the purpose of targeted advertising. In some cases, the choice of whether to provide such information or not, does not affect the consumer's access to the platform's services. A consumer could be described as being in control of this information. 4.70 Other data may be collected by platforms from consumers automatically and without the platform providing an option for consumers to prevent this happening. A consumer could be described as having no control over this information being collected. An example of this would be information regarding a consumer's device attributes as collected by Facebook. Some platforms believe it is necessary to collect such information to optimise the way their website or application is displayed on a consumer's device. 4.71 In between these two types of information, there may also be some information collected by platforms where a consumer can either influence the extent to which this information is collected, without fully preventing its collection, or the way the information is used. Consumers may therefore be said to have some control over this information. 4.72 Facebook's default settings determine that: - consumers' posted content and any additional personal information other than their name, gender (if provided), username and user ID will only be shared with their 'friends'; - consumers will not be shown ads based on data provided by Facebook's partners but can opt in via Facebook's Ad Preferences page to be shown such ads; - consumers' activity is used to personalise ads, both on Facebook and on third-party websites and apps; - some information, such as device attributes and usage of Facebook, is automatically collected; and - device-based location settings and face recognition is turned off. 4.73 Other social media platforms that we reviewed took a comparable approach to Facebook towards their default settings regarding advertising. 4.74 In summary, we found that social media platforms required consumers to give more data to use their services than for general search platforms and the use of personal data for advertising was a condition of accessing the service. Controls over additional information, such as data about consumers' devices, are variable across platforms. 4.75 More detail on the extent to which consumers have control over different categories of information is set out in Appendix F. ## Consumer Engagement With Privacy Policies And Controls 4.76 Surprisingly, most of the platforms we contacted were only able to provide limited data about consumer engagement with privacy policies or controls. 4.77 None of the twelve platforms we contacted could tell us how many consumers accessed their privacy policy during registration. Only two platforms provided data about access to their privacy policy on an ongoing basis and for both parties this data was limited in terms of the time period it covered. 4.78 Only Facebook, Google, Verizon Media and TikTok could provide data about how consumers use settings and controls. Only Verizon Media could provide robust data and for the other three platforms, the data was either limited in detail or deleted after a short period of time. For example, Google did not provide historic data as it usually only maintains this data for 28 days before being deleted. 4.79 The lack of data collected by platforms stands in stark contrast to the substantial collection of data in other parts of their business and means there is very little evidence on how consumers behave in practice. This makes it hard to determine how much consumers care about privacy and whether an online platform's approach to privacy is effective in promoting consumer engagement. 4.80 The ICO, when giving guidance on how to draft 'privacy information' in response to the hypothetical question 'Should we test our privacy information?'; observes that testing and collecting such data 'will help you improve the effectiveness of your delivery of the information. You are likely to come up with a far more useful and engaging approach if you consider feedback from the people it is aimed at'.178 The ICO suggests testing to gather feedback from consumers on how they accessed the privacy policy; if they found it easy to understand; whether anything was difficult, unclear or they did not like it; or if they identified any errors. The ICO gives an example of how this consumer testing might allow optimisation of a policy for those who access it via different ways. 4.81 The data that was provided by Google and Facebook indicates that few consumers engage with privacy settings when they register for a service. Consumer engagement appears to be slightly higher on an ongoing basis when people use the service but remains low overall. 4.82 Below, we set out our initial findings on consumer engagement with privacy policies both at sign up and on an ongoing basis. We then discuss consumer engagement with privacy settings or controls, which are the tools by which consumers can limit or otherwise control how the data about them is collected or used. Finally, we discuss the apparent discrepancy between low levels of engagement with privacy settings and the concerns people have about privacy - the so-called the privacy paradox. ## Evidence Of Engagement With Privacy Policies 4.83 A 'privacy policy' is the statement or legal document which sets out the ways in which a firm will collect, use, disclose and manage a consumer's data. It informs the consumer what specific information is collected, and whether it is kept confidential, shared with partners, or sold to other firms or enterprises.179 When consumers sign up to a service, they are asked to review the privacy policy.180 Importantly, no platform could tell us the proportion of consumers who accessed their privacy policy when first using the service or creating an account. However, from the limited data available, there is evidence that consumer engagement with privacy policies on an ongoing basis is low. 4.84 Google provided data on the number of visits to its Privacy Policy on the Privacy Policy Web page between 21 July and 19 August 2019. If we divide this figure by the number of unique authenticated users over this period, this would be equivalent to [0-5]% of UK users having visited the Privacy Policy on the Privacy Policy Web page over this period. However, if a user visited the Privacy Policy more than once than that would imply that this figure is an overstatement. 4.85 Google also provided data for the 28-day period between 13 September and 11 October 2019 which showed that the average visit to the Privacy Policy Web page lasted 47 seconds. Furthermore, 85% of the visits in this period lasted less than 10 seconds and only 0.4% of visits lasted over 30 minutes.181 Given that for UK consumers the privacy policy totals over 6,000 words, this - Bakos et al (2014) found that only 0.05% of agreements were accessed by consumers before they consented to them; - the European Commission (2016) in a study involving experiments involving privacy policies, found that only 9.4% of participants accessed terms and conditions when it was optional to do so; and - in an experimental study, Obar & Oeldorf-Hirsch (2018) found that 74% of respondents did not open the privacy policy. very short time for reading the policy indicates that consumers are not able or willing to engage with privacy policies of this length or complexity. 4.86 In their response, Google explained that they did not believe that user visits to a Privacy Policy page or how long a consumer spent on the privacy policy web page were reliable measures for consumer engagement. For example, Google explained that a relatively quick visit to the Privacy Policy may indicate that a consumer has had a successful visit and found what they needed. However, we note that Google's own data indicates that 85% of consumers visited the privacy policy web page for less than 10 seconds. We do not consider that they can have engaged meaningfully with the privacy policy in such a short period of time. As a result, we consider that this evidence shows that consumer engagement is very low and that visits to privacy policies are brief. 4.87 This finding that consumers spend very little time engaging with privacy policies is also consistent with the academic research which indicates that consumers are not spending long enough on such policies to have read and understood them properly. For instance, Bakos et al (2014) found that consumers that accessed an End User Licensing Agreement ('EULA') spent an average of just over one minute on the EULA page (with the median time being just over 30 seconds).182 Obar & Oeldorf-Hirsch (2018) reported a reading time of a privacy policy of 73 seconds.183 4.88 Other studies also suggest that some consumers believe that a privacy policy means that their privacy is protected as the default (Turow et al, 2007; Martin, 2015). That is when these consumers see the term 'privacy policy' they believe that their personal information will be protected and, in particular, the website will not share their personal information. This suggests that the term 'privacy policy' has the capacity to be misleading and influence consumers against reading privacy policies. 4.89 We discuss the length and complexity of privacy policies in the section later in this chapter on possible barriers to effective engagement, but it is clear from this evidence that the ordinary person does not spend a lot of time reading terms and conditions. ## Evidence Of Engagement With Privacy Settings And Controls At Sign Up 4.90 By privacy settings and controls, we mean the tools by which consumers can control or restrict the data which firms collect about them, such as whether or not they receive personalised advertising and what location information is collected about them. 4.91 On some platforms, when consumers sign up to the service, they are prompted to review these settings. From the data that the platforms were able to provide, it is clear that consumer engagement with privacy settings is very low at registration: very few consumers change their default settings at registration or within 30 days of registering.184 4.92 For example, Table 4.1 below sets out data received from Google, which indicates that only a very small percentage of consumers engage with privacy settings during account creation. The data indicates that, when consumers do engage during account creation, they are more likely to disable features than enable them. | Privacy setting | | |---------------------------------|---------| | account creation | | | [ | | |  | | | ] | [0-5]% | | Enable location history | [0-5]% | | [ | | |  | | | ] | [0-5]% | | Enable voice and audio activity | [0-5]% | | Disable ads personalisation | [5-10]% | Source: Submitted to the CMA by Google in response to a request for information. 4.93 Further data from Google found that [5-10]% of consumers who had created an account within three months accessed their privacy settings or controls over a 28-day period. 4.94 Similar data from Facebook shows a low proportion of new users who registered and engaged with a setting or tool, as shown in Table 4.2. ## 30 Days Of Creating An Account | Privacy setting or control | | |----------------------------------------------------------------|---------| | viewed a setting or tool within 30 days of creating an account | | | Facebook ad preferences | [0-5]% | | Facebook privacy check-up | [5-10]% | Source: CMA calculations based on data submitted by Facebook in response to a request for information. ## Evidence Of Engagement With Privacy Settings And Controls On An Ongoing Basis 4.95 Consumer engagement with privacy settings and controls appears to be slightly higher on an ongoing basis but remains low overall. Table 4.3 sets out data received from Google, and demonstrates that only a small number of consumers engage with their privacy settings or controls on an ongoing basis:185 | Privacy setting or control | | |-----------------------------------------|--------------------------| | control or setting over a 28-day period | | | 186 | | | | | | [0-5]% | Google Account (Data and | | Personalisation tab) | | | Privacy Checkup | [0-5]% | | My Activity | [0-5]% | | Ad Settings | [0-5]% | | Security Check-Up | [0-5]% | | About Me | [0-5]% | | Auto-Delete (Web & App Activity) | [0-5]% | Source: Submitted to the CMA by Google in response to a request for information. 4.96 The data from Google also indicated that [5-10]% of active UK consumers had accessed at least one of the following: Privacy Checkup, Privacy Advisor, My Activity, Activity Controls, Ads Settings, Google Dashboard, Takeout, Google Account (Data and Personalisation Tab) or Privacy Policy. 4.97 Data from Facebook also indicates different levels of consumer engagement with different privacy settings and controls. We note that the data from Facebook covers one year whereas Google's data follows a 28-day period. As a result, the two tables are not directly comparable with one another. We also note that in March 2018, it was widely reported that Cambridge Analytica had harvested personal data from millions of peoples' Facebook profiles without their consent and used it for political advertising purposes. This is likely to mean that there was an increased focus on Facebook's privacy settings and controls over the period covered by this table. | Privacy setting or control | Percentage of UK consumers who viewed the setting or | |----------------------------------------|---------------------------------------------------------| | control over one year (04/18 to 03/19) | | | Ad preferences | [0-5]% | | Privacy Checkup | [20-30]% | | Why Am I Seeing This Ad? Tool | [10-20]% | Source: CMA calculations based on data submitted by Facebook in response to a request for information. 4.98 Facebook also submitted that as of 30 September 2019, [0-5]% of UK consumers have viewed the 'Download Your Information' tool in the past four years. Similarly, as of 31 July 2019, [5-10]% of UK consumers have viewed the 'Access Your Information' tool since the beginning of the year. 4.99 We note that more consumers engage with the privacy check-up tool on an ongoing basis than at sign-up. Facebook introduced this tool to 'assist Facebook consumers to review and adjust their privacy settings' and as such it is expected that engagement with this tool on an ongoing basis will be higher than at registration. 4.100 We recognise that these results are for only two online platforms (albeit the major ones) and that consumers may engage with policies or settings on other platforms differently. However, it is consistent with academic findings, that consumer engagement with privacy policies and settings in practice is lower than reported in consumer surveys. One reason for this is that it is commonly recognised that in participating in a survey, consumers often face a 'social desirability bias', that is, they have a tendency to answer questions in a manner that will be viewed favourably by others. 4.101 Evidence from consumer surveys also provides some indication as to why engagement may be low, although the evidence is mixed. As indicated above, on the one hand, in some surveys, consumers report that they find it easy to change their settings and yet at the same time, it is not clear that consumers find it easy to locate the privacy settings. This is discussed in more detail below in the section headed 'Navigating to privacy settings'. 4.102 Even if consumers can locate the privacy settings, it is not clear that consumers understand the implications of using them. For example, Habib et al (2018) found that two thirds of participants overestimated the protection that 'private browsing' offers.187 A separate survey performed in 2018 found that the description of 'private browsing' offered by major platforms did not clear up common misconceptions.188 4.103 The finding that consumer engagement with privacy settings is low is unsurprising. In the course of our work in other markets, consumer engagement has sometimes remained low despite the existence of strong financial incentives for consumers to participate actively (for example, by shopping around for a better broadband deal or switching energy supplier to avoid paying a loyalty penalty). In the online world of search and social media platforms, there is no direct financial incentive to prompt consumer engagement: consumers 'pay' for services, not with money, but with their data and attention. We might therefore expect engagement with privacy controls to be low except for those consumers for whom privacy is a top of mind issue. 4.104 In these circumstances, the default control settings implemented by the platforms will continue to apply to the collection and use of data for a majority of consumers. ## The Privacy Paradox 4.105 Our finding that consumers say they are concerned about privacy but have low engagement with privacy settings and controls is consistent with findings in the academic literature. A number of academic articles (eg Acquisti (2004), Barnes (2006)) have pointed to the existence of a 'privacy paradox' in relation to the collection of data from consumers in online settings: that is, consumers say in surveys that they value their privacy and that are concerned about protecting it but behave in ways that contradict this stated preference. 4.106 There has been some debate about whether this is in fact a genuine paradox. For instance, given the central role that some services play in consumers' lives, they may feel that there is little point engaging with privacy policies on the basis that they are presented as a 'take it or leave it' choice and an individual consumer is not in a position to negotiate over them. At the same time, other interpretations point out that the framing of choices by platforms and the exploitation of behavioural biases can have an important influence on consumers' privacy decisions. In particular, consumers' choices about privacy controls can be heavily influenced by factors such as the default settings (eg whether to allow ad personalisation or not), how the choice of privacy setting is presented and what language is used to describe the privacy setting. Experimental research has also found that where securing privacy requires additional effort or comes at cost of a less smooth user experience, consumers were quick to abandon technology that would offer them greater protection (Athey et al, 2017). 4.107 In the next section we consider how platforms may exploit some of these aspects of consumer behaviour to induce consumers to make choices that result in them providing more data to platforms than they may otherwise be comfortable with. ## Possible Barriers To Effective Engagement 4.108 It is important that, for those consumers who would like to engage actively in this market, they are able to access and understand information easily and face low transaction burdens in the course of their engagement. In this section, we assess how choices are currently presented to consumers and set out the barriers to effective engagement that we have so far identified. 4.109 For those consumers who seek to engage, the way that choices are presented to them has a significant influence on what they choose. The Data Protection Commission, the supervisory authority for several platforms including Google and Facebook Ireland, notes that organisations can design their websites and use 'branding, colour and font selections to highlight or emphasise certain options rather than others.' They set out that design is important and by highlighting 'Ok' or 'I agree' buttons, consumers may overlook further information that may be less prominent, such as in grey text.189 These are typically referred to as 'dark patterns'. 4.110 The use of dark pattern techniques can nudge consumers to making choices that are in the best interest of the platforms which maximise data collection, rather than their own preferences. To understand how information may affect consumers' choices, we have considered: - evidence on the power of default setting in these and other markets; - what platforms claim about the nature of their service(s) and how they are funded by personalised advertising; - the consumer experience at sign-up and click-wrap agreements; - the presentation of terms and conditions; and - how consumers navigate the controls available. 4.111 We asked platforms if they undertook testing to assess to what extent their controls facilitate engagement on the part of users. We discovered that some platforms do carry out some testing of aspects of their privacy policies and privacy controls but they have not prioritised research to improve consumer control in this area. This finding is at odds with the extensive testing some platforms undertake in respect of other areas of their business. For example, Google ran over 650,000 experiments in 2018 when looking to make improvements to Google Search.190 ## The Power Of Default Settings 4.112 The power of default settings is an area of behavioural economics that has been well researched and is well-evidenced across a wide range of settings eg pension savings, medical insurance, food consumption etc. There is a general recognition that the presence of status quo bias means that individuals will often stick with the default choices they are presented with. 4.113 The Behavioural Insights Team, the NCC and Which? have pointed to the role that defaults have in terms of influencing consumers' choices about sharing data with service providers suggesting that firms could be exploiting behavioural biases to get them to accept privacy-intrusive defaults (so called 'dark patterns'). 4.114 There is some evidence that consumers have a preference for privacy-friendly default settings. Research carried out in 2019 by the US Stigler Center at Chicago-Booth University looked at the privacy and security practices of Facebook, Google, Amazon, and other platforms. They found that consumers would often - but not always - prefer and expect default provisions that enhanced their privacy and security. 4.115 We have therefore focussed our analysis on the default settings on platforms, and the controls available to consumers to change them. When referring to default setting, on platforms which purport to allow the consumer to give their active consent, we treat the settings which the consumer is invited to consent to, as the default settings. We turn to this in Chapter 6 and discuss possible interventions to ensure that settings are aligned with consumers' preferences. ## Long And Complex Terms And Conditions 4.116 An understanding what data is collected and how it is processed, is imperative for consumers to make an informed choice about whether to share data and with whom. We therefore considered the nature of the terms and conditions and how accessible they were. 4.117 We found that platforms' terms and conditions were long and typically located in several places. As shown in Table 4.5, Bing had the longest set of terms and conditions, totalling 27,000 words, in two separate places on their platform. | | Social Media | Search | |------------------------|-----------------|-------------| | | | | | Facebook | Snapchat | Twitter | | Duck | | | | DuckGo | | | | Terms/policies visible | | | | on front/main page? | | | | Yes | Yes | Yes | | No/ | | | | Unclear | | | | 191 | | | | | | | | 9,300 in | 13,300 in 2 | 11,900 in 3 | | Words | 3 parts | parts | | 192 | | | | | parts | parts | | 193 | | | | | | | | 6,500 | | | | 194 | | | | | | | | 27,000 in 2 | | | | parts | | | | 195 | | | | | | | | 2,100 | | | | 196 | | | | | | | | Clickwrap | Yes | Yes | | 197198 | | | | | Yes | | | 199200 | | | | | N/A | | | 201 | | | | | | | | | | | Source: CMA analysis. 4.118 We do not think it reasonable for platforms to expect that consumers have read and understood all of these, often complex, terms before signing up to use a service. 4.119 Faced with this level of text on multiple platforms that may be used every day, it is not surprising to find that consumer engagement with privacy policies is low. A consistent finding in many surveys is that only a minority of consumers claim always to read privacy policies and academic research has also shown that very few consumers read privacy policies when signing up to an online service.202 4.120 When explaining the lack of engagement by consumers, a number of surveys and academic research have identified time as the predominant factor behind consumers' disengagement with privacy policies. McDonald and Cranor (2008) estimated that a consumer would have to spend several weeks per year to read the privacy policies on each website they visited. Given that their research was conducted in 2007, this figure is likely to be much larger today given that the time spent on digital media has increased significantly since that research was carried out.203 At the same time we note that research by the Behavioural Insights Team indicates that telling customers how long a privacy policy takes to read can actually then increase the opening rates for privacy policies by 105%.204 4.121 Even when consumers do click onto privacy policies, they do not necessarily engage with the policies in terms of taking the time to read them thoroughly. As noted earlier, the average visit to the Google privacy page was just 47 seconds. We note that some academic research has suggested that consumers may instead use different methods to assess whether or not to provide consent to online platforms.205 This could include the use of proxy assurances, such as online reviews. 4.122 In summary, we found that terms and conditions are unreasonably long for consumers to read before signing up to services. ## Navigating To Privacy Settings 4.123 For consumers to engage with the privacy settings that platforms provide they need to be able to locate them easily. We found that this was more straightforward with search engines than social media platforms, although the format varied according to the device.206 As a minimum both Google and Bing displayed a small privacy link at the foot of each page. Selecting this provided the consumer with access to the available controls. 4.124 All of the social media platforms that we reviewed purported to provide consumers with easy access to their privacy settings, allowing them to adjust these as and when desired. However, we found that for all the social media platforms reviewed, it is not obvious how to access these settings and the settings themselves may only be visible after navigating through multiple menus. 4.125 For example, on the Facebook desktop website, we found that the Settings webpage can only be reached via a drop-down menu which appears only when a small downward arrow symbol in the options ribbon is clicked, as shown in the screenshots below. Source: screenshot, Facebook. Source: screenshot, Facebook. 4.126 In addition, even when a consumer has been able to navigate to the correct menu, they are often presented with multiple other settings, which serves to reduce the prominence of the location of the privacy settings. For example, on Facebook's Settings Page, consumers are presented with links to 20 different tabs along the left-hand margin of the page, of which 'Privacy', leading to Facebook's Privacy Settings and Tools is one. Source: screenshot, Facebook. 4.127 The effect of making navigation towards privacy settings and the selection of alternative options to the default a multi-stepped and partially obfuscated process has been described as a 'dark pattern'.207 By relying on the fact that consumers generally do not change default settings, platforms are able to maximise the number of consumers that will share the maximum amount of their personal information, to the benefit of the platform. ## Lack Of Clarity About The Service(S) Being Offered To Consumers 4.128 We found that most platforms promoted the benefits of their service, rather than the nature of the exchange between the platform and the consumer. Clearly, it is important that consumers fully understand this exchange before they can make meaningful choices about whether or how to engage with a particular service. While information about the funding relationship could be found, it was not presented prominently to casual users of platforms and only rarely referred to as part of the account creation process. 4.129 Ofcom research shows that only a little over half of adults are aware that the major search engines offer their services at no monetary cost because they gain consumers' attention and data, 208 which they monetise through the sale of advertising. Starting at platforms' homepages, we reviewed the way that Google, Bing, Facebook and Twitter explain their services and the nature of their funding models. 4.130 We found that: - Google and Bing do not describe the functions of their service nor the funding relationship on their front pages. For Google, depending on whether viewing desktop or mobile version, selecting 'How search works' provided a series of information screens that included a link to a statement on funding.209 Consumers are also told that their data will be used for ads during the sign-up for an account although the explanation that ads fund the site requires additional clicks to reach it. The position with Bing was mixed. For those without an account, we found some limited information210 by navigating from an initial cookies statement through several links and screens.211 However, during the sign-up for an account, consumers are told just ahead of account creation that the site relies on advertising. - Facebook and Twitter both provide 'tagline' descriptions of their services on their front pages.212 Facebook's Terms of Service include a statement on how services are funded. Twitter includes the information that 'Advertising revenue allows us to support and improve our services' which was reached by scrolling through several screens in the Privacy Policy.213 However, Twitter users are presented with an option to 'Customize your [their] experience' during the sign-up process and this includes whether or not to accept personalised ads based on information relating to them collected by Twitter 'off-platform'. The explanation provided to consumers before making their choice includes the following disclaimer: 'You will always see ads on Twitter based on your Twitter activity', which is likely to suggest to consumers that advertising is important to Twitter although, again, this is not stated explicitly. 4.131 In April 2019, the Consumer Protection Cooperation Network, a collection of consumer protection authorities within the European Union, took collective action to secure a range of commitments from Facebook.214 The CPC was concerned that Facebook failed to clarify that their main source of revenue was based on the commercial use of consumers' data in exchange of using Facebook's service. In response to those concerns Facebook agreed to make clear that it does not charge for its services, but that consumers will be shown commercial content based on their profile and data and will in future explain its business model, including that it makes money by providing targeted advertising to traders using data from consumers' profiles. 4.132 This is a positive step towards platforms clearly communicating the nature of the bargain to consumers and the basis on which they share data and receive personalised services. However, our initial view is that more can be done, throughout consumers' use of these platforms, to reinforce that consumers are exchanging their attention and data in return for relevant advertising and free services. ## Experience At Sign-Up And Click-Wrap Agreements 4.133 A common theme in our review was the frequent use of click-wrap agreements. A click-wrap is a form of agreement where the consumer must agree to terms and conditions before they are able to use the service. Agreement forms the basis of the data the platform collects and the consumers' acceptance of the terms and conditions. Click-wrap agreements are used by all the social media platforms we examined. As noted above, an account is not needed to use search engines so, while we noted some use of click wraps to create associated accounts, we do not discuss that in detail here. Source: screenshots, Facebook and Snapchat. 4.134 Figure 4.5 shows two examples of click-wrap agreements on social media platforms Facebook and Snapchat. For both, the page emphasises the information needed, but a statement appears in a smaller font size below stating that the consumer acknowledges they have read and agreed to the platforms' terms and conditions and other policies (as applicable). For all the platforms considered, policies are available via hyperlinks. However, below this statement a prominent message is displayed in a large blue button, stating 'Sign up' (or an equivalent message) which must be clicked to continue the process. 4.135 For platforms which are either only accessible via a mobile app, or most likely to be accessed via a consumer's mobile device, it is even more unlikely a consumer will read the relevant terms of service and privacy policies in full before agreeing to sign up. For these platforms, a consumer would either need to review the platform's terms and privacy policy on the small screen of their mobile device or access them via a separate laptop or desktop computer for review there, whilst in the process of signing up. ## Examples Of Better Practice 4.136 Our review of a sample of platforms did find elements of better practice. For example, guidance from the ICO on the presentation of privacy information includes discussion of the challenges of engaging consumers, balancing the amount of information provided, and ensuring that it is sufficiently prominent.215 4.137 Google's approach to privacy information for logged-out consumers incorporates some of these. A clear 'Privacy Reminder' is displayed and, while it was concerning that this can be dismissed or ignored for three days, it does eventually require a response before the consumer can continue. When 'Review' is selected, the information provided is in short summaries with links to further detail. Source: screenshot, Google. 4.138 We also noted that it was possible for platforms to adopt what should be helpful techniques such as layering information and simplifying language in ways which buried key information or made it too vague to be helpful. 4.139 We have heard from platforms that they work hard to ensure their services are easy to use and consumers are clear about what data they collect and the controls available. For example, Facebook emphasised that their terms and conditions have 'been specifically designed to be clear'.216 As recommended by the European Data Protection Board, they said they adopted a layered approach to their terms and conditions. Google also argued that they used 'clear, plain language' in their terms and conditions and we noted they used explanatory videos and infographics to communicate with its consumers, had periodically reminded consumers they could undertake a privacy check-up.217 4.140 We accept that it can be difficult for platforms to communicate a large amount of complex information to consumers, and we have seen some elements of good practice where platforms are clear about the bargain between them and consumers, present content in a visual as well as text format and use plain language. However, we did not find a platform that got all elements right and good practice was not consistent across all platforms. We return to this point in Chapter 6 and consider which elements of good practice can be embedded across all platforms. 4.141 More detail on platforms' sign-up processes, terms and conditions, and navigation to privacy settings, can be found in Appendix F. ## Data Protection Regulation And Competition 4.142 As the preceding discussion makes clear, we strongly support effective regulation that puts consumers in control of their own data. In our study, however, we have heard some concerns that aspects of the design and interpretation of current data protection regulation risks creating competition concerns by unduly favouring the business model of large, verticallyintegrated platforms over smaller, non-vertically-integrated publishers. 4.143 There are two aspects to these concerns in digital advertising markets: - first, that large platforms may use privacy regulation such as GDPR as an excuse not to share data with third parties, thereby consolidating their own market position; and - second, that the design of GDPR and its interpretation by data protection authorities makes it easier for large platforms to gain consent for data processing than smaller publishers, giving the former a strong competition advantage. ## Behaviour Of Large Platforms 4.144 The Furman Review made public that it had received concerns that GDPR was 'enabling large digital companies to impose unduly strict compliance duties on smaller firms, serving to reinforce their own dominance in the process'.218 Similar concerns have been raised with us in the context of this study. 4.145 For example, the Daily Mail Group told us that 'while the GDPR inter alia aimed at placing some limits on the way digital platforms collect and process personal data, these platforms turned this regulation to their advantage'219 and the News Media Association submitted that publishers have struggled to resist attempts 'by global tech companies to force unfair terms on them through the new consents regime'.220 4.146 We have heard concerns that GDPR is being used as an excuse for vertically integrated firms to restrict rivals' access to data and services, even when these do not obviously raise legitimate concerns under GDPR. We explore a number of these concerns in Chapter 5, including recent concerns that Google has removed time stamp data from bid requests, which may harm publishers' ability to compete effectively in the open display market, and Google's decision to prevent the DoubleClick user IDs being accessed by ad buyers, which may impede advertisers' ability to make use of independent attribution modelling and cross-platform measurement of reach and frequency. ## Design And Interpretation Of Gdpr 4.147 We have also heard several concerns, particularly from publishers, that elements of the design and interpretation of GDPR have consolidated the strength of large vertically-integrated platforms. For example, Professor Damian Geradin submitted that that GDPR 'effectively strengthened the position of the platforms on digital advertising markets to the detriment of other intermediaries, but also advertisers and publishers',221 while the Daily Mail Group told us that GDPR has given Google the 'freedom to do what they want with data collected through publishers, while threatening not to serve ads to any publishers which do not satisfactorily obtain consumers' consent on their behalf'.222 4.148 We note that, in principle, the GDPR makes gaining and managing consent within a 'walled garden' to deliver a particular purpose, either within an undertaking, or group of undertakings in common control, an easier exercise than sharing data between undertakings to deliver the same purpose. 4.149 Large platforms who engage in 'bundling' consents, may therefore have an easier and simpler task in purporting to obtain valid consent from consumers to use their data for personalised advertising compared with intermediaries involved in the supply of display advertising in the open market.223 4.150 This may become more pronounced as the display advertising industry moves to address concerns raised by the ICO about how widely data is shared between firms in the open display market and whether current practices provide consumers the opportunity to provide meaningful consent or have visibility about what happens to their data given the number of firms involved. The ICO highlights in its RTB Update report that currently a single RTB request can result in personal data being processed by hundreds of organisations creating risks for transparency, fair processing, security and data sharing. 224 4.151 The effect may be that large platforms such as Google and Facebook may find it easier to get valid consent for processing personal data for use in display advertising and share very little data with third parties, while the open display market involving multiple operators will face greater difficulties in securing consent for using the same data for the same purposes. This will create competitive advantages where data is used within firms compared to situations where the same data is used between firms. 4.152 This presents a fundamental challenge to the non-vertically integrated advertising business model used by newspapers and other online publishers. We have reviewed evidence that suggests that prohibiting publishers from serving personalised advertising in the open display market while allowing platforms to continue to offer personalised advertising would have a very significant impact on publishers' revenue. For example, a recent experiment undertaken by Google indicates that UK publishers earned [between 50% to 65%] less revenue overall when they were unable to sell inventory using personalised advertising but competed against others who could. 225 4.153 We recognise that these are challenging issues. We have had constructive interactions with ICO and the Irish DPC and will continue to engage with them in the second half of the study to explore potential ways forward that could both address legitimate data protection concerns while preserving effective competition in the open display market. In Chapter 6, we outline some potential ideas for further work in this area. ## Initial Findings 4.154 To get a fair deal from the use of their data, we think consumers need to be fully informed about what data is collected, how it is used, and find it easy to choose to accept or reject this or use alternative platforms that do not rely on their data. We found that there may be an imbalance in the relationship between platforms and consumers. 4.155 We note that consumers value relevant advertising and the monetisation of platforms, often through targeted advertising, is key to the provision of free, innovative services, which are a significant benefit for consumers. However, we consider that consumers are only able to judge whether this exchange is fair and meets their needs if they have enough information about how their data is used. Further, they are only able to act on this information if they have full control over their data, allowing them to withhold it and share it if they wish. 4.156 Our initial analysis has found that is not always the case. We found that: - Most platforms we assessed served consumers with personalised advertising by default - we know that consumers are unlikely to change default settings. Recent research also suggests that consumers prefer defaults that enhance their privacy and security. - Consumers have some controls over their data, but frequently platforms do not give them full control and some do not allow consumers to turn off personalised advertising. - Consumers must engage with unreasonably long, complex, terms and conditions and must make several clicks to access their settings. Understandably, consumers rarely engage with these terms and when they do, they spend very little time reading them. It is unreasonable to expect ordinary consumers to read and understand these terms for every platform that they use. - Consumer engagement with privacy policies and controls is low. And platforms do little by the way of systematic testing to measure this or test what would increase consumers' engagement with these policies. Instead they rely on the fact that very few consumers alter the default settings in order to increase their ability to use personal data. 4.157 We recognise that consumers have a range of views and behaviours. There is a minority that want to engage with the detail of how their data is used, while the majority will likely stick with the default arrangements, even if they are inconsistent with their preferences. We want to ensure that any intervention in the market strikes the right balances between this range of preferences - protection for those that need it, and genuine effective choices for those that want to exercise them. 4.158 Effective competition in a market is crucial for securing good outcomes for consumers; equally high standards of consumer protection drive competition on things that matter to consumers. For example, we think that protecting consumers, increasing their trust in the market and offering them appropriate controls will increase their engagement with the market. In turn, we would expect this to provide incentives for platforms to design their services with consumers in mind as they will want to promote the benefits of data sharing. 4.159 As data protection law and its interpretation develops, we think all authorities and businesses can take steps to ensure that it does not harm consumers by negatively affecting competition, particularly by favouring incumbent firms that are vertically integrated or firms that offer a wide range of services so can obtain consent only once, in contrast to a single service provider. 4.160 In Chapter 6 we set out a range of options for possible interventions that could address the harms we have identified. ## 5. Competition In Digital Advertising - Google has market power in search advertising. It has over 90% share of search advertising revenues. Its rivals face significant barriers to attracting advertisers, in addition to the barriers to building share on the consumer side. - Facebook (including Instagram) accounts for nearly half of display advertising revenues and also has market power. It has a significant data advantage over smaller publishers, which both increases the value of its advertising inventory and creates additional barriers for its competitors to overcome. - Online publishers such as newspapers sell their inventory through the open display advertising market. This market relies on a complex and opaque chain of intermediaries to auction advertising in real time. This 'ad tech stack' has been consolidating, and Google now holds a strong position at each level of the value chain. This raises two main sets of concerns: o In acting simultaneously on behalf of publishers and advertisers, and on its own account, Google faces strong conflicts of interest. o Google is able to leverage the market power from its 'owned and operated' advertising inventory into the open display market and make it harder for third-party intermediaries to compete. - Advertisers and publishers face a lack of transparency over key aspects of market functioning, including the quality and effectiveness of advertising, the way auctions are carried out and prices determined, and the remuneration of intermediaries. - We are concerned that advertisers and publishers are likely to be facing worse outcomes than in a more competitive market. This would result in advertisers paying higher prices, which feed through to higher consumer prices, or in a reduced ability of publishers to invest in valuable content. ## Introduction 5.1 This chapter sets out our initial analysis of competition in the digital advertising market. Digital advertising plays a crucial role in funding online content - not just for large platforms such as Google and Facebook, but also for smaller publishers such as news websites and app providers. Consumers will benefit from competition in the digital advertising sector where this drives down costs to advertisers and hence consumers, and where content providers are able to use advertising to fund services that consumers value. 5.2 In the first six months of the market study we have sought to understand how digital advertising works and to identify the broad areas where the market might not be working well. We have focused on understanding the extent to which features of the digital advertising market might exacerbate the concerns about the large platforms' market power and their control over personal data outlined in the previous chapters. We have also sought to understand how programmatic advertising technology works and assess potential concerns about competition between the intermediaries that supply this technology. 5.3 The chapter discusses our initial findings in relation to: - the characteristics of digital advertising markets, including how advertisers buy digital advertising and the degree of substitution between different forms of advertising; - search advertising, including Google's position as the largest search advertising provider, and barriers to competition arising from features of the advertising side of the market; - display advertising, including the market power of Facebook as the largest display advertising provider, and barriers to competition in digital display advertising; - the open display segment of the display advertising market, including issues relating to lack of transparency and Google's position in the ad tech stack; and - broader issues arising from the relationship between platforms and publishers. 5.4 We conclude with a summary of our initial findings on this theme and indicate the areas that we expect to focus on in the second half of the study. ## Characteristics Of Digital Advertising Markets 5.5 This section identifies the broad characteristics of digital advertising markets. It then summarises our initial understanding of how advertisers buy digital advertising and the degree of substitutability between different types of advertising. Finally, it sets out some of the possible implications of a lack of transparency. ## Types Of Digital Advertising 5.6 As set out in Chapter 2, there are three main types of digital advertising: - Display advertising - where advertisers pay online companies to display advertising using a range of advertising content types shown within defined ad units on web pages or mobile apps; - Search advertising - where advertisers pay online companies to link their company website to a specific search word or phrase so that it appears in relevant search engine results; and - Classified advertising - where advertisers pay online companies to list specific products or services on a specialised website serving a particular vertical market. 5.7 Within these types of advertising many further distinctions can be made. One of the key distinctions within display advertising is whether advertising content is in video or non-video format. There are also important differences in how display advertising is bought. Advertisers can choose to buy display advertising by making direct deals with media owners or using technology that enables the advertising to be bought via a real-time auction as the consumer opens the relevant web page. This technology can either be provided 'inhouse' by the digital platform that is also the media owner, such as Google and Facebook, or by intermediaries. 5.8 We did not find that there was a consistent industry definition for what should be included within classified advertising. For the purposes of our study, we noted that there are a broad range of online platforms focused on specific sectors that provide the ability for advertisers to list specific products and services and the functionality for consumers to then make comparisons across these listings. Sectors where classified advertising is common include recruitment, ecommerce, consumer finance, travel, property and cars. We have considered the role of classified advertising previously in our Market Study on Digital Comparison Tools.226 5.9 Below we have focused on competition in search and display advertising. We have not looked in detail at classified advertising but have rather considered its possible role in providing competition to other forms of digital advertising. ## Demand For Advertising Advertiser Decision Making 5.10 Decisions made by advertisers choosing digital advertising media tend to be data-driven using measurable indicators. Advertising campaigns are planned by first defining the business objectives and available budget to achieve these objectives. Advertisers, or commonly the media agencies advising them, will then determine a series of metrics, or key performance indicators (KPIs), relating to the outcomes the advertising campaign is hoping to achieve. 5.11 Typically, KPIs relate to either the impact of the advertising on brand awareness at one extreme or to driving specific consumer actions (eg sales or enquiries) at the other. Several advertisers and media agencies referred to the 'marketing funnel' or 'purchase funnel', which illustrates the mental steps along the consumer journey to making a purchase of a product or service - from awareness to consideration to purchase. At the top of the funnel, KPIs relate to improving the awareness of consumers that are 'out-of-market' and are not currently aware of the product or service. At the bottom of the funnel, KPIs relate to selling to those customers who are 'in-market', in that they may have expressed some preference for the product or service but have not yet bought it. Source: CMA. 5.12 Choice of appropriate digital advertising inventory is largely based on optimising the outcomes of advertising on the KPIs being targeted. In order to assess this, advertisers or their agents need to be able to measure outcomes. This means that, in addition to the performance of media in meeting KPIs efficiently (at low-cost), principles of accountability227 and measurability228 are also important in driving advertiser choice. At a high level, advertisers and their agents will choose the media that best meets their specific objectives but may face diminishing returns in each media channel they use. 5.13 In some cases, choice of inventory is driven by attributes that are exclusively available within a certain advertising channel. Certain channels may have access to inventory, data or technology that allows for the targeting of specific audiences not available elsewhere. Advertisers can also be motivated by various distinct factors in their choice of platforms, for example commercial agreements or restrictions due to the nature of their products (eg gambling, pharmaceuticals). ## Advertiser Segmentation And Multi-Homing 5.14 Larger, more sophisticated advertisers often use media agencies and technology tools to purchase inventory from multiple sources. The large five media agencies229 directly account for approximately one quarter of overall expenditure on digital advertising, though this is higher for display advertising (44%) than for search advertising (13%).230 5.15 Almost all the larger advertisers that responded to our questionnaire use a media agency and highlighted the following benefits of doing so: - best practice advice and external expertise in designing campaigns and allocating budget across advertising channels; - greater economies of scale and scope in resource requirements (manpower, technology and expertise); and - preferred trading arrangements, eg volume discounts, negotiated by the agency. 5.16 In many cases media agencies are remunerated on a commission basis based on the amount spend by the advertiser (though sometimes on a fixed fee basis and sometimes with performance fees). In general, media agencies exploit their scale to negotiate volume rebates with media owners based on aggregate spend across the media agency. They typically then share these rebates proportionally with their advertising clients. However, media agencies have told us that their ability to negotiate discounts from the large digital advertising platforms (such as Google, Facebook and Amazon) is limited, as the vast majority of inventory is sold by auction and the large platforms tend not to offer discounts. There are some opportunities to negotiate volume discounts from smaller platforms or media owners, particularly those that work on a fixed-price basis when selling to advertisers. 5.17 Larger advertisers told us that the benefits of using multiple platforms to purchase advertising from various sources was that this provided them with greater variety of audience and more flexibility in optimising targeting capability and cost effectiveness, allowing them to better achieve KPIs. Some advertisers also mentioned that a multi-platform approach avoided them being overly reliant on a single platform. Most suggested that while there were some issues in comparing advertising performance across platforms, these were not sufficient to stop them multi-homing. 5.18 Smaller, less sophisticated advertisers are less likely to multi-home across platforms or use media agencies, due to the proportionally greater transaction costs in doing so. Instead, they more commonly go directly to Google and Facebook due to their wide reach and their simple self-service interfaces, eg Google Ads or Facebook Ad Manager. This suggests that Google and Facebook may have a competitive advantage in competing for smaller advertisers. 5.19 Both Google and Facebook have very long tails of small advertiser clients. Expenditure of the median UK advertiser in 2018 on Google Search was only £[200-300] while the mean was £[16,000-17,000]. Expenditure of the median UK advertiser in 2018 on Facebook was only £[0-100] while the mean was £[500-1000]. Smaller advertisers account for a significant proportion of these platforms' revenues. [15-20]% of Google's 2018 UK search advertising revenues came from advertisers spending less than £100,000 and [30-40] % came from advertisers spending less than £1 million. About half of Facebook's advertising revenue comes from smaller clients. ## Supply Of Advertising Inventory 5.20 Search advertising is the largest category of digital advertising, with total ad spend of £6.4 billion in 2018. Search advertising is sold predominately by two leading search engines, Bing and Google. Amazon also sells search advertising in the form of Sponsored Brands and Sponsored Products that appear in the search results on its ecommerce platform. However, Amazon's search advertising differs from search advertising provided by search engines as it is only available to sellers on its platform. 5.21 Total spend in display advertising was worth £5.1 billion in the UK in 2018. About 60% of expenditure is made on owned and operated platforms, which typically provide social media to consumers. The largest of these platforms is Facebook, which owns both Facebook.com and Instagram. YouTube is the second largest and is owned by Google. Other platforms selling a smaller amount of display advertising include Snapchat, Twitter, Pinterest, TikTok, Verizon Media, LinkedIn and Amazon. 40% of ad spend is made through intermediaries used by advertisers to access many publishers of smaller scale (for example, suppliers of news media and app providers). 5.22 Google and Facebook are active in display advertising both through their owned and operated platforms (Facebook, Instagram, YouTube) and through activities providing various intermediation and technology services, which are discussed in more detail within our assessment of open display advertising. ## Substitutability Between Advertising Media 5.23 To inform our assessment of competition, we have considered substitutability between digital advertising and other more traditional forms of advertising, such as TV, and distinctions within digital advertising, such as between display, search and classified and, within display, between owned and operated and open channels and between video and non-video advertising. 5.24 We sought the views of advertisers and media agencies on how decisions to allocate budget between different types of media are made and what this implied for substitutability. The views of the large media agencies are of particular significance, given their role in acting on behalf of a wide range different advertising clients and buying across all types of advertising media. While media agencies said that substitutability between different media depends on the nature of each advertiser and the specific objectives of their campaign, both agencies and advertisers identified some areas where substitutability is likely to be more limited. ## Between Digital Advertising And Traditional Advertising Media 5.25 At a high level, the ability for advertisers to use data to target specific audiences online distinguishes it substantially from traditional advertising media. In the case of search advertising, advertisers can target audiences that have expressed intent through their search queries, and in display advertising, advertisers can use data gathered by online companies to target specific audiences. 5.26 We focused particularly on the extent to which video display advertising is substitutable with TV advertising (including Video on Demand), as this seems to be where similarities between digital advertising and traditional advertising media are greatest. Our discussions with media agencies and with TV media owners suggested that there is limited substitutability between the two, principally because the greater availability of data in online display advertising means that more specific audiences could be targeted than through TV. This means that advertisers would only find TV advertising to be substitutable with online display in certain circumstances.231 TV advertising can be used for advertising campaigns with broad reach or where the desired audience can be defined by the context (ie TV programme) within which the audience is shown. Our understanding is that TV advertising is also unlikely to be an effective substitute for the long tail of smaller advertisers that use Google and Facebook. This is because TV advertising needs to be bought at some scale and providers tend not to offer such simple self-service interfaces for smaller advertisers as Google or Facebook. 5.27 Google and Facebook both submitted to us that they compete with a wide range of media owners, including those supplying traditional advertising media, such as TV. They suggested that the characteristics of the advertising products that are offered by TV and online are becoming closer. The view that TV advertising and online display advertising were likely to converge as TV made greater use of user data was shared by some stakeholders. However, there was not a suggestion that this change was likely to occur imminently. ## Between Search And Display 5.28 We noted a consistent view that search and display advertising are unlikely to be substitutable in general. All media agencies and most advertisers told us that search and display advertising are not substitutable, mainly because they perform different roles within the customer purchase journey. Search is intentbased advertising designed to provide immediate answers to those consumers that have already shown interest in buying the product and are at the end of the purchase funnel ('in-market consumers'), whereas display is suitable for raising brand awareness and reaching new audiences that might not yet have shown interest ('out-of-market consumers'). 5.29 This distinction is reflected in the advertising KPIs that search and display are typically used to target. Almost all respondents suggested each had relative advantages in targeting different KPIs: display is considered more versatile and typically cheaper at driving reach and brand awareness objectives, while search is considered closer to the point of purchase and so better for targeting actions, conversions or sales. Some respondents mentioned that search and display advertising work well in tandem. 5.30 Most advertisers set budgets for search and display advertising independently and do not allocate them interchangeably. Some told us that they might switch budget from display to search when the campaign objectives change. Most advertisers told us that they had not changed their broad approach to allocating budget between search and display over the last few years. However, there were several recent instances mentioned by advertisers of budget being switched from display to search following analysis showing that display was not performing as well in terms of return on investment (ROI) and other KPIs. 5.31 The distinction between display and search was to a large extent reflected in the views we received from suppliers of digital advertising inventory and in their internal documents. However, several suppliers of display advertising inventory suggested that they also competed with Google Search, particularly due to its scale across the digital advertising sector as a whole. Google and Facebook identified each other as key competitors for advertising and also pointed to a wider set of online and offline competitors including TV advertisers, video streaming services and Amazon. ## Between Classified And Search Advertising 5.32 We have heard a consistent view from advertisers that classified advertising, or paid listings on sector-specific websites, is not a substitute for search advertising. Few advertisers that responded to our questionnaire use classified advertising, but those who do all said that classified and general search advertising are not substitutable but are rather used in tandem to achieve advertisers' goals. This is because they target different points of the purchase funnel and can be used to reach different audiences. Search has a higher reach, is cheaper and is best used to achieve conversions for a wider audience that has demonstrated general intent, while classified is more expensive, has lower reach and is used to achieve conversions within a narrower audience that are engaged in actively researching specific products or services. 5.33 Notwithstanding these advertiser views, we have considered in more detail later in the chapter the competitive constraint that classified advertising may impose on Google, due to its importance in understanding the extent of Google's market power. ## Between Video And Non-Video Display Advertising 5.34 We received views that suggest limited substitutability between video and non-video advertising. Media agencies told us that decisions between video and non-video advertising were typically likely to be driven by the need to convey the advertiser's message in the best way. These decisions were likely to be taken at an early stage of the planning process, driven by input from the creative agency. This would limit substitutability between video and non-video advertising. ## Between Owned And Operated And Open Display Advertising 5.35 Media agencies told us that similar advertising formats and audiences are available on owned and operated platforms and in open display advertising and that the targeting techniques available are also roughly the same. Consequently, advertisers would largely see these channels as substitutable and decisions would be driven by the ability of the inventory chosen to meet specific KPIs. Media agencies highlighted that there are some contextual differences that may affect consumer engagement with the advertising. Owned and operated platforms such as Facebook showed display advertising in the consumer's news feed while open display advertising would typically be embedded in articles. However, advertisers would largely see owned and operated and open display advertising as substitutable in spite of these differences. ## Overall View On Substitutability Between Different Media 5.36 The evidence we have gathered so far suggests that the competitive constraint imposed on search and display advertising by other forms of advertising is likely to be limited. Similarly, search and display advertising appear likely to impose little competitive constraint on one another. In our view, it is most appropriate for us to consider competition in search and display advertising separately from one another and from other forms of advertising. In the case of display advertising, it seems likely that a further segmentation between video and non-video advertising would also be appropriate, though we will look at this further during the rest of the study. ## Lack Of Transparency 5.37 For there to be effective competition between suppliers of advertising inventory, advertisers need to be able to make informed choices about the inventory that they buy. Effective competition between intermediaries relies on both advertisers and publishers being able to make informed decisions on the channels through which they buy and sell. However, advertisers and publishers face a lack of transparency on several aspects of digital advertising needed for them to drive effective competition. For example, there may be a lack of transparency over: - the quality and effectiveness of advertising; - how auctions are carried out and how outcomes are determined; and - how intermediaries acting on advertisers' or publishers' behalf are remunerated. 5.38 In many markets, attempts by suppliers to exploit a lack of transparency will often harm both the demand and the supply sides of the market, as it reduces the trust that customers place in the market. This creates a natural incentive for suppliers to act in a way that preserves their reputation. However, in the case of digital advertising this reputation mechanism may not be sufficient. 5.39 Advertising has some of the characteristics of an 'experience good' in that it is only possible to evaluate its quality and effectiveness after an advert has been shown to an audience.232 Many advertisers are small and micro-businesses or even individuals. This means they are likely to be relatively unsophisticated in their understanding of the market. The complexity of digital advertising makes it difficult for non-specialist advertisers and publishers to monitor and evaluate the effectiveness of advertising for themselves or make the rational, wellinformed choices that drive effective competition. Moreover, it may not always be the case that the intermediaries used by advertisers and publishers to buy and sell inventory or to evaluate market outcomes have the right incentives to act in their customers' best interests or the ability to access the data required to do their job. 5.40 The wide volume of data available in digital advertising goes some way to addressing the need on the part of advertisers to understand the effectiveness of their advertising. That is, in digital advertising buyers and sellers potentially have access to a range of data on everything from the interests of potential customers, the devices they use and their location at any point in time. This provides the ability to target audiences more precisely and so reduce the 'wastage' that is a feature of traditional advertising media such as TV. It should also mean that the effectiveness of advertising can be monitored and assessed more accurately after it has been shown.233 5.41 However, the use of this data results in substantial complexity. The sale of digital advertising involves high volumes of transactions in real time with much of the buying and selling being carried out by automated trading programmes. Intermediaries and technology providers perform various functions to make this process work, such as running auctions to aggregate supply and demand, providing and analysing the data required for audience targeting and for verification and measurement of advertising outcomes. The complex way in which digital advertising is sold means that it is more difficult for individual advertisers to make an informed assessment of the effectiveness of advertising outcomes. Data is also unevenly distributed across market participants. This creates scope for outcomes to be misrepresented and for the incentives of advertisers and the intermediaries representing them to be misaligned. 5.42 We are aware of academic research which has raised concerns about the measurement of the effectiveness of some online advertising.234 Other research has also found that in spite of the information about the potential lack of effectiveness of brand search advertising being widely reported in the popular and business press, a majority of advertisers continued with 'business as usual', suggesting a substantial inertia of business practices. In addition, the research found that advertisers did not react to the information about the ease and benefits of running experiments to carry out their own testing of the effectiveness of their advertising.235 5.43 Platforms and intermediaries may have the incentive and ability to exploit the asymmetries of information and inertia on the part of advertisers in a number of ways. For instance, platforms with market power can take steps to reduce the degree of transparency in digital advertising markets, or refrain from taking steps to make it more transparent, forcing advertisers to rely on information and metrics provided by those platforms. Asymmetric access to information across suppliers may also create opportunities for exclusionary behaviour on the part of the large advertising platforms. The upshot of all of these issues may be that competition is weakened. These issues are considered in more detail below within each of the digital advertising sectors we have looked at. ## Competition In Search Advertising 5.44 This section sets out our initial findings on competition in search advertising. It covers: - our understanding of the competitive process, including how advertisers choose between search engines and how search engines may respond to competition; - evidence on market outcomes in search advertising, including market shares, prices and trends over time; - the competitive constraints on search advertising from classified advertising or specialised search; - barriers to entry and expansion; and - how market power may be exploited. 5.45 Our initial findings are based on the views of advertisers and media agencies and of suppliers of search advertising. We have also sought evidence on market outcomes from suppliers of search advertising. ## Competitive Process How Search Advertising Is Sold 5.46 In search advertising, advertisers bid to link their company website to specific keywords so that the links appear in relevant search engine results. In the vast majority of cases, advertisers will only pay when a consumer clicks on their link (cost-per-click), though in a small minority of cases they may choose to pay only for impressions.236 5.47 Search engines use second-price auctions to set prices for advertising inventory, where the price paid by the advertiser that wins the auction (and so the right to display the link in relevant search results) is determined in part by the value of the second-highest bid. A key feature of the auctions used in search advertising is that outcomes are also determined by the relevance to the search query of the underlying content of the advertiser website to which the advertising links.237 Search engines assess relevance directly and use this assessment to weight bids from different advertisers on a real-time, in-auction basis. 5.48 These weightings have a direct bearing on whether the advertiser's link is displayed in search engine results at all for any given search and on the costper-click that the advertiser pays if the results are displayed. The price paid by the winning advertiser is equivalent to the bid that would have been required to match the second-highest bid, given the relative relevance weighting of the two bids. Higher relevance will mean the search engine places greater weight on the advertiser's bid, with the result that its advertising is more likely to appear in search results and at a lower cost-per-click. 5.49 The quality adjustment process is one way that search engines can influence outcomes and prices - we discuss this in more detail later in the chapter. It can also improve relevance, which is a benefit to both consumers and advertisers as it means that search advertising is only shown to audiences that have expressed their interest in the relevant product or service through their search query. ## Demand For Search Advertising 5.50 The complexity of the auction mechanism means that buying search advertising is a data-driven process that requires advertisers to make many granular decisions. These decisions include: - Which keywords to bid for - advertisers may often bid on thousands of keywords simultaneously. They choose which keywords to bid for based on their likely relative return on investment. Performance is typically measured in terms of the conversion rate, in other words the extent to which consumers that click on the advertising go on to make a purchase. - How flexible to be with matching to those keywords - advertisers can also choose from different matching functions that determine how these keywords are matched to consumer search queries. At one extreme, advertisers can specify that the keyword has to exactly match the search query, for example Google's 'Exact Match' function. At the other extreme, the advertiser can rely on algorithmic matching provided by the search engine which links the keyword to similar search queries, for example Google's 'Broad Match' function. - Which consumers to target - advertisers often use data to target search advertising on specific audiences (for example by demographic or depending on whether they are an existing customer). Targeting more specific audiences can increase return on investment substantially and provide additional segmentations across which relative performance can be measured. - How much to bid - in addition to choosing which keywords to bid for, advertisers also choose how much to bid for each keyword. As outcomes are determined by second-price auction, an advertiser's bid does not directly determine how much it pays, but rather affects its ranking in the auction and consequently its ranking in the search results (and indeed whether it appears at all). Advertisers may delegate some of this decisionmaking to the search engine by using automated bidding tools. These tools automatically adjust an advertiser's bid to optimise performance within their budget. 5.51 In approaching these decisions, advertisers attempt to optimise their expenditure on search advertising continuously over time, by setting their bids to allocate their expenditure to the keywords, search engines and target audiences where their return on investment is greatest. Often, they will use technology tools such as Google's SA360 to automate this process. This provides the mechanism for competition between search engines to occur. If the return on investment from bidding for keywords on one search engine is greater than another, eg because the conversion rate is higher or the costper-click lower, advertisers will divert expenditure to bidding for keywords on that search engine. ## How Search Engines Compete For Advertisers 5.52 Search engines are two-sided platforms that compete for both consumers and advertisers. Consequently, the main way in which search engines compete for advertisers is indirect, ie through attracting consumer attention. Search engines attract consumer attention through offering high-quality, relevant search results and then monetise this attention by offering the opportunity for advertisers to incorporate relevant advertising into these results. 5.53 Search engines also compete more directly for advertisers, through various mechanisms. They compete through the quality of interface offered to advertisers and through the use of data to offer more granular audience targeting and the measurement of advertising outcomes. As search advertising is targeted on keywords which relate to specific consumer search queries, audience targeting is incrementally less valuable than in display advertising. However, most advertisers and media agencies we contacted did use audience targeting to some extent. As search advertising is often used for achieving conversions, measurement of outcomes and attribution analysis is particularly important.238 5.54 While search engines use auctions rather than setting prices directly, we have identified various levers at their disposal to directly and indirectly influence advertising prices and conversion rates. Search engines determine the maximum number of ads that can be shown per search query, how these ads are presented, the way in which relevance is assessed, the level of reserve prices, and the way in which matching algorithms work. In some cases, they also determine advertisers' optimum bidding strategy on their behalf. These levers collectively determine the extent to which advertising is shown at the expense of organic search results, while influencing which adverts are shown and the prices advertisers pay. ## Market Outcomes In Search Advertising 5.55 In addition to shares of consumer attention and search traffic described in Chapter 3, we have looked at evidence on various market outcomes in search advertising. This evidence and the supporting data are set out in more detail in Appendix C on market outcomes. 5.56 Figure 5.2 below shows that UK search advertising revenues have grown steadily over the last few years. Google's revenues grew from £2.3 billion in 2010 to £6.0 billion in 2018, reflecting a compound annual growth rate of around 12%. Google has continued to account for more than 90% of search advertising revenues, an order of magnitude greater than its next closest rival, Bing. In our view this evidence strongly suggests that Google benefits from market power, particularly when interpreted in light of the scale advantages discussed in Chapter 3 and further below. Source: CMA analysis of parties' data. 5.57 We have also looked at evidence from Google and Bing on average prices, or cost-per-click, from July 2016 to June 2019, split between prices charged for searches on desktop and prices charged for searches on mobile devices. This is shown in Figures 5.3 and 5.4 below. Average desktop prices are higher than mobile, perhaps because consumers are more likely to purchase higher value items or are more likely to complete purchases when using desktops. 5.58 We note that Google has achieved somewhat higher prices on average than Bing over the period. This is consistent with feedback from advertisers, most of whom suggested that Google tended to have higher prices than Bing for similar keywords. However, at this stage we interpret the evidence on relative pricing with some caution. In particular, we note that relative prices are likely to be driven by composition effects, notably: - differences in search terms entered by consumers on either search engine; - differences in conversion rates, either reflecting differences in the users of either search engine or differences in the ability of either search engine to target and track attribution; and - differences in the population of advertisers using either platform, for example smaller advertisers may be more likely to single-home on Google. 5.59 We are not able, therefore, to conclude on the basis of this data alone whether Google has higher prices than Bing on a like-for-like basis. We will consider in the second half of the study whether we can produce a more likefor-like comparison of prices. 5.60 Finally, our analysis of market outcomes shows that there has been a substantial shift over time from advertising delivered to consumers on desktop to advertising delivered to consumers on mobile. This is consistent with other market reports we have seen239 and reflects the underlying increased usage of mobile devices. We note that this shift may benefit Google over its rivals, due to Google's default status on nearly all mobile devices. The continuation of this trend would mean that Google is able to gain an increasing overall share of search queries and advertising revenues as well as gain an advantage over rivals from the data it can gather from mobile devices. ## Competitive Constraint From Specialised Search 5.61 Google submitted to us that it faces strong competition from a range of different 'vertical search services' (ie 'specialised search services') who specialise in paid listings in particular sectors, eg Amazon in retail and Booking Holdings in travel.240 Google told us that because consumers search (offline and online) for particular things, different competitive constraints are relevant to different query types. It said that [a small proportion] of search queries generate most of Google's search revenues. These are commercial queries (eg shopping, credit cards, finance, travel, hotels, plumbers etc). Specialised search services exist in each major commercial content category and Google competes with these services. Google also said that the pressure on it to innovate derives not just from competition in one category alone, but from the aggregate effect of competition across all categories. 5.62 However, the evidence we have reviewed so far suggests that, with the possible exception of Amazon, these specialised search providers do not impose a strong competitive constraint on Google, even in the sectors within which they specialise. 5.63 As noted above, the advertisers we have contacted so far during the study have been unanimous in their view that paid listings on classified sites are not substitutable for general search as the two are used for different purposes. 5.64 Further, we note that this issue has been looked at before in the context of the European Commission's Google Shopping investigation, which considered whether specialised search services were in the same market as general search.241 It found the markets to be distinct for a range of reasons. Most notably, the Commission found that the two types of service operate as complements rather than substitutes as a substantial number of consumers access specialised search via general search rather than accessing them independently. 5.65 We note evidence that in most sectors it appears that the relationship between general search and specialised search services tends to be more vertical than horizontal in nature. In other words, rather than providing an alternative for consumers and advertisers using specialised search providers, it appears to a large extent that Google's general search performs the function of a 'gatekeeper', through which consumers access specialised search. Google is a key source of consumer traffic for all the specialised search providers we have identified. This was highlighted by advertisers that responded to our questionnaire and is supported by Comscore data, which suggests (for desktop only) that a large proportion of traffic arriving on vertical search websites comes directly from Google websites.242 5.66 In turn, it appears that a large proportion of Google's revenues in sectors where vertical search providers are present comes from the vertical search providers themselves, rather than from advertisers choosing to advertise on general search as an alternative to vertical search.243 5.67 We note that some specialised search providers may be becoming more successful in generating their own traffic through promoting their brands and mobile apps, particularly as mobile usage has increased. However, in most cases they still appear to be heavily reliant on Google. For example, Booking Holdings has strong brands (Booking.com, Priceline, Kayak) and a large share of the online travel agency (OTA) market but still spends about half of its total global operating costs on performance marketing (primarily search advertising with Google).244 5.68 One notable possible exception to this is retail, where the evidence that Google competes directly with Amazon is more compelling. While Google is an important source of consumer traffic to Amazon (Amazon being one of Google's largest search advertising customers) we note survey evidence that suggests Amazon is the preferred consumer starting point for product search.245 In addition, we note that Amazon is likely to have important competitive advantages from its broader role as an ecommerce channel (for example from its physical distribution network, its Prime membership and its first-party data built on its consumers' shopping histories). The value of Amazon's first-party data was stressed to us by media agencies and several advertisers from the retail sector. 5.69 However, even if Amazon imposes some competitive constraint on Google in relation to retail search advertising, this would only apply to advertising representing a minority of Google's revenues in search. From IAB 2018,246 we note that 18% of search revenues are derived from the retail sector. Amazon may compete to some extent in other sectors defined in the IAB report, such as consumer electronics. However, collectively it appears unlikely that Amazon competes with Google in sectors exceeding one third of Google's search advertising revenues.247 ## Barriers To Entry And Expansion 5.70 In order to sell search advertising, potential entrants need to be successful in attracting search queries from consumers. This means that the barriers to entry on the consumer side of the market, derived from the need for access to reported retailers. a search index, from economies of scale and scope in click-and-query data and from defaults as described in Chapter 3, are naturally also relevant to potential entrants wanting to supply search advertising. 5.71 In addition to these advantages from the consumer side of the market, Google appears to derive additional advantages on the advertising side of the market which create further barriers to entry. These advantages come from singlehoming by (particularly smaller) advertisers, Google's better data for targeting and better synchronisation with Google Analytics, and Google's ability to influence advertiser behaviour through its ownership of the search intermediation tool SA360. 5.72 Transaction costs faced by advertisers in using multiple search engines appear likely to benefit Google and create a barrier to entry for smaller rivals. Most of the larger advertisers we contacted did not suggest there was a difficulty in multi-homing across multiple search engines and used tools such as SA360, or those provided by third parties such as Marin and Kenshoo, to do so. However, a minority of the larger advertisers who responded to our questionnaire choose to single-home as Google had a sufficiently large market share and reach to meet all their needs. We understand that many smaller advertisers choose to single-home, using the simple interface provided by Google Ads and benefiting from its broad reach. We intend to investigate this issue further in the second half of the study. 5.73 Access to demand from a significant proportion of advertisers that singlehome may also provide Google with greater advertiser density, allowing it to run more competitive auctions that generate higher prices and more relevant ads. This is likely to be of particular benefit for more specific keywords relating to the 'tail' of less common search queries. These keywords (which for example might include more detail on product characteristics desired by the consumer) tend to be preferred by advertisers as they can allow for more specific targeting, resulting in higher conversion rates and returns on investment. 5.74 Google's extensive first-party data is also likely to have substantial advantage over smaller rivals, creating a barrier to entry for potential rivals. Google's first-party data means that advertisers can target search advertising on particular audiences (and have confidence in the composition of those audiences), allowing them to improve performance. Several advertisers highlighted Google's first-party data as an advantage over Bing. 5.75 Advertisers also told us that Google had an advantage from better synchronisation with Google Analytics, allowing for better measurement and attribution of advertising performance than Bing. Microsoft told us that Google had additional advantages in measuring effectiveness from the prevalence of its online Tags and from its mobile data that allowed it to measure offline conversion in the form of store visits (in addition to deals it had negotiated with third parties such as credit card providers). It pointed to publicly available research indicating that Google tags (ie Google Analytics, Google Ads and Floodlight tags) cover about 88% of UK websites, whereas Microsoft's tags cover less than 1% of UK websites. Given the importance of measured performance in driving advertisers' decisions on how to allocate expenditure in search advertising, in our view it is highly likely that these advantages would create a barrier to entry for potential rivals. 5.76 In addition to these advantages, Microsoft further explained that Google Search also benefits from the relative interoperability between SA360, a tool used by many advertisers to automatically optimise expenditure across keywords and platforms, and Google Search compared to that between SA360 and Bing. Microsoft has stated that Google did this in two ways: - Data on bids from Google Search is fed back to SA360 and combined with conversion data in real time, while bidding data from Bing comes back only periodically. This can make it appear to advertisers that Google Search is performing better on SA360 because conversion information for Google appears before Bing and automatic budget allocation rules will correspondingly allocate it more budget. - New functionalities of Google Ads are introduced on SA360 quickly while Bing has often had to wait significant periods of time for innovations in the functionality of its search engine to be adopted by SA360. 5.77 We intend to investigate Microsoft's concerns more fully in the latter part of the study. ## Exploitation Of Market Power 5.78 Search advertising prices are set by auction, based on the bids submitted by advertisers, rather than being set directly by the search engine. This raises an important question as to whether a search platform with market power has the ability to influence the prices that advertisers pay. Our current understanding is that search engines have several levers through which they can influence market outcomes such as the quantity of advertising and advertising prices. 5.79 A profit-maximising search engine has the incentive to maximise the revenues it earns from search advertising. It can earn greater revenues both by designing its auctions to more effectively extract economic rents from advertisers, driving higher advertising prices, and by selling more advertising at the expense of organic search results. The market power of Google's search engine could allow it to use either of these mechanisms to increase search revenues. 5.80 Higher advertising costs may be passed on to consumers through the impact advertising costs have on competition in downstream markets. Higher advertising prices may be passed through directly to the prices of products bought by consumers in cases where search advertising is treated by advertisers as a variable cost relating to each product. Alternatively, where search advertising is treated by advertisers as a fixed cost required to enter the market, higher search advertising prices may raise barriers to entry for smaller rivals unable to afford access to search advertising. This will also indirectly raise downstream prices to final customers. 5.81 The following paragraphs explain ways in which Google could in principle apply its various levers to exploit market power. We have not as yet established to what extent these levers are employed in practice and will consider this in the second half of the study. ## Advertising Capacity And Presentation 5.82 Google determines the overall limit on the number of advertisements that can appear in search results and how these advertisements are presented alongside organic search results.248 It could exploit market power by crowding out organic search results with more advertisements that are shown more prominently, or in a way that makes them less distinguishable from organic search results. We note some evidence that Google may have increased the number of ads appearing in certain search results over time.249 ## Reduced Weighting On Relevance Compared To Bid Levels 5.83 Google could also affect the overall volume of advertising shown at the expense of organic search results through reducing the weight it places on the relevance of advertisements in its auctions compared to the level of bids. By setting lower Ad Rank Thresholds (the thresholds for the relevance required for advertising links to appear in the results) for some auctions,250 Google could monetise its search results to a greater extent at the expense of organic search results. ## Setting Of Reserve Prices And Quality Adjustments To Extract Rent 5.84 Google's Ad Rank Threshold also acts as a reserve price, directly determining the price paid by advertisers when only one bid exceeds the threshold. This is the case in [the majority] of Google's auctions, representing [a material proportion] of its revenues. In these cases, by setting a higher Ad Rank Threshold251 Google could increase the price paid by advertisers, thus extracting more economic rents.252 5.85 We note that Google sets the Ad Rank dynamically across each individual auction. This could allow it to set higher Ad Rank thresholds in auctions where only one bid is likely to exceed the threshold and lower Ad Rank thresholds in auctions where multiple bids are likely to exceed the threshold (in these cases allowing it to show more advertising at the expense of organic search as described above). 5.86 In auctions where there are multiple bidders that exceed the Ad Rank Threshold, the price paid by the winning bidder is determined by a function of the value of the second-highest bid and the quality adjustments Google makes to either bid. This may provide Google with flexibility to increase the price paid by the winning bidder, either by increasing the quality adjustment applied to the second bid or by reducing the quality adjustment applied to the first bid. ## Matching Algorithms And Automated Bidding 5.87 In addition to the quality adjustment process, there appear to be other mechanisms where there may be scope for Google to exploit market power. For example, we note that matching algorithms are used to match keywords to search queries and that Google Ads runs automated bidding to allocate advertiser budgets on their behalf. These mechanisms could give Google some flexibility in allocating advertiser bids across auctions and Google may face conflicts of interest in doing so. For instance, it may have the incentive to match keywords very broadly, potentially resulting in more advertising being shown in search results where it is less relevant to the user query.253 Google could also allocate bids across auctions in a way that raises prices for other advertisers, taking advantage of the second-price auction format.254 These mechanisms may allow it to better extract economic rents from advertisers. ## Leveraging Of Market Power Into Other Markets 5.88 Finally, it appears that Google may be able to exploit its market power in general search by leveraging it into other related services. This includes specialised search. Google has launched downstream specialised search services, such as Google Shopping and Google Flights. Search advertising is a key source of traffic for downstream 'specialised search' markets, such as price comparison sites or online travel agents. Google has the potential to exploit this through self-preferencing in how specialised search is presented alongside general search results or through diverting search engine traffic away from rivals. We note that the European Commission found Google to have abused its dominant position in general search, through selfpreferencing of Google Shopping. One online travel comparison site raised concerns in response to our statement of scope about how changes to Google's search algorithm have reduced its visibility in organic search results. 5.89 Google may also be able to leverage its market power in search into the open display market. Smaller advertisers often choose to single-home to minimise transaction costs. Advertisers that wish to single-home have a strong incentive to use Google Ads as they can use it to access Google search advertising and YouTube inventory as well as the open display market. This is discussed in more detail later in the chapter. ## Evidence Of Exploitation Of Market Power 5.90 As Google has held its very high market share in search advertising in the UK for at least the last decade, there is no recent direct evidence of the impact of Google's market power on market outcomes relative to the counterfactual of a more competitive market. That said, our analysis of Google's profitability is consistent with exploitation of market power. Google's global returns on capital in search are likely to be well over 40%, well above its cost of capital.255 We also note that some advertisers have suggested that prices on Google have risen over time (especially in relation to branded terms). Others have told us that the monetisation of Google's search results has increased over time as a greater volume of advertising is shown at the expense of organic search, particularly for searches on mobile devices. 5.91 The lack of transparency around Google's auction processes makes it very difficult for market participants to observe whether Google is exploiting market power in the ways indicated above. This makes it more difficult for them to respond to Google's behaviour. Several advertisers have raised concerns about the transparency of Google's search advertising auctions. Some advertisers have also expressed the concern that prices to advertise on their own brand names have risen substantially but that there is no transparency as to why this is the case. Others have suggested that Google may have incentives to penalise rivals that it competes with elsewhere, for example in specialised search, or publishers that it competes with in the sale of display advertising. ## Initial Findings On Search Advertising 5.92 The evidence we have reviewed so far suggests that Google has substantial market power in search advertising. 5.93 Google has had very high and stable shares of supply in search advertising in the UK of over 90% for at least the last ten years. 5.94 The evidence we have reviewed so far does not suggest that many specialised search providers impose a strong competitive constraint on Google, even in the sectors within which they specialise. One notable possible exception to this is retail, where the evidence that Google competes directly with Amazon is more compelling. However, even if Amazon imposes some competitive constraint on Google, this would only apply to a minority of Google's revenues in search. 5.95 Search advertising is subject to significant barriers to entry that limit the actual or potential competitive constraint faced by Google. Barriers to entry on the consumer side of the market, derived from the need to create a search index, from economies of scale and scope in click-and-query data and from defaults as described in Chapter 3, also apply to potential entrants wanting to supply search advertising. 5.96 In addition to these advantages from the consumer side of the market, Google appears to derive additional advantages on the advertising side of the market which create further barriers to entry. These advantages come from singlehoming by (particularly smaller) advertisers, Google's better first-party data for targeting and attribution, better synchronisation with Google Analytics and Google's ability to influence advertiser behaviour through its ownership of the search intermediation tool SA360. 5.97 The market power of Google's search engine could allow it to exploit market power both by designing its auctions to more effectively extract economic rents from advertisers, driving higher advertising prices, and by selling more advertising at the expense of organic search results. Higher advertising costs are likely to be passed on to advertisers' final customers through the impact these costs have on competition in the downstream markets where advertisers compete. 5.98 We think that any interventions to remedy this situation would need to focus primarily on addressing the sources of Google's market power on the consumer side of the market, but there is also a case for intervention in relation to features of the advertising market that reinforce Google's market power. We consider the potential interventions in the next chapter. ## Competition In Display Advertising 5.99 This section sets out our initial findings on competition in display advertising. We consider competition between suppliers of display advertising at a high level, including between owned and operated platforms and publishers who sell via the open display market. Issues specific to the open display advertising sector are covered in the following section. 5.100 This section covers: - our understanding of the competitive process, including how advertising is sold, how advertisers choose between suppliers of display advertising and how suppliers compete; - evidence on market outcomes in display advertising, including market shares, prices and trends over time; - closeness of competition between platforms in display advertising; - transparency of advertising outcomes; - barriers to entry and expansion; and - how market power may be exploited. ## Competitive Process How Display Advertising Is Sold 5.101 At a high level, the display advertising sector can be segmented into two channels: owned and operated platforms and the open display market. Owned and operated platforms typically provide social media, which they use to attract consumer attention and create advertising inventory, which they sell to advertisers using proprietary interfaces. They gather data on these consumers to enable advertisers to target specific audiences. 5.102 In the open display market, many publishers of smaller scale (for example, suppliers of news media and app providers) also attract consumer attention through providing content. However, they sell advertising inventory in an open market in competition with other publishers using a complex chain of intermediaries, who often run real-time auctions and typically supply the data used for audience targeting. The open display market is described in more detail later in the chapter. 5.103 In both these channels advertising is either sold using technology to allocate inventory using real-time auctions, or through direct deals. Direct deals can either be hosted using the same programmatic advertising technology used to run auctions or alternatively can be organised directly between the advertiser and publisher. Stakeholders have told us that the vast majority of display advertising inventory is now sold using programmatic technology. 5.104 Many of the auctions used in programmatic advertising are pure price-based auctions, where inventory is sold to the highest bidder. Some social media platforms, including Facebook, will also adjust the ranking of bids according to relevance. ## Demand For Display Advertising 5.105 Advertiser choice in display advertising is primarily driven by the objective of targeting increased brand awareness for specific audiences. KPIs for display advertising tend to be focused on the reach achieved with a specific audience group. This means that the use of data to identify target audiences is key for display advertising. 5.106 Media agencies and advertisers have told us that advertisers are generally agnostic in their choice across different platforms that sell display advertising and between using owned and operated platforms and the open display market. Rather, decisions are made primarily based on effectiveness of meeting KPIs against cost. However, we understand that some smaller advertisers that do not use media agencies may prefer to rely solely on Google or Facebook's ad buying platforms. ## How Suppliers Of Display Advertising Compete For Advertisers 5.107 Compared to search advertising, in which advertising is shown when relevant to a specific search query, in display advertising user data plays a much more significant role in providing the ability for advertisers to target specific audiences. Consequently, access to valuable user data that enables more granular audience targeting is a key dimension of competition. In addition, suppliers can compete directly for advertisers through the quality of the advertising interface and associated technology. 5.108 Suppliers of display advertising also have flexibility in the extent to which they monetise consumer attention through the creation of advertising inventory. They have direct control over the quantity of advertising shown or 'ad load'. Suppliers of display advertising face a trade-off in deciding on how much inventory to create. A higher 'ad load' may mean greater immediate financial reward. However, this can come at the expense of the consumer experience to some extent. Unlike search advertising, which is shown in response to specific consumer queries, display advertising is typically unwanted by consumers. This suggests there may be a greater imperative for publishers of display advertising to limit the quantity of advertising shown so as not to harm the consumer experience. ## Market Outcomes In Display Advertising 5.109 In addition to the market outcomes on the consumer side in social media described in Chapter 3, we have looked at evidence on various market outcomes in display advertising. This evidence and the supporting data are set out in more detail in Appendix C on market outcomes. 5.110 The fragmented nature of the open display market and the fact that advertising is sold via intermediaries makes the estimation of overall expenditure shares in display advertising difficult. Our preliminary estimates, shown in Figure 5.5, suggest that Facebook (including Instagram) is by far the largest supplier, with a share of [40-50%] of advertising expenditure. Facebook has considerably greater scale than the second largest supplier, YouTube, which has [5-10%] of advertising expenditure. In our view this evidence suggests that Facebook is likely to have market power. Source: CMA analysis based on parties' data. Note: Segments shown in the chart are illustrative, based on mid-points of the stated ranges rather than actual revenue figures. 5.111 As noted above, it seems likely that a segmentation between video and nonvideo formats is appropriate given that many advertisers would have limited ability to substitute between the two. As shown in Figures 5.6 and 5.7 below, Facebook (including Instagram) has a [50%-60%] share of video advertising (£[1-1.1] billion revenues in 2018) and a [40%-50%] share of non-video advertising (£[1.3-1.6] billion revenues in 2018). YouTube is the second largest supplier in video display advertising with a [15%-20%] share of expenditure. We estimate that the open display market accounts for around [20%-25%] of video and [45%-50%] of non-video display advertising. Our analysis also shows that there has been a significant move over the last three years towards video advertising, which is taking an increasing share of overall expenditure. Source: CMA analysis based on parties' data. Note: Segments shown in the chart are illustrative, based on mid-points of the stated ranges rather than actual revenue figures. Source: CMA analysis based on parties' data. Note: Segments shown in the chart are illustrative, based on mid-points of the stated ranges rather than actual revenue figures. 5.112 We have also looked at trends in average advertising prices, as measured by cost per thousand advertising impressions (CPM) for the larger owned and operated platforms, including Facebook, YouTube, Instagram and another social media platform. This is shown in Figure 5.8 below. It shows that prices for Facebook's core platform have been increasing over the last three years and are significantly higher on average than other platforms. However, we interpret this analysis with some caution as relative price differences can be driven by composition effects (for example between mobile versus desktop and video versus non-video) similarly to search advertising. We intend to look at this further in the second half of our study. ## Closeness Of Competition Between Platforms In Display Advertising 5.113 Most advertisers told us that they used a range of platforms to buy display advertising and that different platforms had different relative advantages in achieving advertising KPIs. The platforms most commonly mentioned and ranked highest were Facebook, Google DV360 (Google's demand side platform for purchasing advertising in open display) and Twitter. Several advertisers mentioned YouTube and the Video-on-Demand offerings of ITV, Channel 4 and Sky, and a few mentioned Amazon, Snapchat, Pinterest and other demand side platforms for purchasing advertising in open display. 5.114 Advertisers and media agencies were consistent in what they saw as the relative advantages and disadvantages of different platforms. Facebook and Google (DV360 and YouTube) were consistently identified as benefiting from greater reach and ability to target specific audiences, allowing advertisers to generate greater return on investment from using these platforms. Advertisers also highlighted various disadvantages of these platforms from a lack of transparency: in the case of Facebook relating to viewability, measurement of advertising outcomes and brand safety, and in the case of Google relating to transparency over its auctions and concerns about fraud and brand safety. 5.115 Advertisers submitted that some rival platforms had idiosyncratic relative advantages. Twitter was highlighted by several advertisers as being especially effective for direct customer engagement and reactive advertising. Snapchat was highlighted for the flexibility of its creative assets and Amazon for its first-party data and for its proximity to the point of sale. 5.116 Rivals similarly saw Google and Facebook as the strongest competitors in display advertising. All of the display advertising rivals we contacted identified Facebook as a competitor and most of these platforms specified that Facebook was one of their top two competitors. These businesses also identified Google as a major competitor, some referring to its ownership of YouTube, and some also referring to its search advertising or its total scale across digital advertising as a whole. 5.117 While all of the platforms identified Facebook and Google as their closest competitors, this does not imply that they impose a significant competitive constraint on Google and Facebook. For example, LinkedIn noted that competition was asymmetric as while Facebook and Google compete with LinkedIn for most of its advertising revenue, LinkedIn only competes for a small subset of Facebook and Google's advertising revenue. Google and Facebook also identified each other as key competitors for advertising, but also a wider set of competitors including TV advertisers, Video on Demand and Amazon. 5.118 Facebook suggested its strength was in making the advertising experience as easy as possible for advertisers to use so that even small advertisers can use it. 5.119 Google's internal documents comprehensively cover its competitors and show that Google does not focus solely on one part of digital advertising supply chain. For example, Google pays particular attention to Facebook and Amazon. Google submitted several reports monitoring Facebook and some documents benchmarking YouTube's ads against Facebook. Amazon was often identified as having growth potential in advertising. 5.120 Facebook's internal documents cover a range of rivals. All the rivals are differentiated from Facebook, but they all compete for consumer attention, advertising, or both. The competitors which are monitored most frequently are Google, YouTube, Pinterest, Twitter and Snapchat. Other rivals Facebook monitors include Amazon, traditional TV and smaller platforms, who are monitored less frequently. 5.121 Overall, the views of advertisers, media agencies and suppliers support that Facebook has market power in display advertising. However, they also suggest that Google is likely to be Facebook's closest competitor. Both Google and Facebook benefit from greater scale and access to user data than their rivals. Both platforms face a degree of competition from a range of sources. While Google's and Facebook's internal documents suggest that they are likely to be each other's closest competitors, a number of other competitors are also mentioned. ## Transparency Of Advertising Outcomes 5.122 To make informed choices that can drive competition, advertisers need to be able to measure advertising outcomes to assess effectiveness and verify quality, accounting for factors such as viewability, brand safety and ad fraud. Access to the necessary underlying data on advertising outcomes in a form that facilitates these assessments is key. 5.123 Several advertisers and agencies commented on the lack of common definitions and standard industry metrics across different search and social media platforms. For instance, different definitions of audiences can mean that data from different platforms is not directly comparable. This makes it difficult to aggregate estimates of reach and frequency across multiple platforms. It can also make it difficult to manage frequency caps and retargeting and avoid duplication in the course of an advertising campaign. 5.124 Some advertisers raised concerns about restrictions on the third-party verification of advertising on inventory owned and operated by Google and Facebook. Responses indicated that although both Google and Facebook do work with a number of 'approved' third-party verification providers, they restrict access to detailed consumer level data in respect of verification for the advertising inventory they own and operate. Other display advertising platforms reported that they do allow advertisers to use tracking tags for thirdparty verification of impressions served on their advertising inventory. Without access to the underlying raw data and the ability to have full independent verification, there was a perception on the part of advertisers and agencies that Google and Facebook were able, in effect, to 'mark their own homework' in respect of the effectiveness of their own advertising inventory. 5.125 In their responses both Facebook and Google referred to the fact that the way in which they compile data - for instance, on the viewability of impressions on their inventory - meets industry standards and is subject to external audit. Google also argued that it had reviewed the way in which it worked with third parties ahead of the implementation of GDPR. As a result, it had restricted the number of third-party measurement providers that it was able to support on Google Search and YouTube and had stopped accepting other third-party tracking pixels post GDPR.256 5.126 Several advertisers have highlighted to us their previous experience of incidents in relation to the verification of viewability and brand safety in digital advertising. For instance, there have been issues with the misreporting of viewability on the Facebook platform257 and with brand safety on YouTube.258 5.127 We are also aware of concerns about the level of ad fraud in relation to digital advertising, with a number of large scale, systematic frauds being discovered.259 5.128 There are a wide range of estimates of the overall scale of fraud in relation to online advertising. However, a number of stakeholders referenced the most recent report by White Ops and the American Association of National Advertisers (ANA),260 which estimated that the global scale of losses from ad fraud would fall from $6.5bn in 2017 to $5.8 billion in 2019 despite estimates that digital ad spending had increased by just over 25% over the same time period. It found three main factors which contributed to this projected decline in ad fraud: - The use of ads.txt to help publishers create lists of authorized media sellers. 261 This had worked to reduce desktop spoofing to the lowest levels recorded in the history of the report. - It had become more expensive and less efficient to buy sophisticated bot traffic. Efforts by the Trustworthy Accountability Group (TAG) and their Certified Against Fraud program, coupled with groups working together to dismantle botnets, had drastically reduced both the supply and the demand for traffic from vendors that are caught selling bot traffic. - More digital advertising was being sold through platforms that had built-in fraud prevention measures. 5.129 Responses from advertisers and agencies also indicated that the level of ad fraud in the UK was estimated to be relatively low. For instance, a number of responses indicated that the scale of ad fraud was estimated to be less than 2% of impressions. 5.130 Respondents were also aware of the main industry initiatives by the IAB, JICWEBs and others aimed at addressing brand safety and fraud issues, and many respondents were also active members of those industry bodies. At the same time, some agencies also reported that such initiatives were not yet fully mature and so there was work still to be done. 5.131 As indicated above, a lack of transparency can undermine the functioning of a market. That is, if advertisers cannot be sure that the advertising inventory they are buying is authentic or that the agents they are trading with are legitimate, then that lack of transparency would undermine trust in an industry. Again, it is not clear that reputational incentives would prove sufficient to address this concern. 5.132 However, the responses to our information requests indicate that ad fraud is acknowledged as an industry-wide challenge and an issue that requires industry-wide solutions to address it. There is also a perception that ad fraud is more of a risk in relation to the open display market because of a long tail of smaller publisher sites. 5.133 Large platforms - such as Google and Facebook - do appear to be engaging with industry initiatives to combat ad fraud eg in terms of seeking industry accreditation for their fraud prevention processes and systems. 5.134 However, aside from engaging with measures to tackle ad fraud directly, there remain concerns that the large platforms could do more to improve transparency for advertisers and intermediaries. By restricting full independent verification of their own inventory, Facebook and Google have engineered a degree of opacity into the buying and selling of their own advertising inventory. Advertisers have to rely on the information provided by Google and Facebook. This could weaken competition or potentially result in advertisers over-paying for the advertising inventory supplied by Google and Facebook relative to other sources of supply. 5.135 In a similar vein, some advertisers expressed the concern that they have to rely on the information on fraudulent impressions provided by platforms. That is, they were not told why impressions were considered to be fraudulent and were not in a position to validate any adjustment or refunds implemented by the platforms. This suggests that there could be scope for greater transparency in relation to the reporting of ad fraud. However, it is not clear to us at this stage how much appetite there is in the industry for this: we are aware that if platforms reveal too much about how ad fraud is detected, that could actually assist those parties seeking to perpetrate ad fraud. We would welcome further views on this. ## Barriers To Entry And Expansion 5.136 Suppliers have identified several barriers that need to be overcome for a provider to be able to effectively compete in display advertising. The barriers to entry and expansion identified fall into the following categories: - economies of scale; - network effects in accessing consumer attention; - accessing user data; and - incumbency advantages. ## Economies Of Scale 5.137 There are several inputs required to support a display advertising platform. In particular, investments need to be made in technology, such as developing a website/app and back-end functionality to support the platform and technical equipment (eg servers); facilities, such as offices; and equipment and marketing, such as launch and brand awareness campaigns. The investments and fixed costs required to develop and maintain these inputs are likely to give rise to economies of scale. Economies of scale create a cost advantage for larger rivals over smaller potential entrants, giving rise to barriers to entry. 5.138 Facebook submitted that no minimum scale is required for entrants to compete effectively. Facebook submitted that its income statements indicate that while it experienced some economies of scale in its early years, its costs have grown at a faster rate than its user base over the last decade (from 2009-2018). This suggests that, in aggregate, any economies of scale which Facebook has benefited from appear to have been largely exhausted in its early years of development. 5.139 However, in our view, this evidence does not suggest that no minimum scale is required, for several reasons. The two-sided nature of Facebook's platform and the associated dynamics this implies suggest that, in considering the extent to which it benefits from economies of scale, it may not be appropriate to simply focus on how Facebook's user numbers and costs change from year to year. 5.140 While user growth on Facebook has decelerated significantly, its advertising revenues per user have continued to grow substantially (albeit at a somewhat decreasing rate) as it has further monetised its platform to benefit from historic investments on the consumer side. We also note that Facebook's current costs may partly reflect investments it is currently making to further enhance the consumer experience and enter new markets in the future. Facebook submits that it did generate economies of scale in its earlier stages, which is most relevant for assessing the prospects of a potential entrant. Further, other platforms told us that significant scale is needed for an entrant to be viable in the long term. ## Access To Consumer Attention 5.141 The need for suppliers of display advertising to first grow their user base in order to gain access to consumer attention and data mean that the most important barriers to entry are faced on the consumer side of the market. Several suppliers of display advertising told us that the way to enter display advertising was to first offer a compelling platform which captures consumer attention. Therefore, generating an innovative or engaging product or service for consumers is the first barrier that needs to be overcome. To maintain the attention of consumers, platforms then need to offer improvements to their consumer product position or to offer personalised relevant content. As described in Chapter 3, the consumer services relevant for supporting digital advertising, such as social media, are typically characterised by strong network effects. These network effects result in very high barriers to entry that also restrict competition in display advertising. ## Access To Consumer Data 5.142 The academic literature as well as the evidence we have collected to date show that consumer data has a significant value to advertisers in that it allows them to better target audiences. Access to higher quality or more granular data allows for more precise targeting of more specific audiences. Granular data is particularly valuable when combined with high reach among different audience types using the platform, as this allows for relatively large numbers of very specific audiences to be targeted. These factors can allow platforms with better data to sell their advertising inventory at higher prices. This creates a substantial competitive advantage for Google and Facebook, both of which have access to much richer and higher quality datasets and benefit from much greater scale and reach than their rivals. 5.143 This view was largely confirmed by advertisers and media agencies. Several told us that Google and Facebook offer more granular personalised targeting compared to other platforms. Google offers in-depth targeting options, driven by its unique and vast sources of data. Facebook has the advantage of offering the ability to target specific audiences based on demographic characteristics, interests and location. Some advertisers also singled out Facebook's remarketing capability. Facebook's scale allows it to reach a large proportion of advertisers' known customers, using the advertiser's first-party data. 5.144 The ability to show effectiveness of advertising is another important driver of advertisers' decisions on how to allocate their advertising expenditure across publishers and platforms. Google and Facebook tags are widely available on advertiser websites. This enables a more sophisticated analysis of attribution because they are more easily able to track a consumer's journey across the internet and provide a single source for the data. A number of responses indicated that Google and Facebook had a competitive advantage in respect of their access to consumer data and an ability to track consumers' behaviour across different websites and measure attribution across their own inventory more accurately. 5.145 The use of data both for better targeting of relevant audiences and in measuring performance is of direct benefit to advertisers. However, the inability for smaller platforms and publishers to access equivalent user data to Google and Facebook may raise barriers to entry, as it reduces the ability for these rivals to compete on a level playing field and realise the full value of their advertising inventory. 5.146 Suppliers of display advertising told us that consumer data was a key input required to target audiences. The more data and the higher the quality of the data a platform holds the better equipped it is to provide advertisers with exactly what they want. The majority of these platforms offer free analytics tools and metrics to advertisers to create and tailor content and to analyse campaign effectiveness of ads. 5.147 However, rival platforms did not suggest that accessing consumer data was an insurmountable barrier to entry. Some submitted that monitoring consumers on their platform provides enough data to compete effectively, where sufficient activity can be tracked across different consumers. Generating scale on the consumer side of the platform is particularly important because effective analysis of this data is heavily dependent on gaining enough scale in user-generated content. 5.148 Based on the above, it appears that the ability to access consumer data is likely to be closely tied to competition for consumer attention. This adds to the importance of barriers to entry from network effects in the consumer services relevant for supporting digital advertising. ## Incumbency Advantages 5.149 As discussed in Chapter 3, there have been several recent examples of entry by display advertising platforms. However, with the possible exception of Instagram, we note that these platforms are yet to reach a very significant scale in the supply of display advertising. This raises the question of whether these platforms may face barriers to expanding to a scale sufficient to impose a material competitive constraint on Facebook. 5.150 Barriers to expansion may arise from the need to compete aggressively for consumers to build scale and benefit from consumer side network effects before monetising the platform. Current rivals to Facebook are likely to be limited in their ability to monetise through digital advertising, as this may hamper their ability to compete effectively on the consumer side. This dynamic is supported by Facebook's earlier experience of competing with Myspace. As noted in Chapter 3, Facebook has submitted that its early success in competing with Myspace was due to Myspace's focus on maximising advertising revenue, to the detriment of the consumer experience. By contrast, Facebook reached a much larger scale of users and consequently benefited to a greater extent from consumer-side network effects before it started to monetise through display advertising. ## Exploitation Of Market Power 5.151 Our view at this stage is that the dynamics in the display advertising market create the incentive for Facebook to exploit its market power on the consumer side of the platform - by extracting large amounts of data from consumers. This exploitation by Facebook of consumers is then rewarded in the digital advertising market through higher prices paid for its advertising inventory. 5.152 Facebook's large scale may be sufficient to create an incentive for it to exploit market power through limiting the overall quantity of advertising inventory it supplies, thus increasing overall market prices relative to a more competitive market.262 We note that the need to maintain a high-quality consumer experience already creates an incentive for Facebook to limit its quantity of advertising inventory to some extent. However, market power may create the incentive to restrict the quantity of advertising further than would be the case in a more competitive market. Similar to search, higher advertising costs are likely to be passed on to advertisers' final customers through the impact these costs have on competition in the downstream markets where advertisers compete. 5.153 Facebook's auctions in display advertising are second-price auctions that include adjusting bids for quality. These adjustments can be a benefit to both consumers and advertisers as they reduce the extent to which advertising is shown to consumers that do not want to see it. In a similar way to Google in search, Facebook could influence the prices that advertisers pay through how it adjusts bids for quality, allowing it to extract more economic rent from advertisers.263 5.154 In principle, Facebook could also extract rents from advertisers by raising its reserve prices. However, []. 5.155 Similar to Google in search, our analysis of Facebook's profitability is consistent with exploitation of market power. It shows that Facebook's global returns on capital are also likely to be over 40%, well above its cost of capital.264 ## Initial Findings On Display Advertising 5.156 The evidence we have reviewed so far suggests that Facebook has market power in display advertising. Our current estimates suggest that Facebook (including Instagram) is by far the largest supplier of display advertising, accounting for [40-50%] of advertising expenditure. Facebook has considerably greater scale than the second largest supplier, YouTube, which has [5-10%] of advertising expenditure. 5.157 Display advertising is subject to significant barriers to entry that limit the actual or potential competitive constraint faced by Facebook. The need for suppliers of display advertising to first grow their user base in order to gain access to consumer attention and data mean that the most important barriers to entry are faced on the consumer side of the market. As mentioned in Chapter 3, potential entrants face barriers to entry from network effects. 5.158 There have been several recent examples of entry by platforms offering display advertising. However, these platforms are likely to be limited in their ability to monetise through digital advertising, as this may hamper their ability to compete effectively on the consumer side. Their smaller scale means that they are likely to have stronger incentives than Facebook to further increase their scale of users and benefit from network effects. This may create a barrier to them expanding their supply of digital advertising to a scale large enough to impose a material competitive constraint on Facebook. 5.159 The inability for smaller platforms and publishers to access equivalent user data to Facebook may also create barriers to entry and expansion, as it reduces the ability for these rivals to compete on a level playing field and realise the full value of their advertising inventory through targeted advertising and provision of attribution and measurement services. 5.160 Our view at this stage is that Facebook has an incentive to exploit its market power on the consumer side of the platform - by extracting large amounts of data from consumers. This exploitation by Facebook of consumers would be then rewarded in the digital advertising market through higher prices paid for its advertising inventory. 5.161 Facebook's large scale may also create an incentive for it to exploit market power through increasing overall market prices to advertisers relative to a more competitive market. 5.162 In light of these findings, our initial view is that there is a case for intervention to address the source of Facebook's power on the consumer side of the market (notably resulting from network effects) and to limit its ability to exploit consumers through excessive extraction of data. There may also be a case for intervention in relation to features of the advertising market that reinforce Facebook's market power. The range of potential interventions on these issues are discussed in the next chapter. ## The Open Display Market 5.163 This section sets out our initial views on issues in the open display market. It sets out: - a summary of how digital advertising intermediation works and the main players in the intermediation chain; - our preliminary analysis of competition at different levels of the intermediation chain; - concerns that a lack of transparency in the intermediation chain might lead to worse outcomes for advertisers and publishers; - vertical integration and concerns about whether it can lead to conflicts of interest and whether the platforms (notably Google) can leverage their market power from 'owned and operated' advertising into ad tech; and - possible implications of privacy concerns and the data protection legal framework for the open display market. 5.164 A detailed explanation of how this part of the market functions can be found in Appendix H. ## How Digital Advertising Intermediation Works 5.165 Digital advertising intermediation is a highly complex industry.265 This section provides a high-level summary of its working. The following description reflects our current understanding, based on extensive engagement and discussions with industry participants. We welcome scrutiny of and feedback on it. 5.166 Many publishers of online content monetise the services they provide, at least in part, through digital advertising. Some of their advertising space (or inventory) is sold through direct deals between the publisher and specific advertisers or media agencies. However, most digital advertising (80% in 2017 according to the IAB) is now sold 'programmatically'. 266 The defining feature of programmatic buying is that the decision on whether to buy a particular impression is made in real time, making use of information not only about the environment (eg webpage) in which the ad will appear, but also about the internet user in front of whom the ad will be placed. 5.167 In order to make programmatic trading possible, a complex ecosystem has emerged, including a range of intermediaries between advertisers and publishers - the so called 'ad tech stack'. A simplified version of the intermediation chain is provided in Figure 5.9 below. Source: CMA. ## 5.168 On The Demand Side, The Main Participants In The Ecosystem Include: - Advertisers - interested in serving ads to consumers, their aim can be increasing consumers' awareness of their brands or inducing a direct response (eg a purchase) from consumers seeing the ad. Advertisers' aims affect their preferences over which consumers to target with the advertising campaign.267 - Media agencies - often used by large advertisers to plan and deliver an advertising campaign. Media agencies can offer in-house trading desks, which provide the technical expertise to execute programmatic media buying. Media agencies and their trading desks charge advertisers a percentage of their media spend or in proportion to amount of work performed. - Demand-side platforms (DSPs) - provide a platform that allows advertisers and media agencies to buy advertising inventory from many sources. DSPs bid on impressions based on the buyer's objectives and on data about the consumers. DSPs usually charge advertisers a percentage of their media spend. ## 5.169 On The Supply Side, The Main Participants Include: - Publishers - operate websites or apps and want to monetise their services selling digital advertising. - Supply-side platforms (SSPs) - provide the technology to automate the sale of digital inventory. They allow real-time auctions by connecting to multiple DSPs, collecting bids from them and performing the function of exchanges.268 They can also facilitate more direct deals between publishers and advertisers. SSPs are typically remunerated through a revenue share agreement with publishers. - Publisher ad servers - manage the publisher's inventory and are responsible for the decision logic underlying the final choice of which ad to serve, based on the bids received from different SSPs and the direct deals agreed between the publisher and advertisers. Publisher ad servers typically charge publishers a fee based on the volume of advertising processed. 5.170 The advertising ecosystem also includes further participants involved in the provision and management of data and in advertising analytics: - Data suppliers - A wide range of companies provide data that can be used to augment the user data already possessed by advertisers and publishers and enhance the ability to target advertising to specific types of audiences. - Data management platforms (DMPs) - allow other participants along the value chain (advertisers, DSPs, SSPs and publishers) to manage and analyse their data, integrate it with third-party data, and use it to create audiences that can be used for targeting purposes. - Advertising analytics - services used by advertisers to measure the performance and impact of advertising campaigns. 5.171 In a typical real-time transaction, when a consumer opens a webpage (or navigates through an app), an automated process is put in motion through which - Multiple SSPs receive ad requests for the advertising space available on the web page. In turn, SSPs send bid requests to multiple DSPs. - DSPs evaluate the advertising opportunity based on the objectives of the campaigns of all their customers (advertisers and media agencies) and automatically generate bids to be sent to SSPs. - SSPs then rank the bids received based on price and on priority levels that may have been set by the publisher, and send the winning bid to the publisher. - Finally, the publisher ad server compares the bids received, together with any pre-existing direct deals between the publisher and specific advertisers, and decides which ad is to be served on the webpage. 5.172 SSPs can submit their bids into the publisher ad server in several different ways. - SSPs can be ranked by a publisher according to their expected bids and be called by the publisher ad server sequentially, with the next SSP being asked for a bid only if the previous one had not bought the impression (sometimes known as the 'waterfall'). If an SSP is vertically integrated with the publisher ad server, it may have the possibility to submit its bid first, using the highest expected bid from the other SSPs as a floor price. - SSPs can be called and submit their bids simultaneously, before the publisher ad server is called, if the publisher uses a 'header bidding' solution.269 Header bidding began to be widely adopted in 2015 as a mechanism to increase competition between SSPs and generate higher revenues for publishers. - A publisher ad server can provide an alternative mechanism to allow SSPs to submit bids simultaneously. Google Ad Manager, the most widely used publisher ad server, has offered such a service, initially called Exchange Bidding and recently renamed as Open Bidding, since 2018. ## Competition In Digital Advertising Intermediation 5.173 The following paragraphs provide an overview of competition among DSPs, SSPs and publisher ad servers and include our initial estimated shares of supply of some of the main providers. We also briefly discuss vertical integration along the intermediation chain and the efficiencies it can generate. 5.174 Our main findings can be summarised as follows: - In recent years, the industry has been consolidating, with supply increasingly concentrated in a small number of large providers at each level of the value chain. - Concentration is particularly high at the publisher ad server level, where, based on submissions from industry stakeholders, we believe Google is likely to have a share of supply above 90%. - There appears to be more competition at DSP and SSP level, although Google has significant shares in these markets as well (50-70% of the value of ads purchased through DSP, 40-60% of the value of ads sold through SSPs).270 - There has been a growing trend towards vertical integration, driven party by efficiency reasons and partly by pressures resulting from privacy concerns and recent changes in data regulation (eg the implementation of the GDPR). Vertical integration may also have anti-competitive motivations, as discussed in a subsequent section. ## Dsps 5.175 There are many DSPs operating in the UK. Some of the largest include Google's DV360 and Google Ads, The Trade Desk, Xandr DSP, Amazon DSP and Criteo. 5.176 Advertisers and media agencies told us they decide what DSPs to use mostly based on two types of consideration: - the advantages derived from a DSP's access to exclusive inventory, use of exclusive data, or integration with other services offered by the same provider; and - the technical sophistication, customisation and level of support of the DSP services themselves. 5.177 Based on advertisers' submissions, the strength of some DSPs, such as Google's DV360 and Amazon DSP, appears to be mainly based on access to data and inventory, while other DSPs, such as Xandr and The Trade Desk, are considered relatively stronger on technology and service. 5.178 While larger advertisers and media agencies often use multiple DSPs across advertising campaigns, typically a single DSP is used for a given campaign, as this allows to manage frequency caps over the entire campaign and facilitates audience management and reporting. ## Ssps 5.179 SSPs can be broadly divided into two groups: generalist SSPs, such as Google AdX (part of Google Ad Manager), Index Exchange, OpenX, PubMatic, Rubicon Project and Xandr SSP; and specialist providers, such as TripleLift, Sharethrough and Teads, which specialise in particular ad formats such as native display or video. 5.180 SSPs need to attract both sellers (publishers) and buyers (DSPs, and ultimately advertisers) to their platform. They operate in a two-sided market which exhibits indirect network effects: on the one hand, advertisers are more willing to work with platforms that have higher access to supply, in order to achieve their goals at scale; on the other hand, companies which are able to work with many advertisers (or DSPs) can provide publishers with greater demand, which is one of the main factors publishers look at when deciding which SSPs to work with. The strength of network effects, however, may be limited by the fact that both DSPs and publishers tend to work with multiple SSPs. ## Publisher Ad Servers 5.181 The market for publisher ad serving appears to be very concentrated. Based on submissions from industry stakeholders, we estimate that Google Ad Manager may account for more than 90% of all the display ads served in the UK. Several publishers described Google Ad Manager as the global market leader and superior to other ad servers. Other providers include Xandr and Smart, but their presence as publisher ad servers in the UK market appears to be marginal. 5.182 Publishers typically single-home on one ad server, although it is possible to have a secondary ad server in addition to the main one. This appears to be the solution adopted by some publishers whose primary ad server is not Google Ad Manager in order to have access to Google's demand. 5.183 Publishers generally told us that switching ad server is a complex and lengthy process which takes several months to complete and involves significant risks of revenue loss. We consider this issue in more detail later in the chapter. ## Vertical Integration And Efficiencies 5.184 Several operators in the advertising intermediation ecosystem provide more than one service along the value chain. One industry participant told us that vertical integration has become the preferred method for rapid growth in the advertising industry. The largest companies are either acquiring smaller companies along the supply chain or building extensions of their own platform stack into new parts of the supply chain. Recent examples include FreeWheel's expansion from ad serving into SSP through the acquisition of StickyAds in 2016; Adobe's expansion into the DSP market through the acquisition of TubeMogul in 2017; and Amazon's launch of a header bidding solution in 2018. 5.185 The case of Google is noteworthy because not only does it operate along the entire value chain, but it also has the largest shares of supply among providers at each level of the chain. Source: CMA. Note: We include Google AdX, Google Ad Sense and Google AdMob in our definition of SSPs and Google DV360 and Google Ads in our definition of DSPs. Share estimates at SSP/Exchange and DSP levels have been computed based on data from the intermediaries we received information from. As our coverage is not complete, Google shares may be over-estimated. 5.186 Google's presence across the ad tech chain was initially driven by a series of acquisitions, as set out in Box 5.1. While Google's suite of products has developed significantly over time, it is notable that Google integrated a number of existing products rather than developing its position organically. ## Box 5.1: Google'S Acquisitions In Ad Tech We have been told that Google's most significant acquisitions in ad tech include: - DoubleClick (April 2007) - Publisher ad server and ad exchange; formed the basis of Google's ad server and AdX (now Google Ad Manager). - AdMob (November 2009) - Technology for serving ads on apps; formed the basis of Google's AdMob product. - Invite Media (June 2010) - Media buying optimization technology for the display advertising market; evolved into Google's main DSP product, Google DV360. - AdMeld (June 2011) - Supply Side Platform; integrated into Google AdX. - Adometry (May 2014) - Analytics and attribution provider; integrated into Google Analytics to provide improved attribution services. Google has also made more recent acquisitions in the ad tech space, including mDialog, Directr, Toro and Famebit. 5.187 Vertical integration, especially between DSPs and SSPs, can give rise to technical efficiencies. The main ones relate to cookie matching and latency. - DSPs and SSPs associate each consumer with a cookie ID. As cookie IDs are specific to each company, if the DSP and SSP are operated by different companies a process of cookie matching is required in order for the DSP to identify the relevant consumer information to associate to a given impression. This process is prone to failure and, according to one ad intermediation provider, can result in approximately 30% failed matching. This inefficiency is avoided when the same company operates both the DSP and the SSP. - After an SSP sends bid requests, DSPs have a time limit to submit their bids. Latency can therefore result in a bid being received too late and therefore being excluded from the SSP's auction. If the same company operates both the SSP and the DSP, it can locate them close by, reducing the time needed for information to travel between the two. 5.188 Despite the efficiency benefits, vertical integration could raise concerns if it led to conflicts of interest or to risks of anti-competitive foreclosure. We consider these issues later in the chapter. ## Lack Of Transparency In The Intermediation Chain 5.189 Many stakeholders that we spoke to, both on the advertiser and publisher sides of the market, commented on the lack of transparency in the digital advertising sector. This is partly a function of the technical characteristics of programmatic advertising where advertising is displayed in real time to a given consumer, making it difficult to verify exactly when an advert has been seen and by whom. The lack of transparency is exacerbated in the open display market, where publishers and advertisers rely on intermediaries to manage the process of real-time bidding and ad serving but cannot observe directly what the intermediaries are doing or, in some cases, how much they are being charged at different points in the supply chain. 5.190 One symptom of this lack of transparency is the significant degree of uncertainty around the average ratio between the amount that publishers receive for their inventory and the amount that advertisers pay, as discussed in Chapter 2 and in Appendix C on market outcomes. 5.191 Lack of transparency and asymmetric information can lead to inefficient outcomes - for example, advertisers may be reluctant to purchase advertising if they are unsure whether it will ultimately be viewed by a consumer. However, in some cases we would expect market participants to have a shared interest in trying to overcome the problem - for example, by investing in technology to improve ad verification. Therefore, we have focused on assessing whether there might be situations where the interests of different market participants are not well aligned and where a lack of transparency might be exploited by platforms with market power. We currently consider that the main concerns relate to the transparency of fees paid to different intermediaries and the opportunity for 'arbitrage'. 5.192 Market participants typically do not have visibility of the fees charged along the entire supply chain and are concerned that this limits their ability to make optimal choices on how to buy or to sell inventory, reducing competition among intermediaries. In particular: - Publishers have complained about lack of visibility of fees to intermediaries used by advertisers (DSPs, DMPs etc), reducing their ability to negotiate directly with advertisers. This may limit the competitive pressure faced by DSPs. - Some advertisers and agencies have expressed a concern about not being able to observe the fees that SSPs charge to publishers. Given that publishers decide which ad should be served based on net bids, visibility of these fees could make it easier for buyers to select the cheapest path to secure specific inventory and for DSPs to decide where to bid. This may limit the extent of competition between SSPs. 5.193 In the context of an intermediation process characterised by the presence of sequential auctions, lack of transparency may give rise to rent-seeking behaviour and arbitrage opportunities, ie the possibility for an intermediary (SSP or DSP) to buy impressions at one price and sell them at a higher one, without its customers being aware of this 'hidden fee'. 5.194 Some stakeholders have expressed the concern that some SSPs, after running an auction among DSPs, may charge the winning DSP the amount of its bid but submit a lower bid to the next stage, keeping the difference for themselves. While some SSPs have publicly announced that they are no longer adopting these practices, stakeholders believe that other SSPs may still do it. 5.195 A similar concern was expressed in relation to Google Ads. Google Ads, which in the open display market operates as a DSP, runs an internal secondprice auction among advertisers. While the winning bidder is charged by Google Ads an amount corresponding to the second-highest bid received by Google Ads, the amount that Google Ads bids into SSPs may be different, as Google Ads optimises the bid to achieve a high probability of winning the impression without overpaying for it. Some publishers have expressed their concern that the difference between what advertisers pay and what publishers receive from Google Ads may be substantial. This could be the case, for example, if Google Ads' internal auction were 'thicker' than the subsequent auction, or if advertisers using Google Ads had higher value for the inventory, owing to superior targeting capabilities allowed by the use of Google's data.271 Google has provided us an initial estimate of the difference. We will investigate this further in the second part of the study. 5.196 Google's high share of supply and market power as a publisher ad server may also allow it to increase arbitrage opportunities. Some publishers have expressed the concern that recent changes in how Google Ad Manager works reduce their ability to respond to what they perceive as the capture of significant rents by intermediaries. These publishers used to set higher floor prices for some DSPs in order to force them to submit higher bids and limit their ability to extract rents. However, Google Ad Manager has recently eliminated the possibility to set different floor prices for different sources of demand.272 5.197 These hidden fees would result in lower revenue for publishers, therefore reducing their incentives to invest in content, to the detriment of final consumers.273 The current structure of the market, along with the lack of transparency that exists, appears to create both the incentives and ability for some market participants to charge hidden fees. We will be exploring the extent to which these concerns occur in practice in the second half of our study, and we invite stakeholders to submit any evidence or views on this subject in response to our consultation. ## Vertical Integration, Conflicts Of Interest And Leveraging 5.198 Vertical integration can allow intermediaries to realise technical efficiencies to the benefit of advertisers and publishers. At the same time, vertical integration can also give rise to conflicts of interest and allow companies with market power at one stage of the value chain to leverage it in other parts of the industry, potentially foreclosing competing providers. 5.199 The core concern is that, where a firm controls intermediaries on both the 'buy' and 'sell' side of the market, it may act on behalf of the two counterparties to a commercial transaction, thus creating actual and/or perceived conflicts of interest. When operating on behalf of the publisher, such a firm might have an incentive to favour bids coming through its own advertiser-side intermediaries, rather than necessarily those that are best for the publisher. When operating on the buy-side, it might have an incentive to channel an advertiser's spend to its publisher clients, rather than to the publishers that are best for the advertiser. 5.200 Given the lack of transparency over fees and bids through the intermediation chain, there might be legitimate concerns about any operator having positions on both the buy and sell side of the market, whether or not that operator is in fact acting other than in its clients' best interests. Equity research company Arete suggested that programmatic advertising had similar characteristics to financial markets, because of the real-time nature of the bidding and complexity of the intermediation chain and products. We agree that there are analogies between the two and that there is a case for considering general rules on all market participants to mitigate potential conflicts of interest, similar to those that exist in financial markets. 5.201 However, the concerns about conflicts are greater where firms have market power at certain points in the intermediation chain, because publishers or advertisers will have less ability to switch away from intermediaries with market power, even if they have concerns about potential conflicts of interest. Moreover, vertical integration can enable players with market power at one point in the chain to leverage it into other points, making it harder for independent players at each stage to compete. 5.202 In particular, concerns have been raised that Google, which is present along the entire intermediation chain, may be able to leverage various sources of market power and exploit its position on both sides of the market. Based on our initial discussions with stakeholders, we have identified four main areas of potential concern about Google's behaviour: - using its market power in inventory and data to advantage its own DSP services (Google Ads and DV360); - channelling Google Ads demand through Google's SSP (AdX) and limiting the integration of AdX with rival publisher ad servers; - self-preferencing between Google's publisher ad server and AdX; and - self-preferencing between Google's DSP and SSP. 5.203 The following paragraphs first summarise Google's sources of market power which are relevant to the open display market, and then describe the various concerns in more detail, outlining the evidence we have received on whether these practices are taking place and on their potential effects. ## Google'S Sources Of Market Power 5.204 We concluded earlier in this chapter that Google has substantial market power in search advertising. In display advertising, while Google's owned and operated inventory is currently smaller than that controlled by Facebook, the value of advertising on its YouTube platform corresponds approximately to [10-25]% of the value of open display advertising in the UK; in video advertising, the value on YouTube is [60-80]% of that of the entire open market. Google also has exclusive access to a large amount of user data that can be used for targeted advertising and for measuring advertising outcomes, collected through its consumer-facing services and through its advertising analytics products. Moreover, the availability of log-in data allows Google to identify all the computers and mobile devices associated with a user, associating all the data about the user to a single user ID. 5.205 In addition, Google has a very high share of supply for publisher ad serving in the UK, likely in excess of 90%. The number of alternative providers has decreased recently with OpenX, Open Ad Stream, and Verizon Media deciding to stop providing a publisher ad server product. 5.206 Google's position in publisher ad serving is strengthened by the presence of substantial barriers to switching. Most publishers responding to our information requests submitted that switching to another ad server is a technically complex process because of how deeply integrated an ad server is into a publisher's systems. The process would be costly and take several months to complete. In addition to the direct costs of switching, there are operational risks and the possibility of demand losses resulting from the transition. For example, the time and effort that the publisher would need to invest in familiarising itself with the new ad server and learning strategies to optimise revenues on the new system would hamper its ability to innovate to maximise its revenues. Moreover, publisher ad servers typically do not support the transfer of data between them. Loss of historical data after the switch makes accurate inventory forecasting impossible, which can result in either over or underselling. ## Google'S Ability To Use Its Market Power In Inventory And Data To Advantage Its Own Dsp Services 5.207 The first set of concerns is that Google uses the importance for advertisers of its owned and operated inventory and the richness of its data for targeted advertising to strengthen its position as a DSP provider in open display. 5.208 As discussed above, Google has access to very rich user data. These data allow Google to create detailed audiences, which are made available for targeting in open display only through Google's own DSP services (DV360 and Google Ads). In addition, advertisers can buy YouTube inventory programmatically only through Google's DSPs. This affects advertisers' choice of DSP for non-Google inventory as well, because a single DSP is typically used for a given campaign. Using a single DSP gives advertisers the ability to manage frequency across the entire campaign, making sure that the same ad is not served too frequently to the same consumer. Therefore, if an advertiser wants to include YouTube in a campaign, it has a strong incentive to use Google's DSP for the entire campaign. 5.209 The effectiveness of this strategy is confirmed by submissions we received from advertisers in relation to DV360, which is used by larger advertisers and media agencies to buy display advertising.274 Every respondent to our information request used DV360, although in many cases they also used other DSPs, depending on the campaign. All those advertisers who had decided to use a single DSP across all their campaigns chose DV360. Based on advertisers' submissions, the main reasons for choosing DV360 include the use of Google's proprietary data and affinity audiences, and exclusive access to YouTube inventory, in addition to its integration with the rest of Google's ad stack and its access to a large advertising inventory across the internet. ## 5.210 We Heard Three Main Counterarguments From Google: - Having an advantage in terms of data or inventory is not unique to Google. For example, Facebook and Amazon have extensive user data that can be used for targeting purposes and make it available to advertisers only through their platforms; they also control, especially in the case of Facebook, a large advertising inventory on their consumer-facing platform. However, Facebook has a limited presence in the open display market, and Amazon is currently a much smaller competitor to Google as a DSP (although it is growing rapidly). - Although YouTube inventory has not been available on AdX, and therefore not accessible to non-Google DSPs, since 2016, even before that thirdparty DSPs accounted for [a small percentage] of spend on YouTube. YouTube mobile inventory was never available to third-party DSPs, nor was TrueView inventory,275 which is sold using proprietary algorithms and pricing models different from the real-time bidding model used by DSPs bidding into AdX.276 However, the fact that YouTube inventory was only available on a restricted basis even before 2016 does not remove the potential concerns about the impact on current market conditions of the tying of YouTube inventory to Google's DSP. - Some other DSPs have been able to attract advertisers by investing on their technology and providing a more customised service and easier integration of advertisers' own data. However, these appear to be significantly smaller than Google, and have told us that one of the main barriers they face is the ability of Google to tie its inventory into its DSP services. 5.211 Finally, Google may be also able to leverage its market power in search inventory into display advertising. Google Ads is the main route through which advertisers, especially smaller ones, buy Google's search inventory. The importance of search inventory for advertisers makes Google Ads an extremely popular buying platform. Advertisers using Google Ads for their search campaigns can easily extend the scope of their campaigns to display advertising. Indeed, Google Ads includes both Search and Display Network by default when an advertiser sets up a campaign on Google Ads.277 Moreover, Google Ads makes it extremely easy for small advertisers to build a display ad, offering a free tool for creating it and even providing pre-made images that can be added to text ads.278 All this makes it very attractive for smaller advertisers to use Google Ads not only for search, but also for display advertising on third-party websites. As a result, Google Ads constitutes an important source of demand for publishers.279 ## Links Between Google Ads, Google Adx And Google'S Publisher Ad Server 5.212 The second set of concerns is that Google has made it difficult to access its advertiser demand (especially from Google Ads) through alternative publisher ad servers, thereby increasing its market power in ad serving and making it difficult for other providers to compete on the merits. 5.213 Demand from advertisers for third-party display inventory through Google Ads is overwhelmingly channelled through Google's own exchange, AdX (now part of Google Ad Manager). Between September 2018 and August 2019, the aggregate value of the impressions won by Google Ads through AdX was [several] times that of impressions won through other third-party exchanges. This suggests that publishers place a high premium on being able to access AdX demand. 5.214 In turn, it is difficult for publishers to efficiently access AdX demand from a non-Google ad server. Although AdX can receive requests from, and submit bids to, other ad servers, its demand cannot be easily placed in real-time competition with that from other SSPs. Unless an SSP is vertically integrated with the publisher ad server, the only way for it to compete with other SSPs with real-time bids is through a header bidding solution (or, if a publisher uses Google Ad Manager, through Google's Open Bidding). AdX, however, does not participate in header bidding. As a result, if the publisher uses a non- Google ad server, AdX would compete with an 'expected' price, rather than with an actual bid. This system is inefficient for the publisher. 5.215 While other publisher ad servers may provide a technical solution to integrate AdX demand, this is not as efficient as header bidding and presents several limitations. An ad server provider told us that the only way publishers using its ad server can benefit from Google Ads demand is to first run an auction of all non-Google demand and, then, to dynamically call an ad unit in Google Ad Manager, setting a floor price equal to or higher than the price returned from the auction for all non-Google demand. Google will then run its own auction. This process is highly inefficient. The main issue is around latency, as the publisher has to wait for two separate auctions to complete in sequence. Latency degrades the customer experience of the publishers' users, and risks loss of revenue if the impression is lost due to the delay in serving an ad. The process also increases costs, because the publisher has to pay ad serving fees to both the main ad server provider and Google. This system also potentially gives Google a 'last look' advantage, as Google knows the winning price of the non-Google demand before it runs its auction. Finally, this is a technically complex set-up that requires significant effort by both the publisher and the ad server provider to implement and maintain. 5.216 Google told us that its decision not to participate in header bidding was due to several reasons, including the fact that header bidding increases latency and harms consumer experience, the lack of transparency about what header bidders actually pay, and the impossibility of ensuring that impressions sold via header bidding are sold in compliance with data protection laws. 5.217 The effect of linking Google Ads demand to AdX and AdX to Google's publisher ad server is to increase the barriers publishers face in switching from Google to a different ad server, reducing competition in ad serving. The main concern some publishers expressed around switching to a non-Google ad server was not related to the costs and risks discussed above, but to the risk of not being able to access demand from AdX, and therefore from Google Ads, in an efficient manner. 5.218 In addition, linking Google Ads demand - where Google may be able to extract a significant rent - with the publisher ad server may provide Google with a greater incentive to foreclose rival providers along the intermediation chain. - First, this link may allow Google to soften rivals' ability to compete. Google could implement such a strategy by credibly committing to price aggressively on the ad serving market, leading to the exit of competitors or depriving them of economies of scale. In this regard, we have been told that Google has implemented a very aggressive sales strategy for its publisher ad server, charging very low prices for ad serving and, in some cases, offering guaranteed media spend to publishers signing up to Google Ad Manager. We will explore these concerns in the second part of the study. - Second, Google has an incentive to degrade the quality of rival providers, by favouring its own intermediation services, so that rivals are less attractive to publishers, making a foreclosure strategy less expensive to implement. In the following paragraphs, we explain how Google may have historically favoured, and may still be favouring, its own SSP. ## Self-Preferencing Between Google'S Publisher Ad Server And Adx 5.219 A third area of concern is that Google may be able to use its position as the largest publisher ad server to favour its own demand from AdX. 5.220 Historically, and at least until the most recent changes to how Google Ad Manager operates, AdX had an advantage over other SSPs when Google's publisher ad server was used. The nature of this advantage changed through the years as a result of the evolution of the intermediation ecosystem; this is discussed in Appendix H. 5.221 Google has recently announced its decision to change how its publisher ad server works, introducing a unified first-price auction in which the winning header bidding SSP, the DSPs bidding into AdX, and SSPs participating in Open Bidding will take part. As part of this transition, Google has made the policy decision to remove AdX's ability to observe the bids submitted by header bidding SSPs before running its own auction, the so-called 'last look' advantage. While this decision should lead to a fairer competition between different SSPs, some publishers told us that the bidding information they receive from Google Ad Manager does not allow them to effectively verify that the auction is conducted fairly. Google still has the incentive to favour its own services and some other changes introduced with the move to a unified auction may still give AdX an advantage, as we discuss below. 5.222 Publishers typically measure the value of their SSPs based on the incremental revenue driven by each provider. Doing so requires the ability to compare the winning bids received from an SSP with the second-highest bids received for the same impressions: the higher the difference, the higher the value of that SSP for the advertiser. Following recent changes in the bidding data that Google Ad Manager provides to publishers, it will no longer be possible for them to compare the performance of non-Google SSPs versus AdX, ie comparing the winning bid from a non-Google SSP with the bid received from AdX. As a result, SSPs will find it increasingly difficult to demonstrate how they add value for publishers, while publishers will have less incentive to sustain the costs of integrating non-Google SSPs through header bidding. 5.223 In relation to this change, Google told us that the data files that include AdX non-winning bids were only made available in August 2017 as an 'alpha' feature, giving buyers the option to opt out of sharing their bid data with publishers. The possibility to opt out was removed with the transition to unified auction. This, however, required Google to eliminate the possibility to link nonwinning bids to specific impressions, and therefore to individual consumers. The restriction was also prompted by consumer privacy considerations. 5.224 Google has also introduced a new piece of information that Google Ad Manager will send to AdX and to Open Bidders after an auction is completed - the 'minimum bid to win'. These bidders will receive information on the minimum bid that would have allowed them to win an auction. Google told us that this benefits buyers by allowing them to improve the competitiveness of their bid; in turn, the increased demand-side transparency and bid accuracy benefits publishers by improving auction competition, which drives publisher revenues. While this information cannot be used to bid on the same auction, as it is provided ex-post, it is useful for training bidding algorithms in future auctions. This information is provided to SSPs bidding through Open Bidding but cannot be provided to those bidding through header bidding, as Google Ad Manager does not know the identity of header bidders. As a result, it provides an incentive for non-Google SSPs to use Open Bidding rather than header bidding. When using Open Bidding, however, SSPs are charged an additional fee, placing them at a disadvantage compared to AdX. ## Self-Preferencing Between Google'S Dsp And Ssp 5.225 The fourth area of concern is that Google could potentially be favouring its own SSP by preferring it when DV360 decides where to submit its bids. As publishers typically work with multiple SSPs, DSPs receive multiple bid requests related to the same ad opportunity. While there is currently no way to efficiently de-duplicate such requests, some DSPs have developed systems to reduce the volume of bid requests that reach them, reducing the costs they have to sustain to listen to the bid stream and respond to bid requests. It is therefore possible that a company operating a DSP may favour its own vertically integrated SSP when deciding where to bid. One advertiser told us that the activity reports it receives from DV360 show that it heavily relies on AdX. 5.226 However, Google told us that DV360 submits a bid for each bid request with a suitable impression according to the parameters set by the advertiser. Moreover, we note that there are efficiency reasons why a DSP would tend to buy impressions from its vertically integrated SSP more often than from other SSPs. As discussed earlier in this section, when the DSP and the SSP are operated by the same company, they use the same user identifier, eliminating the loss of data due to failed cookie matching. In addition, the low level of latency in the communications between the DSP and SSP means that the bid submitted by the DSP will always reach the SSP before the auction closes, unlike with third-party SSPs. 5.227 On the other hand, these technical efficiencies, in the context of the issues discussed above - Google's market power in ad serving and the preferential treatment of AdX by Google's publisher ad server - provide a further advantage for DV360 over competing DSPs, in addition to those already discussed above. When Google's ad server is used by the vast majority of publishers and AdX has an advantage compared to other SSPs when bidding into it, a DSP like DV360 which does not suffer from loss of data or latency when bidding into AdX becomes an even more attractive option for advertisers. ## Potential Impacts Of Privacy Concerns And Data Protection Legislation 5.228 As discussed in Chapter 4, one of the overarching concerns highlighted by market participants was the potential impact of privacy concerns and data protection legislation (including GDPR) on how the open display market might develop. We heard two broad areas of concern: - first, that the GDPR might lead to continuing consolidation of the display advertising market within vertically integrated 'walled gardens' and make it harder for independent intermediaries to compete with the likes of Google in the open display market; and - second, that GDPR and privacy concerns have been used to justify a reduction in sharing of data with other market participants including publishers, which exacerbates the concerns about lack of transparency in the market. ## Impact On Competition In The Open Display Market 5.229 Programmatic advertising relies on an extensive chain of data flows. When publishers make a bid request, advertisers and DSPs attempt to match a publisher's user ID with their own data about the individual in order to provide personalised advertising. Figure 5.11 illustrates the typical flows of data between parts of the open advertising chain. Source: CMA. 5.230 There are relatively few transfers of personal data between different entities for a transaction conducted entirely within a vertically integrated platform because the platform can make use of its own data on the individual in order to provide personalised advertising - ie the data flows remain within the 'walled garden'. By contrast, third-party intermediaries in the open display market rely on being able to match different sources of third-party data, for example by using cookie-matching. 5.231 The ICO has stated that, due to the provisions of the PECR, which provide specific rules regarding the use of cookies and similar technologies, consent is required for the processing of personal data in bid requests, and that in practice consent is also the most appropriate lawful basis for other processing. Where personalisation does not involve processing activities to which PECR applies, legitimate interests may also be considered on a case by case basis. The ICO's Update Report into Adtech and RTB also stated that in the current ecosystem it is not possible for consumers to provide valid consent to the processing of their personal data (including special category data such as political opinions, religious beliefs and data relating to heath). This is due to PECR's requirements and also because of the nature of the processing. The data may be shared with an unknowable (from the perspective of the consumer) and large number of parties, with unknowable controls and security measures. This means that the consumer would never be fully informed about what happens to their data and would not be able to exercise their rights over that data. 5.232 For reasons discussed in detail in Appendix H, it is challenging for intermediaries that do not offer user-facing services to obtain consent. At the extreme, this could mean that third-party intermediaries would need to radically reduce the number of other parties they shared a consumer's personal data with to a level the consumer could realistically understand so as to give valid consent to targeted personalised advertising. This would increase, potentially very significantly, the data advantage of the large platforms that have their own rich sources of first-party user data. We expect that this in turn would increase the competition concerns in the open display market outlined above. ## Reduction In Data Sharing By The Platforms 5.233 We have also heard concerns that data protection legislation is being used by the platforms to justify moves to limit the amount of data that is shared with other market participants. Examples of decisions that have led to such data limitations include: - Google's decision to remove time stamp data from bid requests - previously publishers could attempt to match their own information on advertising impressions with advertiser-side data by using the time stamp of the impression as a common identifier of that consumer. We were told that Google has recently made the time stamp information less precise, so that publisher and advertiser-side data on a consumer can no longer be matched. Publishers have told us that this reduces their ability to understand financial flows across the ad tech chain. - Google's decision to prevent the DoubleClick user IDs being accessed by ad buyers - the DoubleClick ID pulls together data from the company's various ad and consumer-facing products around a unique user ID associated with the DoubleClick cookie. It allowed ad buyers to pull data out of DoubleClick Campaign Manager (now part of the Google Marketing Platform) for reporting on ad performance and ad attribution Although advertisers can now access reporting, attribution and measurement insights using Google Ads Data Hub, they cannot export the data. Google indicated that the DoubleClick ID could be tied to sensitive information like user search histories and could violate the strict data privacy requirements of GDPR. Ad buyers have suggested that stripping out the DoubleClick ID cuts off visibility to user activity within the DoubleClick ecosystem, which made it almost impossible to compare ad performance between ads purchased through the Google ad tech stack and ads purchased through other intermediaries. Advertisers have also suggested that the change made independent ad attribution much more difficult. 5.234 It is not clear whether these examples go beyond the requirements of data protection legislation. However, they illustrate a basic tension between privacy concerns about the sharing of personal data and the desire of market participants to gain access to additional information on consumers to both to target advertising to the right people and to evaluate how effective their adverts are in respect of particular consumers, in order to be able to compete more effectively with the large platforms. We discuss some potential interventions in Chapter 6 which may reduce, but not completely remove, the trade-off between user privacy, activities that contribute to the efficiency of the digital advertising market (behavioural targeting, verification and measurement), and the ability of market participants to compete effectively with the large platforms. ## Initial Findings On Open Display 5.235 The evidence we have reviewed so far suggests that lack of transparency on fees is a significant issue in the open display market. This may limit the extent of competition between SSPs, reduce the competitive pressure faced by DSPs, and give rise to rent-seeking behaviour and arbitrage opportunities. The outcome would be lower revenue for publishers, leading to a reduced incentive for them to invest in content, to the detriment of final consumers. 5.236 Moreover, the evidence suggests that, in recent years, the intermediation ecosystem has been going through a process of consolidation and vertical integration. While vertical integration can generate technical efficiencies to the benefit of both advertisers and publishers, it can also give rise to conflicts of interest and allow companies with market power at one stage of the value chain to leverage it in other parts of the industry, potentially foreclosing competing providers. 5.237 Specific concerns have been raised about Google, which is present along the entire intermediation chain. Google may be able to exploit its position on both sides of the market and to leverage its market power in search advertising, its advantages with respect to user data and its control over a large own-andoperated display inventory to strengthen its position in advertising intermediation. In particular, Google: - may be able to use the importance for advertisers of its owned and operated inventory and the richness of its data for targeted advertising to strengthen Google's position as a DSP provider; - has made it difficult to access its advertiser demand (especially from Google Ads) through alternative publisher ad servers, thereby increasing its market power in ad serving and making it difficult for other providers to compete on the merits; - may be able to use its position as the largest publisher ad server to favour demand from its own SSP; and - may also favour its own SSP by preferring it when its DSPs decide where to submit their bids. 5.238 Privacy concerns and the application of GDPR are likely to have a significant impact on the market, reinforcing the trend towards vertical integration and potentially increasing the data advantage of the large platforms that have their own sources of first-party user data, making it harder for third parties to compete. These trends could exacerbate the existing competition concerns. 5.239 Refer to Appendix H for a more detailed explanation of how intermediation in open display advertising operates. Potential interventions to tackle our concerns about transparency and conflicts of interest are set out in the Chapter 6. ## The Relationship Between Large Digital Platforms And Publishers 5.240 The previous section discussed the issues faced by publishers when they sell digital advertising via intermediaries in competition with walled gardens. In this section we examine the other relationships publishers have with Google and Facebook. 5.241 Publishers of online content rely on Google and Facebook to host content or for referrals of traffic to their online properties, which they can then monetise by displaying advertising to these visitors. However, online publishers consider that they face an imbalance of bargaining power with Google and Facebook, which disadvantages their businesses in a number of ways. 5.242 This section draws on evidence we have received from a number of large publishers of online content aimed at a UK audience.280 These submissions come from a range of publishers including traditional news publishers - who have transitioned from print-based distribution of content towards either a mix of print and online distribution or solely online distribution - and 'digital-first' publishers. 5.243 Below we first set out the various relationships publishers have with Google and Facebook and then our preliminary analysis of the potential imbalance in bargaining power between publishers and these platforms. ## Relationships Between Publishers And Large Digital Platforms 5.244 Publishers typically identified Google and Facebook as being by far the most important digital platforms for their businesses. Apple, in its role as a supplier of a large mobile operating system and its Apple News service, was also mentioned as being important by a number of publishers, but its importance was generally rated as being significantly below that of Google and Facebook. ## Publisher Business Models 5.245 Publishers describe employing three broad types of business model to monetise their digital properties. The type of digital business model affects how the publisher generates revenues and how it interacts with Google and Facebook. Broadly the three types of business model are: - Subscription based - where the prime focus of the publishers is to turn an engaged audience into paying subscribers; - Traffic/digital advertising based - where the main goal is to drive traffic towards the publisher's webpages and monetise this in the form of targeted digital advertising displayed to visitors; and - Monetisation of content on posted third-party platforms - publishers post content on third-party platforms, usually social media, and use the monetisation tools made available by those platforms - such as the sharing of advertising revenues - to generate revenue. 5.246 In practice, most of the publishers blend some aspects of all three of these business models and depend to a significant degree on Google and Facebook for the success of their business models. ## Interaction With Google'S Consumer-Facing Services 5.247 Online publishers interact with the consumer-facing services of Google in a number of ways. 5.248 The most important interaction is with Google Search, which is a very significant referrer of traffic to online publisher websites both via organic and, to a lesser extent, paid search results.281 Prominence in the organic results of relevant Google searches is considered extremely important by online publishers. As a result, significant resources are devoted to optimising the positioning of web pages in Google search results (an activity known as search engine optimisation - SEO). In addition, almost all publishers we spoke to told us that they engage in paid search activity to increase the prominence of their web pages in Google search results. 5.249 YouTube was also considered very important for their businesses: all of the publishers we received submissions from reported that they post content on YouTube. Their aims in doing so are threefold: firstly, to drive traffic back to their websites; secondly, to generate awareness to their content and brand; and thirdly, to generate revenue via YouTube advertising and, to a lesser extent, subscriptions. 5.250 Publishers of content on YouTube can be eligible for a share of advertising revenue on YouTube if the content meets certain standards and a threshold number of views is passed. Where this is the case, YouTube sells advertising, displayed at the beginning (pre-roll) and during (in-stream) of publisher content. Publishers told us that they receive around 55% of any consequent advertising revenue. In some cases, publishers can arrange for their directly sold advertising to appear alongside their content. In addition, content publishers have the option to earn revenue from subscriptions.282 5.251 One other aspect of Google's consumer-facing services that is considered very important by publishers is Accelerated Mobile Pages (AMP). AMP is a publishing format for mobile devices that enables the fast loading of content in browsers. In order to enable fast page loading, AMP employs an optimised and restricted version of the code used to build web pages, and web pages are cached within the AMP ecosystem.283 As pages are cached, usually by Google, consumers remain within the Google ecosystem whilst browsing an AMP page.284 5.252 Publishers told us that they need to put web pages in AMP format, because they think that gives them greater prominence in mobile search results. In particular, it was noted that only AMP pages will appear in the 'Top Stories' carousel that are shown in the results of searches with 'news intent'. Publishers considered that, for the most part, AMP pages operated in a similar way to their regular mobile web pages. However, as is discussed in more detail below, they have concerns around restrictions on their ability to monetise these pages and their ability to access data generated from consumers' interaction with them. 5.253 Another Google consumer-facing service that was mentioned by several publishers was the Google News website and app. However, its importance was considered to be much lower than that of Google Search and YouTube. Google News collects information from other online publishers and presents it to consumers as a collated, curated product.285 In principle, publishers are eligible for a share of any advertising revenue for ads that appear alongside their content, but Google does not currently display advertising on Google News. ## Interaction With Facebook'S Consumer-Facing Services 5.254 Facebook is another key source of consumer traffic for publishers. Publishers post content on their own Facebook pages with the aim of generating awareness of their content and brand and of referring traffic back to their websites and apps. Publishers report that they have little or no opportunity to directly monetise what might be termed standard content on their Facebook pages. 5.255 Facebook's News Feed is another key source of traffic.286 To post content in Facebook's News Feed, a number of publishers put their web pages in into Facebook's Instant Articles (IA) format. Similar to AMP, IA is a publication format that has been designed to allow mobile pages to load faster,287 but in the case of IA it is only in use on the Facebook mobile app. Publishers receive a [majority] share in advertising revenue generated by Facebook from adverts that appear alongside their IAs. They also have the option to insert their own directly sold advertising alongside their IA and, where they do this, they receive 100% of the advertising revenue.288 5.256 Several publishers also post content on Facebook's video hosting service Facebook Watch, although several considered that doing so was not worth their while, given the effort required. Where they post content of Facebook Watch, publishers may be eligible for a share of advertising revenue where the content meets certain standards and a threshold of views is surpassed, and they receive approximately 55% of any revenue for advertising displayed alongside their content.289 ## Google And Facebook As A Source Of Traffic For Publishers 5.257 We have analysed website traffic data from a number of large publishers.290 This data shows that in 2018 and 2019 these publishers relied on Google and Facebook properties for around between 36% and 38% of total traffic to their websites, see Table 5.1 below. | Year | Website traffic from Google, Facebook and Direct visits | |---------|-----------------------------------------------------------| | 291 | | | | | | | All traffic | | | Google | | 2019 | 25% | | 2018 | 26% | Source: CMA analysis of publisher data 5.258 Based on publisher submissions in 2018 and 2019 (up until June) the average proportions of traffic to their websites that were referred via Google properties was 26% and 25% respectively (for 2019 min was 8% and max was 57%). Referrals from Facebook properties were responsible on average for 10% of website visits in 2018 and 13% in 2019 (for 2019 min was 2% and max was 47%). Direct website visits were the most important source of traffic with 44% of visits being direct in 2018 and 43% being direct in 2019 (for 2019 min was 6% and max was 57%). Other visits come from what are termed 'other thirdparty referrals', for example referrals from Snapchat or Instagram. ## The Balance Of Bargaining Power Between Online Publishers And Google And Facebook 5.259 Publishers have told us that they view Google and Facebook as 'must have' partners. This is primarily due to a substantial proportion of the traffic referred to their websites coming from Google and Facebook properties and a degree of reliance on prominence on Google and Facebook properties for content discovery and brand awareness. 5.260 As a consequence of this reliance on Google and Facebook for traffic, publishers told us that they suffer from an imbalance of bargaining power when dealing with these platforms. This was an issue that was also raised as part of the Cairncross Review, which concluded that 'Google and Facebook also increasingly control the distribution of publishers' content online' and that as a consequence 'these platforms can impose terms on publishers without needing to consult or negotiate with them'.292 5.261 This potential imbalance of bargaining power has led to publishers expressing a number of concerns about how their relationships with Google and Facebook result in them being disadvantaged. The most significant of these are explained below. ## Unexpected And Unexplained Changes To Search Algorithms 5.262 Most publishers expressed some concern about unexpected and unexplained changes to Google and Facebook search algorithms, most notably in relation to Google Search and Facebook News Feed. Specific examples of several algorithm changes which significantly impacted website traffic were mentioned, including: - Facebook's announcement on 18 January 2018 that from that day its News Feed ranking algorithm would prioritize 'meaningful interactions' from friends and family over content from brands.293 This change had the impact of deprioritising content from some online content publishers in the News Feed ranking of many Facebook users. - Google's 3 June 2019 core search algorithm update announced a change being implemented the following day which resulted in a step change in the daily traffic arriving at many news websites via Google Search. Some sites saw an increase in daily traffic arriving via Google Search, but others saw significant decreases.294,295 5.263 Publishers have argued that a reduction in website traffic resulting from an algorithm change has a direct financial consequence for their business in the form of lost opportunities to monetise these visits through advertising. Furthermore, they told us that sudden, unexplained and significant algorithm changes make planning and financial decision-making more complicated and can lead to significant, potentially wasteful, expenditure on understanding these opaque algorithms and optimising content to appear high up in the rankings. 5.264 Publishers broadly are of the view that they do not get sufficient warning of algorithm changes or sufficient explanation of their impact or of what they might do to mitigate any loss of traffic. A number of publishers have suggested that there should be a role for a regulator to monitor and report on the main Google and Facebook search ranking algorithms. 5.265 Whilst some publishers feel very strongly about algorithmic transparency and considered it to be of critical importance to their businesses, for others it was less of an issue and was viewed more as a consequence of doing business with Google and Facebook which they have, to a degree, grown used to. 5.266 Whilst publishers have a number of issues with the approach taken by Google and Facebook to updating their algorithms, we note that there are legitimate reasons for regularly updating search algorithms as these are central to improving the consumer experience of Google and Facebook properties. There are also arguments to support the idea that too much transparency regarding these algorithms might be counter-productive as providing too much information might allow businesses to effectively 'game' the algorithm by knowingly drafting or changing content to increase their rankings. ## Use Of Publisher Content For 'Free' 5.267 Publishers provide content into the Google and Facebook ecosystems in three main ways: firstly, by posting content on their social media platforms, such as Facebook's main site and YouTube; secondly, through hyperlinks and short explanatory 'snippets' of content that appear within Google's organic search ranking pages; and thirdly when utilising the publication formats AMP and IA. 5.268 Some publishers argue that Google and Facebook effectively 'free ride' on content produced by third-party publishers and that this includes professionally produced content - whether that be breaking news, analysis, features, entertainment or sport, produced by publishers under their editorial responsibility and legal liability. They argue that, without this, Google and Facebook would attract less traffic to their platforms and would consequently generate less advertising and have fewer opportunities to collect valuable user data. 5.269 Some publishers have also argued that there is an increasing tendency for content to be consumed within the Google and Facebook ecosystems without clicking through to the source websites. A European Commission report in 2016 reported that 47% of UK individuals surveyed said that when they access the news via news aggregators, online social media or search engines, they most often browse and read the main news of the day without clicking on links to access the whole articles.296 5.270 A couple of publishers referenced a recent study by the News Media Alliance (NMA). This estimated that Google receives $4.7 billion in revenue from News Publishers' Content worldwide in 2018.297 The methodology of this study is however limited298 and, as Google pointed out in response, 'the overwhelming number of news queries do not show ads'299 and no advertising is currently displayed on Google News. 5.271 Publishers have also mentioned that, while they consider that Google and Facebook benefit significantly from using their content, they cannot always easily monetise content that is hosted on Google and Facebook properties. As we note above, publishers do not benefit from advertising that is placed next to 'standard' Facebook content. Publishers can benefit from advertising revenue that is generated from their own content posted on YouTube, Facebook Watch and through IA. However, several publishers have suggested that the mechanism by which they receive the remuneration is opaque and that any revenues they receive are limited. Publishers have also suggested that their ability to monetise content hosted on AMP is significantly reduced when compared to their standard mobile web pages. One of the reasons suggested for this was that AMP does not currently support client- side header bidding and that, whilst a form of server-side header bidding is supported, the number of partners they are able to integrate into this is limited to five or less.300 5.272 Google and Facebook have previously argued that they do not receive thirdparty content for free from online publishers, but that in fact the publishers receive a significant volume of web traffic in return for their content. In response to the NMA study, Google stated that 'Google News and Google Search drives over 10 billion clicks to publishers' websites, which drives subscriptions and significant ad revenue'.301 In a submission to the EU, as part of its development of the EU Copyright Directive, Google submitted research that it said showed that News publishers in the EU benefited significantly in financial terms from traffic referred to their websites by third parties (including Google Search). 5.273 One potential development in this area is the EU Copyright Directive,302 which was approved in April 2019. The Directive provides media businesses with rights governing the online use of their content by information society service providers (which would include digital platforms). However, it explicitly states that this right shall not apply to the 'acts of hyperlinking' and 'in respect of the use of individual words or very short extracts of a press publication'. 5.274 Publishers were sceptical that the Directive would have any material effect of their ability to negotiate with Google and Facebook over the use of their content even if it were to be adopted into UK law. Although one noted that, in principle, it could enable publishers to negotiate licensing agreements for the distribution of journalism through search and social platforms with market power, the prevailing views were that either its impact was highly uncertain or that there would be very little impact. Particular points of concern were that implementation of the Directive would lead to less content appear on these platforms or that publisher would have little choice but to enter into licencing agreements with the platform for no remuneration in return. ## Giving Up Of Valuable User Data Without Reciprocation 5.275 Google and Facebook are able to collect and use individual data from consumers who interact with content on the publisher platform. Often the use of Google and Facebook analytics services by a publisher leads to the placing of a cookie when the service is accessed or a pixel on the publisher website. In addition, if content is consumed within the AMP or IA publication of formats, then the consumer remains in the Google or Facebook ecosystem and, therefore they have access to data on the consumer interaction. Google and Facebook are able to use this data to develop their services, to deliver targeted digital advertising and improve their ability to undertake ad analytics including ad attribution. 5.276 Publishers do not have access to the same level of data on consumer interaction with their own content, when hosted on Google and Facebook properties. Publishers report that they generally receive data that is very aggregated and anonymised, which they cannot match to their own first-party data to create consumer profiles across domains. Publishers expressed specific concerns about this with regard to Facebook, IA and YouTube.303 Publishers told us that the reason why data is only provided in an aggregated and anonymised form is generally stated as being due to privacy. 5.277 One impact of this ability of Google and Facebook to observe consumer interaction on many publisher sites is to reinforce the advantages they have over most other online publishers in offering targeted advertising due to their greater access to online data. In particular, this reinforces Google's and, to a lesser extent, Facebook's ability to track consumers across different web domains.304 5.278 There is also the possibility that access to data on consumer interactions on many publisher sites may undermine the value of that data to the publishers themselves. Access to this data by Google, may lead to it being used for targeting by Google ad tech companies for ads on sites other than the original publisher website. Therefore, data on a publishers' unique audience may be 'commoditised' and used to target ads on cheaper sites and apps, which might undermine the value of advertising inventory on a publisher's own website. ## Gdpr 5.279 A further example of the imbalance of bargaining power, cited by several publishers, was the approach taken by Google to updating its terms and conditions shortly before the introduction of GDPR. At the beginning of May 2018, just weeks before the GDPR came into effect, Google released its updated online T&Cs, to cover changes to its advertising services. The terms describe Google as a co-controller of data for certain of their advertising products and require publishers to gain consumers' consent on Google's behalf to gather and utilise their data. Publishers consider that these changes were made in a non-negotiable way and that they had no choice but to accept this update to the T&Cs. ## Initial Findings On Relationship Between Platforms And Publishers 5.280 We have found that publishers frequently depend on large platforms as a significant gateway to consumers - for example through Google Search or the Facebook news feed. This can give platforms significant bargaining power over some publishers. 5.281 Manifestations of this relationship between publishers and platforms include: - Changes in the platforms' search or ranking algorithms can have significant impacts on publishers' traffic, and ultimately their revenues. - Platforms are able to use publishers' content to increase their attractiveness to consumers, and to monetise part of the value of that content through the sale of advertising. - In some cases, publishers have to give data to the platforms as a condition for gaining access to consumers. This data can help the platforms to increase the value of their advertisers, and in some cases might also help the platforms in establishing their own additional consumer-facing services. 5.282 In Chapter 6 we consider potential interventions which might help prevent platforms from being able to unfairly exploit their bargaining position with respect to publishers. ## Initial Findings 5.283 Our initial analysis outlined in this chapter suggests that competition in digital advertising is driven primarily by competition for consumers' attention and data. Advertisers are attracted to online platforms and publishers that reach a large volume of consumers and can target advertising at individuals for whom their advertising is particularly salient. Where platforms have market power on the consumer side, this enables them to increase their rate at which they monetise consumer attention, either by increasing the volume of advertising or by increasing advertising prices, leading to worse outcomes for consumers. 5.284 Digital advertising is distinguished from traditional advertising in how data is used both to target specific audiences and to measure outcomes. Advertiser choice is data-driven using measurable KPIs that broadly range from awareness to performance. The complexity of this process results in some transparency issues that could weaken competition or create potential for outcomes to be misreported. 5.285 Although all forms of advertising compete for consumer attention to some extent, advertisers use different forms of advertising for different purposes. Within digital advertising, search, display and classified advertising serve distinct purposes, with only limited substitutability between them. There is also a distinction within display advertising between video and non-video advertising. This means that platforms that control a significant share of a particular type of advertising inventory are able to exercise a degree of market power over advertisers. 5.286 Google has significant market power in search advertising. It has a very large share of search advertising revenues, reflecting its high share of searches on the consumer side. Other search engines face significant barriers to attracting advertisers, in addition to the barriers to building share on the consumer side. Google is viewed as a 'must have' channel for search advertising given its scale, and there are incentives for advertisers (particularly smaller advertisers) to single-home. Google is also able to use its access to data across a large proportion of the internet to provide higher-quality analytics and attribution services which increases the value of the advertising in a way that is very hard for other smaller search providers to compete with. These factors are reflected in the higher revenues per user that Google is able to earn relative to its competitors. 5.287 In display advertising, there are a large number of online publishers and apps selling inventory to advertisers. However, a significant majority of advertising revenues go to a small number of platforms. Facebook and Instagram jointly account for nearly half of display advertising revenues, and YouTube (owned by Google) is also a significant seller of video advertising. The large platforms have a significant data advantage over smaller competitors and publishers, which both increases the value of their advertising inventory and creates additional barriers for their competitors to overcome. As with search advertising, there are also incentives for smaller advertisers to single-home. As a result, the largest platforms are able to exercise significant market power over advertisers. 5.288 Other online publishers wishing to monetise their content through advertising have to sell inventory through the open display advertising market. This market relies on a complex chain of intermediation to auction advertising in real time and provide data for audience-targeting. The market has been consolidating largely through acquisitions over time, partly driven by efficiency reasons, and more recently by concerns about the privacy implications of transferring data on consumers between third parties. As a result, there now appears to be significant concentration at several levels, with a continuing trend towards consolidation. 5.289 Google has a particularly strong position in the ad tech stack. This raises two main sets of concerns. First, Google's position as a provider of advertising intermediation services to both publishers and advertisers creates a conflict of interest, which is exacerbated by the lack of transparency in the market. Second, Google may be able to leverage the market power from its 'owned and operated' advertising inventory into the open display market, both extending its market power and protecting its core position in search advertising and data. As a result, we are concerned that publishers are likely to face worse outcomes than in a more competitive market. 5.290 We are continuing to carry out evidence-gathering and analysis on many of the issues highlighted in this chapter, so we would expect these interim findings to evolve during the study. In particular, we are carrying out further work in the following areas: - further evidence-gathering to better understand advertiser behaviour, including differences between large and small advertisers and the degree of single-homing vs. multi-homing; - more detailed analysis of money flows within the ad tech stack; and - further analysis of advertising outcomes and the potential effects of market power. ## 6. Potential Interventions - The evidence we have seen at this stage strongly supports the case for the development of a pro-competitive regulatory regime for online platforms funded by digital advertising, as envisaged by the Furman Review. - An enforceable code of conduct would be a valuable regulatory tool in helping to address some of the concerns we have identified in the consumerfacing and digital advertising markets. As envisaged by the Furman Review, the code would apply to online platforms with strategic market status; our initial view is that this would include Google and Facebook. Overarching principles within a code could relate to: 'fair trading'; 'open choices'; and 'trust and transparency'. - Potential interventions to tackle the source of Google's market power in search include third-party access to click-and-query data, and mechanisms for determining the default search engine on devices and browsers. - In social media, potential remedies to tackle the source of Facebook's power relate to increasing its interoperability with other platforms. - We are considering options that would give consumers greater control over their data, including the ability to turn off personalised advertising and still receive the same service. We are also considering a fairness by design duty on platforms to ensure that they do not use defaults and choice architecture to unduly influence consumers' decisions. - We are considering a range of options to tackle the conflicts of interest and lack of transparency in the intermediated market for display advertising. These range from requiring greater transparency to various forms of separation of Google's intermediation activities in the open display market. - We recognise that several of these would be major interventions and therefore need careful consideration. We are seeking views from stakeholders on the costs and benefits of these potential remedies. ## Introduction 6.1 In this chapter we present our initial views on potential regulatory interventions (also referred to as remedies) that could address the concerns identified in the previous chapters. The options discussed here draw on views and proposals put to us by stakeholders during the first half of the study. They also build on the proposals set out in the Furman Review for a stronger ex ante regulatory regime to govern the behaviour of online platforms, but take the discussion beyond high level principles to assess which specific interventions might be required in the markets within the scope of the study. 6.2 We have identified a range of concerns that are likely to require some form of intervention, but we have not yet reached a final view on them, or on the need for any specific intervention. Rather, our aim in this chapter is to highlight potential interventions for consultation, and to seek the views of stakeholders on the case for, and appropriate form of, these interventions. This will inform the conclusions we reach at the time of the final report, including on the appropriate next steps. 6.3 To support this chapter we have produced a series of appendices in which we consider the potential interventions in more detail, and seek views from stakeholders on a range of issues including: whether the intervention in question would be effective in addressing the concerns identified in this report; whether the costs of the intervention would likely outweigh the benefits; and how the intervention should be designed to minimise costs and maximise benefits.305 6.4 The chapter discusses the following: - an overview of our approach to interventions in this area, based on the development of a robust pro-competitive regulatory regime; - our initial views on a potential code of conduct to govern the behaviour of platforms with strategic market status; - options for potential interventions to promote competition in search and social media, addressing the issues identified in Chapter 3; - options for potential interventions to give consumers greater control over, and protection in relation, to the use of their data, addressing the issues identified in Chapter 4; and - options for potential interventions to promote competition and improve transparency in digital advertising markets, addressing the issues identified in Chapter 5. ## Overview: Development Of A Pro-Competitive Regulatory Regime 6.5 The work we have carried out in the study to date has strengthened the view we expressed in our statement of scope that there is a strong argument for the development of an ex ante regulatory regime to regulate the activities of online platforms funded by digital advertising. 6.6 This would be a 'pro-competitive' regulatory regime, in that its objectives would be: to encourage competition by overcoming barriers to entry and expansion and thus tackling sources of market power; and to protect both competition and consumers where online platforms have a position of market power, by governing their behaviour to ensure they act fairly (and in particular, do not engage in exploitative or exclusionary practices). 6.7 While we have an open mind at this stage on the merits of some of the specific interventions that might be contained within it, we think that such a regime would be an important complement to our existing antitrust tools. In view of the fast-moving nature of the markets we have reviewed and the number and complexity of the issues arising within them, our view is that ex post enforcement is not sufficient to protect competition but needs to be bolstered with stronger and clearer ex ante rules. 6.8 Alongside addressing the specific concerns that we have identified in digital advertising markets and the consumer-facing services that are financed through digital advertising, we have aimed to inform the broader debate about the need to regulate the behaviour of large online platforms. In this context, our study supports the high-level positions set out in the Furman Review306 and the Stigler Center Review307 earlier this year, both of which called for stronger ex ante rules to address the competition concerns arising from the increasingly important role that large online platforms play in the economy. 6.9 In the UK specifically, we have aimed to support the government's response to the Furman Review and its broader thinking on the case for regulating online platforms. While our study covers a subset of online platforms (those funded by digital advertising) these include some of the largest global platforms, and this focus has allowed us to explore concerns and potential interventions in more depth. As noted in our statement of scope, we believe that recommendations for government legislation in this area are likely to be one of the most valuable outcomes of our work. We will engage with the newly-elected government to understand its perspective on these issues in the second half of the study. 6.10 Internationally, we have also engaged extensively with competition authorities in several countries in the first half of our study, many of whom are considering similar challenges to those we have identified in this study. These have included authorities in the US,308 Australia,309 Germany,310 Japan,311 Netherlands,312 France313 and Spain.314 Given the fact that many of the issues we are considering are international in nature, we believe that it is highly desirable - particularly for any significant interventions that would have a major impact on a platform's business model - that there is a broad consensus on the case for intervention. We hope that this study will help contribute to such a consensus. ## Elements Of The Regulatory Regime 6.11 The interventions that we assess in this chapter fall into two broad categories: - principles and rules to govern the behaviour of platforms with market power, taking the form of an enforceable code of conduct; and - interventions to address specific concerns relating to market power, lack of transparency and conflicts of interest, to promote competition and to protect consumers. 6.12 These two categories of intervention have distinct functions. The first category of intervention comprises rules to govern the behaviour of firms that enjoy a position of market power. Its intention is to address the harmful effects that can arise from the exercise of market power, rather than tackling the underlying causes. It would focus on changing the behaviour of online platforms that enjoy market power through the use of an enforceable code of conduct for platforms with strategic market status (SMS), as envisaged by the Furman Review. The principles set out in this code would target concerns that we have identified across themes 1 to 3. 6.13 The second category of intervention would aim to address specific concerns that we have identified within the markets we have reviewed, and in particular address sources of market power, by tackling issues on both the demand and supply side of those markets. These include a number of types of intervention suggested by the Furman Review - in particular, data-related remedies including the provision of third-party access to data, giving customers control of their data and measures to increase interoperability - as well as remedies not directly considered by the Review, including structural measures. Many of these would be very significant interventions, the costs and benefits of which would need to be considered very carefully. We consider the case for these interventions under each of themes 1 - 3 below. 6.14 At a high level, an important benefit of behavioural interventions as enshrined in the code is that they allow for considerable flexibility in tackling problems as they arise, which is an important consideration in the rapidly-changing digital advertising markets that we have reviewed. In contrast, the benefit of interventions falling into the second category is that they provide for the possibility of solving problems at source, reducing the need for ongoing and costly regulatory controls. However, these interventions could change the nature of competition in fundamental ways, and close attention would need to be paid to the potential costs and unintended consequences of such measures. 6.15 In principle, elements of the second category of intervention could be implemented alongside the code, or considered only once the code has been up and running for a period of time. We would welcome views on this, and ask questions about the sequencing of interventions in Chapter 8. ## Institutions And Legal Powers 6.16 All of the interventions that we consider in this chapter would need some form of regulatory body to implement them. This is consistent with the findings of the Furman Review, which called for a Digital Markets Unit to be created in the UK, and the Stigler Center Review, which called for the creation of a Digital Authority in the US. 6.17 At this stage in our study, we have focused our assessment on the case for potential new regulatory functions rather than on which institutions might discharge those functions. Accordingly, in the rest of this chapter, we use the term 'regulator' to refer to the body empowered to implement the regulatory functions we are considering. We note that this regulator could be a new or an existing institution, or that regulatory functions could be assigned across several bodies. We expect to give further consideration to the question of institutional design in our final report and would welcome any views from stakeholders on this question. 6.18 Any regulator would need to have legal powers to enforce both the provisions of the code and any specific remedies to address sources of market power. We anticipate that any such powers will need to be assigned through primary legislation and in this study we are looking to inform the scope and direction of such legislation. We note that the CMA already has powers to impose some of the interventions discussed in this chapter, in the context of a market investigation. In Chapter 7 we consider the case for launching a market investigation in the near term, to address the concerns we have identified. ## Code Of Conduct For Online Platforms With Strategic Market Status 6.19 As noted above, the Furman Review proposed that the behaviour of online platforms with market power should be governed by a pro-competitive code of conduct. The code would set out principles or rules to govern the behaviour of platforms with strategic market status (SMS),315 requiring them to act in a way that ensures that consumers and businesses dealing with them are fairly treated and vigorous competition can take place. 6.20 Our initial view is that such a code has the potential to address several of the concerns that we have identified in both consumer-facing and digital advertising markets. In this section we: - assess the case for the use of a code as a complement to existing enforcement tools in addressing the concerns we have identified; - consider the criteria for identifying the firms that the code should apply to; and - consider the principles or rules that could be set out in the code and how these relate to the concerns we have identified in the study to date. ## The Case For A Code 6.21 On the basis of the work we have carried out so far, our initial view is that an enforceable code of conduct as set out above would be a valuable regulatory tool in helping to address the concerns we have identified in the consumerfacing and digital advertising markets. 6.22 In principle, a code could have a number of advantages over existing ex post enforcement: - The markets we have reviewed are extremely fast moving and dynamic, and harm to competition can occur rapidly. A code could therefore be helpful in changing behaviour much more rapidly than is possible through existing antitrust tools, where there is either a risk of harm to competition or of an adverse effect on consumers. - A code would allow action in respect of concerns which might fall short of the test of breaching competition law but might nevertheless have an adverse effect on customers through weakening competition.316 - A code of conduct, which would be subject to consultation, could provide increased certainty over what represents acceptable behaviour of the platforms when interacting with consumers and competitors.317 - The markets we have reviewed are highly complicated, both from a technical perspective and (in the open display market) in terms of market structure. It may therefore be beneficial to have a dedicated regulator (or regulators) to enforce the code, as this body will be able to develop its expertise over time. - A code could be a valuable tool in improving transparency and hence trust in the market. The regulator enforcing the code could be given powers to audit and scrutinise the workings of opaque algorithms and to investigate concerns around conflicts of interest or discriminatory treatment of some customers. This would potentially address much of the opacity and lack of trust which has developed in the markets we have reviewed. 6.23 Introducing a code would also create costs, particularly for those platforms subject to the code, which would need to comply with reporting requirements and with investigations. The code might also require large firms to implement new measures to be able to demonstrate compliance, or new systems to be able to demonstrate that customers are being treated equally. And there is a risk that changes brought about through the code of conduct may introduce inefficiencies into platforms' operations. 6.24 Based on our review to date, we consider that there are a number of potentially problematic practices in consumer-facing and digital advertising markets that could be investigated under the code with likely improvements both to competition and trust. A regulator ordering a change of behaviour under the code would need to assure itself that there were sufficient benefits to outweigh the costs on a case-by-case basis, having regard to the evidence. 6.25 In our view, a code of conduct operating along the lines set out above would not preclude competition enforcement in appropriate circumstances. Such enforcement would still be appropriate in cases of egregious or repeated anticompetitive behaviour, serving as a deterrent against such behaviour in the future. Competition or consumer enforcement remains a potential outcome from this study. 6.26 We note that a substantial number of stakeholders have indicated to us, both in responses to the statement of scope and in subsequent interactions, that they are in support of the establishment of a code, highlighting the benefits identified above.318 We would welcome further views from stakeholders on this topic as part of the consultation on the interim report. ## Which Firms Would The Code Apply To? 6.27 At this stage, based on the analysis carried out in the first half of the study, our view is that the code should apply to a small number of platforms around which potential competition concerns arising from their behaviour are likely to be most significant. 6.28 The notion of 'strategic market status' (SMS) was introduced by the Furman Review to define the category of firms to which the code of conduct would apply.319 SMS is not explicitly defined in the report. It is described variously as a position of enduring market power/control over a strategic gateway market with the consequence that the platform enjoys a powerful negotiating position resulting in a position of business dependency.320 6.29 We note that the approach to SMS designation will be considered by government as part of the process of responding to the Furman Review, and that this process will take account of the characteristics of a broader range of online platforms than we have considered in this study. We have, however, given some consideration to how SMS might be defined in the case of platforms funded by digital advertising, drawing on our own analysis and the high-level principles in the Furman Review. 6.30 Our initial view is that the following criteria provide a useful starting point for assessing whether a digital platform should be considered to have SMS and hence be subject to the code of conduct: - the platform has enduring market power over a relevant market; - the platform acts as an important gateway for businesses to access a significant portion of consumers; and - businesses depend on the platform to access users on 'other' side of the market. 6.31 Evidence likely to be relevant in making this assessment for platforms funded by digital advertising include: share of consumer time spent on the platform; level of reach of consumers; share of digital advertising revenues; control over the rules or standards which apply in the market, and the ability to obtain and control unique data that is applicable outside the market. 6.32 Our initial view is that both Google and Facebook would likely be considered to have SMS against these criteria. Google has had around 90% or more of the search market for over 10 years, as well as having a share of over 90% in the key ad server market. It has a reach of over 90% of UK internet users and various businesses depend on Google for accessing these consumers - both advertisers wanting to secure conversions and newspapers and content providers seeking traffic. It has unrivalled access to data through its consumer services, tags on third-party websites and Android devices. 6.33 Facebook has a reach of 85% of UK internet users,321 and over 75% of the time spent on social media for a number of years,322 and a share of over 40% of the display advertising market. It also has extensive access to data - as discussed in Chapter 5, advertisers have told us that only Facebook is able to provide the targeting of advertising that is most valuable for certain campaigns. Facebook also has an important role in driving consumer traffic to content providers. 6.34 We note that other platforms may be considered to have SMS when considering their role in other markets outside the scope of this study. 6.35 Our initial view is that SMS status would apply to the corporate group as a whole, with obligations under the code applying to the markets in which the firm has market power and adjacent markets, in which that market power can be leveraged, but that there would be an opportunity to consider some limitation on the scope of the obligations under the code where the firm operates in clearly distinct markets. The regime would need to build in a mechanism such that SMS designations can be reviewed, and candidates for new SMS designations can be assessed, within a reasonable timescale. 6.36 We welcome views on this broad approach to identifying the scope of the code of conduct for platforms funded by digital advertising. ## Content Of The Code 6.37 Our initial view is that the code should take the form of high-level principles rather than detailed and prescriptive rules. Given the complex and rapidlychanging nature of the markets within scope and the issues we have identified, there is a risk that overly prescriptive rules would soon become redundant or fail to anticipate important new developments. It is likely, however, to be necessary for the regulator to issue periodic guidance to help with interpretation. 6.38 In the markets that we have reviewed in this study, the code could seek to address concerns relating to a range of different relationships between SMS platforms, consumers and business users, including: - advertisers' and publishers' relationships with platforms in relation to buying and selling digital advertising; - publishers' and content providers' relationships with platforms as a gateway for hosting content and accessing consumers via the platform; - business users' relationships with platforms where they are providing services via platforms but which could also compete with the platforms' own service offerings (for example, price comparison sites or online travel agents); and - consumers' direct interactions with platforms (eg using a search engine or accessing a social media page) 6.39 In practice, the content of the code could differ between platforms, and it may be appropriate to consult on the content of the code at the time of SMS designation. At a high level, however, our current view is that, for platforms funded by digital advertising, the key provisions of the code could be summarised in the form of three overarching principles: '**fair trading**'; 'open choices'; and '**trust and transparency**'. In the following sections, we set out our initial views on the key components of each of these principles. ## Fair Trading 6.40 The principle of fair trading would require the SMS platform to trade on fair and reasonable terms for services where they are an unavoidable trading partner as a result of their market position. In effect, this principle is intended to address concerns around the potential for exploitative behaviour on the part of the SMS platform. 6.41 In practice, the principle for fair trading could entail a number of requirements such as: - a requirement that both prices and non-price terms should be objectively justifiable, for example that customers should not be required to provide data to platforms which are not necessary for satisfaction of the contract; - a 'fairness by design' obligation in relation to the design of consumer consents to data use and choice architecture (as discussed in the next section); and - a requirement that contracts should not put any unreasonable restrictions on how users use the services. ## Open Choices 6.42 The principle of open choices would be intended to require the SMS platform to allow users to choose freely between elements of the platform's services and those offered by competitors. This principle is intended to address the potential for exclusionary behaviour on the part of the SMS platform. There are likely to be two main domains in which this principle is important: contractual terms and commercial behaviour; and technical standards and interoperability. 6.43 In relation to contractual terms, this principle could include requirements: - not to bundle services in markets where the SMS platform has market power with services in competitive markets, or where they are sold together to offer comparable terms for the bundled and separate services; - not to impose restrictions on customers' ability to use other providers that compete with the SMS platform; and - to avoid other forms of self-preferencing behaviour - for example, ensuring that search and ranking algorithms do not preference the platform's own services above those of competitors; and ensuring that consumers are given a neutral choice between services operated by the platform and those of competitors. 6.44 In relation to technical standards, this principle would seek to ensure that the SMS platform allows third parties to interoperate with the platform's essential inputs, and complies with common standards. This could include requirements: - to design core services to be interoperable, eg through APIs, at a costbased price which is objectively justifiable, with reasonable endeavours to manage privacy or technical concerns; - not to withhold, withdraw, or deprecate APIs or otherwise change them in a way which has a material adverse effect on users without (i) sufficient consultation and (ii) objective justification for the change; - to comply with common standards where these are developed by independent third parties and approved by a suitable regulatory body; and - to ensure that any standards developed by the platforms themselves are interoperable, and do not favour the platforms' other businesses. ## Trust And Transparency 6.45 The principle of trust and transparency is designed to ensure that SMS platforms provide sufficient information to users, including both consumers and businesses which transact with the platform, so that they understand how the platform operates and how decisions that affect them are made. Users should also have confidence that decisions are being made fairly and according to publicly-stated criteria. 6.46 This principle could include: - a requirement to explain the operation of search and ranking algorithms and advertising auctions and to allow audit and scrutiny of their operation by the regulator; - a requirement to give fair warning about changes to the operation of algorithms where these are likely to have a material effect on users, and to explain the basis of these changes; - a requirement that platforms provide clear information to consumers about the services they receive and the data the platform takes in return, in a format which can realistically be read and understood; - a requirement that platforms are transparent about fees they charge; and - a requirement for large firms to agree to reasonable requests to access certain data on a fair, reasonable and non-discriminatory basis, subject to GDPR and IP rights, where that data is unmatchable as a result of their market power. How do these principles relate to the specific concerns we have identified? 6.47 In Appendix I we explain how the principles set out above relate to some of the concerns we have identified in Chapters 3 to 5. This is summarised in Table 6.1 below, which identifies a range of practices that could be investigated under each of the three main principles. The practices set out in Table 6.1 cover a range of different relationships between platforms, consumers and business users, including advertisers and publishers, reflecting the multi-sided nature of these markets. 6.48 We are not drawing any conclusions about the outcome of any investigation of these practices under the code. In some cases, there may be efficiency arguments for the practices in question, for example. Rather, our objective is to demonstrate that: - there is a wide range of concerns across the markets we have reviewed; - the number and complexity of issues are such that antitrust alone is unlikely to be sufficient to resolve them; and - there is therefore a robust case in practice for the establishment of a code. ## Table 6.1: Concerns We Have Heard In The Study That Could Be Investigated Under The Code | Principle | Example of concern that could be investigated | |-----------------------------------------------------------------------------------|---------------------------------------------------| | Data gathering from business customers: | Concerns that some platforms | | require access to publishers' data and other customers' data, in some cases | | | without sharing that data with the publisher (Chapter 5). | | | Consumer data extraction: | Concerns that social media platforms use | | choice architecture to nudge consumers into giving away data and gives | | | insufficient choice to consumers over personalised advertising (Chapter 4). | | | Principle 1: Fair | | | trading. | Platforms | | offer services on fair | | | terms: including | | | pricing, non-price | | | terms, requirements to | | | share data, and any | | | restrictions on how | | | customers can use the | | | services. | | | Unfair balance of power: | Concerns that publishers do not have reasonable | | levels of control or flexibility over how they choose to sell their own inventory | | | and present content on platforms (Chapter 5). | | | Bundling competitive services with 'must have' services: | Concerns that | | platforms bundle core services with services in more competitive markets | | | (eg Google ad server and SSP) and fail to inter-operate properly with | | | alternatives (Chapter 5). | | | Unfair restrictions on competitors: | it appears that platforms impose | | restrictions that impede companies' ability to compete eg syndication | | | (Chapter 3). | | | Principle 2: Open | | | Choices | Platforms | | which operate across | | | multiple markets | | | should offer consistent | | | terms across the | | | markets to allow | | | consumers and | | | business customers a | | | fair choice between | | | their own services and | | | their competitors. | | | Self-preferencing / undue prominence to own products: | Within the open | | display market, concerns that Google sets the rules for the auction in Ad | | | Manager in a way that favours its own sources of advertising demand | | | (Chapter 5). | | | Restrictions on interoperability: | Concerns that platforms restrict | | interoperability and degrade APIs to competitors. For example, Facebook | | | has in the past imposed restrictions on the use of APIs, by not allowing | | | them to be used for competing services (Chapter 3). | | | As part of supporting | | | more effective | | | competition in markets, | | | platforms should offer | | | open APIs or | | | interoperability with | | | their core services | | | Principle 3: Trust and | | | Transparency | | | Changing how core services work without due notice | : Concerns that | | platforms change their algorithms without warning in a way that can | | | materially affect publishers and retailers that rely on the platforms (Chapter | | | 5). | | | Lack of transparency in digital advertising: | Concerns that platforms do | | not provide sufficient data for advertisers to test against fraud and | | | understand what they are getting for their money, or to publishers to | | | understand bid behaviour and effectively commercialise content (Chapter | | | 5). | | | Conflicts of interest: | Google and some other intermediaries operate on | | buy and sell side of multiple auctions, leading to concerns around hidden | | | fees for both advertiser and publisher customers (Chapter 5). | | | Platforms should | | | provide sufficient | | | information to users, | | | both consumers and | | | businesses which | | | transact with the | | | platform. Platforms | | | should be open and | | | transparent in how they | | | operate their core | | | services. | | | Encouraging consumers to share too much data: | There are concerns | | that platforms do not make it easy enough for consumers to understand and | | | control what data they are agreeing to share (Chapter 4). | | ## Enforceability Of The Code 6.49 The code would give a regulator the power to order firms to comply with its findings following an investigation into a breach of the code. The regulator would be able to carry out own-initiative investigations, with powers of audit, scrutiny and transparency. It would also have a key role in hearing complaints and resolving disputes between industry players under the code. Where appropriate, the regulator would publish reports on its work and the industry more generally. 6.50 It would be important for the code to be directly enforceable by the regulator so that there is a strong deterrent to breaching the code and urgent issues can be dealt with. The regulator would therefore need the power to investigate effectively - this may include the power to: - compel information from SMS firms (and other industry players where necessary to fulfil the code's objectives); - suspend decisions of SMS firms pending the result of an investigation, including the imposition of interim measures; - block decisions of SMS firms at the end of an investigation; and - appoint a monitoring trustee to monitor and oversee compliance by an SMS firm. 6.51 We would be interested to hear views on whether the regulator would need to be able to direct SMS firms to implement, or reverse, measures for the purpose of fulfilling the objectives of the code. We would also be interested to hear views on whether a breach of orders under the code should be subject to other sanctions such as financial penalties (and if so, what impact that might have on the speed and effectiveness of the regime, including any appeal process). 6.52 We would expect that there would be a right of appeal by the SMS firm or other materially-affected person against decisions of the regulator, but that this could be applied in a much more timely manner and to a different standard than applies for competition enforcement, as the objectives of the code would be undermined if its enforcement was not timely. ## Relationship With Other Initiatives 6.53 We note that the broad content of the code suggested above covers a number of the areas of concern set out in Cairncross Review into the sustainability of journalism. The Review set out a proposal for codes of conduct to rebalance the relationship between online platforms and publishers, subject to the oversight of a regulator, covering a range of areas including transparency over fees and ranking algorithms and forewarning of significant changes to algorithms. While our study has not focussed explicitly on the sustainability of journalism, there is an overlap between the proposed provisions of the code set out above and the proposal for multiple codes in relevant digital markets under the Cairncross Review. Government may therefore wish to note these synergies with the potential code of conduct set out above in considering how to take forward this element of the Review's recommendations. ## Other Rules Applying To Sms Platforms 6.54 Other rules and regulations not explicitly covered by the code could apply to SMS platforms. 6.55 The interaction between a code for SMS platforms and the UK mergers regime was considered by the Furman Review. As recommended by the Furman Review, we are currently updating our own Merger Assessment Guidelines to better reflect our understanding of how digital markets function and recent practice in our assessment of mergers, including in the digital space. We are also continuing to reflect on, and to put into practice where appropriate, the learnings identified in the report we commissioned from the economic consultancy, LEAR on the ex-post assessment of previous digital merger investigations. We will keep under review whether there is a case for requesting changes to our existing merger control tools for companies designated as having SMS, or whether a parallel regime for acquisitions undertaken by such companies would be appropriate. 6.56 In addition, aspects of some of the potential interventions set out below, designed to address sources of market power, could be designed with reference to SMS. We note where this is the case in the discussion below. ## Interventions To Address Specific Concerns Under Themes 1 To 3 6.57 As discussed above, our initial view is that a code of conduct would bring benefits in the markets within this review, by helping to avoid behaviour on the part of platforms with SMS that might harm competition and consumers. 6.58 We have also considered a number of interventions that are designed to address specific concerns that we have identified under themes 1 to 3 of the study. These include, particularly in relation to themes 1 and 3, potential interventions to address sources of market power directly, by overcoming barriers to entry and expansion to increase competition. These largely draw on proposals that have been put to us by stakeholders in the course of the study, and include a number of types of intervention suggested by the Furman Review - in particular, data-related remedies - as well as remedies not directly considered by the Review, including structural measures. 6.59 We recognise that several of these would be major interventions, which have the potential to change the nature of competition substantially, and therefore need careful consideration. We are seeking views from stakeholders on the potential costs and benefits of these remedies, as well as on which, if any, of these remedies should be implemented as a priority either by the CMA or by a regulatory body in the future. 6.60 In this section we summarise the main interventions we are considering, to address the issues set out in Chapters 3 to 5 respectively. This summary is supported by Appendices I to M, which provide further details. ## Potential Interventions To Address Market Power In General Search 6.61 As explained in Chapter 3, we have found that the ability of general search engines to compete with Google is constrained by the need to overcome a number of barriers to entry and expansion, on both the supply and the demand side of the market. 6.62 On the supply-side, to produce independent search results, search engines must overcome: economies of scale in crawling and indexing; and scale advantages with respect to the number of search queries and the information gained from consumers' interaction with search. Google and Microsoft are the only two providers that undertake English-language web-crawling and indexing at a scale that can support a competitive search engine in the UK, and the greater scale of English-language queries seen by Google is likely to support its ability to deliver more relevant search results compared to its competitors, especially in relation to uncommon and fresh queries. 6.63 On the demand side, Google is the default search engine for most search entry points in the UK. These default arrangements harm competing search engines' ability to access consumers and are consistently described by these parties as the most significant barrier to growing their userbase, monetising their operations and improving the quality of their search results. 6.64 Finally, other search engines including Yahoo Search, DuckDuckGo and Ecosia access organic search results and adverts through negotiated agreements with Bing (in most cases) or Google. Both Google and Bing place restrictions on these search engines, such as how they can present search results to consumers. This makes it harder for these competitors to differentiate themselves and innovate, for example in developing their own algorithms or in approaches to presenting search results to consumers. ## Third-Party Access To Click And Query Data 6.65 Rival search engines have suggested that Google should be required to provide click and query data to third-party search engines to allow them to improve their search algorithms, thus helping to overcome Google's scale advantages. 6.66 Our initial view is that this intervention has the potential to overcome the data advantages that Google has on account of having a much larger userbase. In particular, it should allow rival search engines to provide more relevant searches to fresh and tail queries and could in principle lead to a situation in which several search engines are able to compete on relevance even for unusual queries. 6.67 However, there are significant challenges with such an intervention, which may radically change the nature of competition in the general search market. Google has expressed the concern that this remedy would create risks to consumers' privacy and potentially lead to a situation in which inappropriate parties could gain access to the data for the purposes of gaming Google's algorithm. We would welcome views on whether this intervention could be implemented in way that avoided these risks. 6.68 Further, the impact of this intervention on dynamic incentives needs to be given careful consideration. There is a risk, if an extensive range of data is required to be shared with third parties in a way that reveals aspects of Google's algorithm, that this will reduce Google's incentives to innovate and improve its algorithm. Our initial view is that the overall effect on competition is likely to be dependent on a number of factors, including the specific type of data to be shared (query data alone, click and query data, or click and query data and search results) and whether third parties are required to pay for access. We would welcome views on these issues. ## Mechanisms For Determining The Default Search Engine On Devices And Browsers 6.69 We have been struck by the very substantial payments that are made to be the default search engine on browsers and devices and the significant impact being the default search engine appears to have on consumer take up. Several stakeholders told us that Google's control over Android defaults and its ability to pay more than its rivals to be the default on browsers such as Safari is one of the most significant barriers to entry and expansion in general search. We have heard two broad proposals to address these barriers. 6.70 The first proposal we have heard is that there should be some form of restriction or limit on the ability of Google to buy default positions and/or a restriction on the ability of device manufacturers and browsers to sell defaults. Given the importance of defaults in search, such a restriction would be a major change in the sector. While this intervention may radically improve other search engines' ability to gain customers and in turn improve their algorithms, this would need to be weighed against any potential consumer harm arising from such restrictions, and the possible impacts on the costs of devices. 6.71 The second proposal concerns a potential requirement to offer choice screens to consumers on devices and browsers and rules regarding their design. We are aware that Google has recently introduced choice screens on all new Android phones and tablets in Europe, following the European Commission's Android case. There have been concerns around the design and implementation of these choice screens, including concerns that Google auctions slots to be on the choice screen and unduly restricts the number of slots to maximise its revenues from the auction. We have heard several proposals intended to restrict Google's ability to extract rent from these choice screens, including the use of non-monetary criteria to allocate slots and, more generally, greater involvement from a regulator in the design of choice screens. We have also heard proposals to extend the requirement to offer choice screen beyond Android devices. 6.72 We would welcome stakeholders' views on all these issues. ## Syndication Agreements 6.73 Some parties have suggested that Google should be subject to obligations to supply syndicated search results on FRAND terms, and that such terms should also apply to Bing when syndicating to much smaller search engines. We welcome views on the effect this would be expected to have on competition, and on how terms should be set, including whether prices could be set at a level that is low enough to provide an incentive to enter the market but high enough to reward providers of search results and maintain the incentive for third parties to develop their own web index. 6.74 These three potential interventions are likely to interrelate with one another. For instance, if a choice screen led to rival search engines receiving sufficiently high levels of search click and query data, then it may be the case that a data access remedy would no longer be required or proportionate. Another example could be that if provision of access to the web-index and search click and query data is successful at reducing the reliance of smaller search engines on syndication from Google and Bing, there may be no need to impose obligations on the form of such agreements. We therefore welcome views on the interdependencies of these remedies and whether a gradual, stepped approach to their introduction would be more appropriate, or conversely, whether these remedies would only be effective if rolled out together, as a package. 6.75 See Appendix J for a more detailed consideration of these potential interventions, and a list of specific consultation questions. ## Potential Interventions To Address Market Power In Social Media 6.76 We have found that Facebook appears to be subject to limited direct competition from close substitutes in the social media sector. Rather, successful entry in this sector over the last ten years has tended to be characterised by the development of more specialised consumer services that are clearly differentiated from Facebook. 6.77 The CMA is aware of calls for Facebook and Instagram (and possibly also WhatsApp) to be structurally separated, with the purpose of incentivising these large social platforms to compete with one another for user attention and for Instagram to challenge the market power of Facebook. Such an intervention, in principle, might lead Instagram to compete more closely with Facebook for users, and lead to greater choice for advertisers in social display advertising. The high degree of interoperability that currently exists between Facebook and Instagram could also be retained to the benefit of users. However, we recognise that a forced separation would also have significant costs and complexity, and it could lead to a loss in efficiencies for users. 6.78 As discussed in Chapter 3, Facebook faces limited competitive threat due to the strong network effects that it enjoys and which act as a barrier to expansion for its rivals in respect of services which are directly comparable to those of Facebook. Therefore, there is a risk that the structural separation of Facebook and Instagram would only deliver short-term benefits, with the market eventually tipping back to one supplier. However, users would at least enjoy the benefits of competition in the meantime, and other remedies such as interoperability measures could be brought into force to reduce the risk, and adverse consequences, of tipping. 6.79 A forced separation of Facebook and Instagram would clearly be a significant step to take, and it would require careful consideration. If other measures, such as the interoperability measures discussed in the rest of this section, are not successfully implemented, then it may be necessary to consider separation of Facebook.com and Instagram. We welcome views on this. 6.80 One way of achieving greater competition between social media platforms would be through increased interoperability with Facebook's large network of users. Interoperability requirements enable the positive network effects stemming from large userbases to extend to other platforms. We are considering the extent to which increased interoperability would improve outcomes in this sector and whether any specific features or functionalities should be subject to interoperability requirements. 6.81 Since interoperability involves some form of standardisation, there is a cost to mandating interoperability (potentially in terms of reduced innovation and variety in respect of the functionality that is standardised) as well as a benefit. Reflecting this, most stakeholders that we have spoken to in the first half of the study, including challenger social media platforms, have not supported socalled 'full protocol interoperability' in which all the functionality of social media platforms would be made interoperable. There has, however, been support for specific functions being made interoperable. 6.82 In principle, the case for interoperability is greater in respect of functionality which is both directly helpful in overcoming identified network effects and yet not highly innovative (or not recently innovative). We are interested in hearing views as part of this consultation as to which elements of functionality would be strong candidates for interoperability against these criteria. 6.83 In particular, we are interested in views on whether Facebook should be required to interoperate specific features of its current network with existing competitors, and if so which features or functions should be made interoperable and how this would increase competition amongst social media platforms. For instance, forms of interoperability which have been suggested are: - the ability to identify and make contact with friends or other potential contacts from other social platforms; - the ability to post content across several platforms simultaneously; - the ability to view posts from friends on other social platforms; - the ability to consolidate and view updates across social platforms, allowing consumers to search for content across their aggregated services in real-time; and - the engage with content by commenting or 'liking' it. 6.84 An illustration of a maximalist approach to social media interoperability, encompassing all the functionalities described above, is set out in Figure 6.1. We note that any increased interoperability will need to balance the potential to increase direct competition to Facebook in social media services against any adverse effects, as well as its overall impact on incentives to invest and innovate in this sector. We seek views on the size both of these potential beneficial effects and costs. Source: CMA. 6.85 We are also seeking views on whether there should be limits on Facebook's ability to impose restrictions on competitors' use of the interoperable features. We note that Facebook may wish to restrict competitors' ability to develop services that compete directly with Facebook. For example, it has previously included a clause in its Developer Policy, which stated: 'Add something unique to the community. Don't replicate core functionality that Facebook already provides'. This clause was removed in 2018, but similar clauses in the future could undermine the objectives of any interoperability remedy. 6.86 A further intervention we wish to consider is whether past API access should be restored. Facebook has told us that it operates a largely open source environment which has incentivised innovation by enabling developers to build complementary services based on the social network's existing systems. However, an interoperability remedy could seek also to facilitate the development of directly competing services. We understand that Facebook recently scaled back APIs which used to enable consumers to invite their friends to other applications or enable the cross-posting of content across platforms. We have been told that these deprecations have harmed competition in these markets, and we are interested in whether or how this level of access could or should be restored; 6.87 Finally, regarding the scope of any interoperability remedies, we are interested in views as to whether any rules requiring interoperability should be applied to Facebook only, or to other existing social media platforms. Potential new entrants would benefit from broader interoperability from social media platforms which have reached a scale which is large, albeit smaller than Facebook, particularly in terms of digital advertising revenue from social media. 6.88 See Appendix K for a more detailed consideration of these potential interventions, and a list of specific consultation questions. ## Potential Interventions To Give Consumers Greater Control Over Their Data. 6.89 In Chapter 4, we identified a number of factors that undermine consumer control over the use of their data. These include: restricted choices, with some platforms not allowing consumers to turn off personalised advertising, and difficulties in exercising choice, due to defaults that nudge consumers into accepting data extraction, and the complexity and length of privacy policies. Consumer engagement with privacy policies and controls is correspondingly low. 6.90 In this section, we set out potential interventions designed to give consumers greater control over their data. By empowering consumers, most of these interventions should serve both to promote competition and protect privacy. We welcome views from a wide range of stakeholders on the case for these interventions, and the impact they might be expected to have. 6.91 We note that there is a wide range of existing regulation in respect of personal data, including the GDPR and PECR, which are enforced by the ICO in the UK and the DPC for some multinational platforms including Google and Facebook which have their main establishment in Ireland. In the context of this regulatory landscape, the interventions discussed below could take a variety of forms, including: - engagement with the ICO, DPC or (and indeed the courts who ultimately decide these questions) regarding the interpretation of existing legislation and prioritisation of enforcement action324; - recommendations to the UK government to legislate to strengthen the current regulatory regime;325 and - direct action by the CMA using the order making powers available to it through a market investigation. 6.92 For each of the main interventions discussed below, we consider which of these forms would be most appropriate. The potential interventions relate to five main areas: - giving consumers a choice over personalised advertising; - changing defaults for personalised advertising on SMS platforms; - imposing a fairness by design duty on all platforms with an additional duty on SMS platforms to ensure they test the design of their services; - designing regulations that work for small, as well as large, companies; and - options for the future: data mobility and privacy-preserving technologies. ## Giving Consumers A Choice Over Personalised Advertising On All Platforms 6.93 We noted in Chapter 4 that several social media platforms, including Facebook, do not give consumers full control over their data by allowing them to turn off personalised advertising. Rather, accepting personalised advertising is a condition of using the platform. We have considered whether platforms should provide consumers with more control over the use of their data, by giving them a choice over whether to receive personalised advertising or not. 6.94 We would welcome views on whether all platforms should be required to give consumers an option to use their services without requiring in return the use of consumers' data for personalised advertising. In practice, this would mean that the consumer could go to their settings on the platform and turn off personalised advertising. 6.95 Under such an approach, platforms would still be able to offer advertising as a precondition of using the service - this intervention would not allow consumers to turn off advertising altogether. If consumers chose not to receive personalised advertising, they would instead receive other nonpersonalised advertising, such as contextual advertising based on the content they are viewing. 6.96 To strengthen the control that consumers have, we are also seeking views on the principle that irrespective of whether or not a consumer has turned off personalised advertising the core service they receive will be the same, with only the nature of the advertising content being varied. 6.97 A further important question in considering such an intervention is whether platforms should be able to offer incentives to consumers to accept personalised advertising, such as offers, reward schemes, payments or a reduced number of ads. Our initial view is that it is important that platforms do have the ability to offer such incentives, as this provides a mechanism by which consumers can benefit more fully in the value of their data and attention, and in turn, this may encourage greater consumer engagement in the future and promote competition. There should be no detriment for consumers who choose not to receive personalised advertising, meaning that such incentives should not affect the core service being provided. 6.98 We recognise that this would be a significant intervention for those companies that do not offer such a choice currently, and we would need to think carefully though the implications of such a change. In particular, there may be significant financial implications for platforms, given the evidence discussed in Appendix E that suggests that targeting with consumer data can have a substantial impact on the value of inventory, and would need to be weighed up against the privacy and control-related benefits of the intervention.326 This financial impact would be driven in large part by the proportion of consumers who would choose to opt in to personalisation, and we would be interested to see any evidence that may shed light on this question.327 6.99 Facebook told us that personalised advertising leads to a better consumer experience as it leads to more relevant advertising that the consumer is more likely to find genuinely useful. It therefore argued that restricting personalised advertising may lead to consumer harm. We agree that many people may prefer personalised to purely contextual advertising, and may therefore not choose to turn off personalised advertising - but we do not consider this to be a strong argument for restricting consumers' ability to choose. 6.100 Our current view is that such an intervention, if introduced, should apply to all platforms, including notably the four social media platforms, Facebook, Instagram, Snapchat and Twitter, which, as noted in Chapter 4, do not currently provide a choice to consumers over whether to accept personalised advertising. To date, we have not yet considered whether a similar obligation should apply to publishers, such as newspapers, and will consider this in the second half of the market study. We also welcome views on whether the choice to turn off personalised advertising should apply more broadly. 6.101 We have also considered the legal context for this type of intervention. As discussed in Chapter 4, our initial view is that requiring consumers' have control over whether their data is used for personalised advertising is consistent with the emerging interpretation of GDPR that 'consent' is the appropriate lawful basis to process personal data for personalised advertising. We have, for example, noted that there is an open statutory investigation by the DPC into 'whether Facebook has discharged its GDPR obligations in respect of the lawful basis on which it relies to process personal data in the context of behavioural analysis and targeted advertising on its platform'.328 6.102 Enforcement and the appeals process through the courts may, therefore, establish in the coming years that GDPR requires consumers to be in control of whether their personal data is processed for personalised advertising, as proposed under this potential intervention. 6.103 However, in the same way that we consider there is a role for ex ante regulation in this space alongside competition law, we think there may be good reasons for providing clarity now that consumers must be given this control, by having the choice not to have their data used for personalised advertising whilst still receiving the core service. This could be set out in UK legislation, and enshrined in an enforceable code of conduct or another instrument.329 We welcome views on these issues. ## Changing Default Settings For Personalised Advertising For Sms Platforms 6.104 We have also considered whether SMS platforms should have additional duties to ensure that consumers are making fully informed choices about personalised advertising. 6.105 We welcome views on whether SMS platforms should be prevented from using personalised advertising by default, but instead be required to present consumers with a clear and open choice up front - with a 'yes' and 'no' option available - on whether to accept data collection for personalised advertising purposes. 6.106 Under this approach, the choice screen or upfront notice would require consumers to make a choice about the collection and use of their data for personalised advertising, and platforms could not serve personalised advertising until the consumer had actively clicked 'yes'. These rules would apply to SMS platforms, ensuring that all consumers on SMS platforms made active choices over the use of their data for personalised advertising. Consumers could also receive periodic reminders about their choices. 6.107 Where large platforms rely on consumer consent, we think there is a sound basis for holding SMS firms to a high standard in terms of securing consent from consumers which is 'freely given and informed'. Since SMS firms have market power, there are likely to be circumstances in which consumers have little meaningful choice of whether to use the platform, resulting in an imbalance of power between controller and consumers, necessitating special measures to ensure consent is 'freely given'.330 However these rules to give consumers control over their data by default would apply to all large platforms, irrespective of whether or not they currently rely on another basis for processing personal data, such as contract, as discussed above. 6.108 As shown in Figure 6.2, under such an approach, if a consumer selected 'yes' they would receive personalised advertising, periodic reminders about their choice so they remain aware that they are receiving personalised advertising, and have an easy way to change their choice and turn it off. Alternatively, if a consumer selected 'no', no data about them would be used for personalised advertising and they would continue to receive non-personalised advertising, such as contextual advertising. They will receive the same level of service and have an easy way to change their choice and turn personalised advertising on. ## Imposing A 'Fairness By Design' Requirement On All Platforms 6.109 For consumers to have genuine control over their data, they must not only have a choice in principle as to whether to provide or withhold access to it - they must also find it easy to exercise that choice freely in practice. We have seen in Chapter 4 how platforms use defaults, choice architecture and other behavioural nudges to encourage consumers to provide consent for the use of data. We have seen in particular the power of defaults in these markets: where consumers are presented with a more prominent option, ie a form of default option, then the majority tend to choose that default option and do not amend their settings. 6.110 To ensure that consumers have genuine control over their data, we have considered whether an intervention is required to ensure that platforms do not nudge consumers into decisions that they may not have made if given a free choice or make it difficult for them to exercise choices, such as placing controls in obscure places on the platform and/or several clicks away. 6.111 In principle, and as set out in Chapter 4, there are many dimensions of choice architecture that could be adjusted to help consumers make the right choices, including the use of defaults, the prominence given to choices to accept or decline data use, ease of access to privacy controls and the length and ease of understanding of privacy policies.331 6.112 For many of these dimensions, there is an active debate within the data protection community about which option is 'best' for facilitating informed consent. For example, in relation to the question of 'bundled' consents, we think it is likely that consumers will find it easier to consent once for an appropriate variety of linked data purposes rather than many times. However, we note this practice is potentially in tension with the principle that consent should be 'specific' (which would imply that multiple, more granular, consents should be sought). 6.113 In the light of these uncertainties, we think that, rather than making prescriptive rules on each of these dimensions, which may soon become redundant and/or lead to unintended consequences, a better approach would be to set out high level principles that platforms would be required to implement. 6.114 Our initial view, therefore, is that **there is a good argument for introducing** an overarching 'fairness by design' duty on platforms in the design of their data collection practices to complement the GDPR 'data protection by design' duty.332 This would put a duty on platforms to ensure fairness in the design of data collection processes (including by facilitating informed consent by consumers) and would allow early intervention by a regulator / consumer authority to ensure that the duty is adhered to ex ante at the design stage rather than purely ex post enforcement (as under current consumer protection powers). 6.115 It would be for the relevant regulator to set the high-level basis of compliance with this principle. Options include: - 'neutrality' (the presentation of choices to consumers in a neutral way, so as to avoid bias); - 'minimising friction' (making it easy to access controls and change them); and - 'engagement and understanding' (seeking to ensure that customers understand and are comfortable with the options available to them on an ongoing basis).333 6.116 Our initial view is that a fairness by design duty along these lines could apply to all platforms. To date, we have not yet considered whether a similar obligation should apply to publishers, such as newspapers, and will consider this in the second half of the market study. 6.117 In addition to the overall fairness by design duty, we also welcome views on whether platforms with SMS should have an additional requirement to trial and test the choice architecture they adopt. The results of such rigorous testing could be reviewed by the appropriate regulator to ensure that the design and choice architecture used is fully informed by rich evidence on how consumers behave. As noted in Chapter 4, we were surprised to find out how little testing is done by platforms in relation to consumer control over data and use of privacy settings, which stands in stark contrast to the very extensive trialling done on a daily basis in other parts of the business. This intervention would address this gap, by using the analytical capabilities and huge reserves of data available to platforms to empower and protect consumers. 6.118 At this stage, we think that such an intervention should apply to platforms with SMS status and the rules could therefore form part of the code of conduct. This is partly on proportionality grounds - since the costs of extensive trialling and testing may be disproportionate for small platforms and publishers. In addition, as noted above, since SMS firms have market power, there are likely to be circumstances in which consumers have little meaningful choice of whether to use the platform, resulting in an imbalance of power between controller and consumers. This provides a justification for special measures to ensure 'freely given consent' for SMS platforms. ## Designing Regulations That Work For Small As Well As Large Companies 6.119 As noted in Chapter 4, we have heard concerns that aspects of the design and interpretation of current data protection regulation risks creating competition concerns by unduly favouring the business model of large, vertically-integrated platforms over smaller, non-vertically-integrated publishers. 6.120 For example, we have observed that the GDPR may incentivise firms that operate services which rely on using a consumer's personal data at different levels of the supply chain to vertically integrate. We have heard concerns that a vertically integrated firm, or a conglomerate firm, can much more easily secure consent from the consumer of personal data for multiple purposes through a single process which is then applied across its businesses to combine and process personal data. Smaller, non-vertically-integrated competitors have told us this approach creates a competitive disadvantage for them, since they require granular, specific and informed consent for each step. We have seen evidence of integration in this market. 6.121 Further, we have heard concerns that the GDPR potentially raises a fundamental question about the lawfulness of processing within the current disaggregated open display market on which many publishers depend, since it relies on an individual consenting to share data with a large number of organisations at once, and such consent cannot be considered to be freely given and informed. 6.122 We are mindful that the GDPR, and the data protection authorities responsible for enforcing it, have a duty to protect consumers' privacy. However, we think it is very important for competition and data protection authorities to consider jointly the interface between consumer, competition and data protection law, as this is likely to produce the best outcomes for consumers in assessing conduct with overlaps across these regimes. Such cooperation is particularly important at the current time, when the interpretation and practical application of GDPR is still evolving. 6.123 We have had constructive engagement in this study with the ICO, and it is in this context that we offer some views on factors that we think should be taken into account when deciding how to prioritise enforcing the GDPR. We would welcome comments on these initial views. 6.124 In relation to the concerns about the current open display market, we welcome the pragmatic approach that the ICO has taken to date on this topic, reflecting the importance of this market for newspapers and other content providers. We also recognise the security concerns arising from the sharing of data between multiple firms and think that DPAs could facilitate and enable appropriate sharing of data between firms by prioritising support for the development of codes of conduct334 and certification regimes335 under the GDPR which would facilitate the secure sharing of a consumer's personal data. 6.125 For example, with this infrastructure in place, a consumer would be able to choose to use a publisher website, having seen that the advertising consent option has (for example) an established quality mark, and provides that the named advertising providers are all members of an effective certification regime which complies with a recognised GDPR compliant code of conduct. 6.126 Such a system would reduce the benefits to a firm from vertically integrating: the perceived incentives in the market may be quite different once this GDPR infrastructure is in place, particularly if enabled in a pro-competitive manner. 6.127 In the medium term we think it would also be helpful if DPAs, the EDPB and the European Commission were open to exploring the extent to which mechanisms, at application, browser, system or device level, can be supported or adopted to give effective control to consumers, by balancing the need for specific, informed and granular consent, against the risk of consent fatigue. We think this could in principle both benefit consumers and ensure neutrality in respect of larger and smaller firms seeking data. 6.128 An example of this sort of approach is in the Commission's original draft of the proposed ePrivacy Regulation,336 and the accompanying impact assessment, which observed that 'end-users are overloaded with requests to provide consent', and intended to 'empower end-users' via 'centralising consent'. The draft proposal called for a 'Regulation [which] enhances end-user's control by clarifying that consent can be expressed through appropriate technical settings': Article 9(2) 'where technically possible and feasible, … , consent may be expressed by using the appropriate technical settings of a software application enabling access to the internet.'337 6.129 These are intended as illustrative examples of interpreting GDPR and adopting an approach to prioritising enforcement which seeks to achieve consistency between different business models in the market, which in the long term will help give consumers greater choice and keep them in control. We welcome views from stakeholders on these points. ## Options For The Future: Data Mobility And Privacy-Enhancing Technologies 6.130 Finally, we consider two contrasting future developments that could help protect privacy, increase competition and ensure that consumers can benefit to a greater extent from the value of their data. These are: mechanisms for increasing data mobility, which would allow consumers to share the data that platforms hold on them with other platforms; and privacy-enhancing technologies, which would reduce the extent of data collection for digital advertising by shifting a significant proportion of the data processing to the device itself. 6.131 Both of these approaches have promise, but neither have yet taken off at scale. In this section we describe each approach, set out the potential benefits and explain what regulatory action may need to be taken to encourage their adoption. We welcome views from stakeholders on the case for pursuing either or both of these approaches, and whether these approaches may be usefully combined. - Data mobility 6.132 GDPR is not only about data protection. Article 20 of the GDPR introduces a new right of data portability, which allows for data subjects to receive the personal data that they have provided to a data controller, and to transmit this data to another data controller without hindrance. 6.133 The Furman Review recommended that its proposed Digital Market Unit should pursue a related concept of personal data mobility where this will deliver greater competition and innovation. It said that personal data mobility would 'give consumers greater control of their personal data so they can choose for it to be moved or shared between the digital platform currently holding it and alternative new services.' The Review noted that 'Open Banking has shown the potential for data mobility to provide new opportunities to compete and innovate in this way.'338 6.134 There have been some attempts to implement versions of data mobility in the markets within our scope, notably through an initiative called the Data Transfer Project (DTP),339 a joint exercise between Google, Facebook, Microsoft, Apple and Twitter to allow individuals to move their data between online service providers whenever they want. Further information about the Project is set out in Box 6.1 below and Appendix K. 6.135 We welcome this initiative, as it should help consumers do a variety of useful things, such as transferring photos from a social media platform to a photo book service or transferring music playlists. However, given the current use cases proposed by the DTP, we think the initiative on its own is unlikely to be transformative at improving competition. ## Box 6.1: Data Transfer Project The Data Transfer Project (DTP) was launched in 2018, with the stated aim of creating an open-source, service-to-service data portability platform so that all individuals across the web could easily move their data between online service providers, in a seamless, direct, user-initiated manner. The contributors to the DTP include both Google and Facebook, as well as other large digital platforms such as Microsoft, Twitter and Apple. These contributors have stated that they consider data portability and interoperability to be central to innovation and that this initiative will facilitate competition, empowering individuals to try new services and switch between suppliers. The DTP has sought to illustrate its potential benefits with some illustrative case studies such as: - Transferring photographs from a social network to a photo printing service; - Moving music playlists from one streaming service to another; and - Transferring loyalty card data between retailers. Stakeholders' views on the DTP as well as our initial assessment of the possible effectiveness of the DTP, and data mobility more generally, at improving competition within social media, are provided in Appendix K. 6.136 We have considered other proposals for more radical forms of data mobility in digital advertising markets, that have the potential to give consumers greater control over the use of their data and a greater share in its value. In particular, we have considered proposals put to us about products such as Personal Information Management services (PIMs) and Personal Data Stores (PDS) which may improve privacy protection and also enhance competition in the provision of services which rely on data to be effective. 6.137 The different ways in which this approach to data mobility could work are set out in detail in Appendix L, but at a high level, it would enable the consumer to instruct a platform or an intermediary to share the information held on them with either the publisher of a site they were visiting or with an intermediary. The consumer would instruct the intermediary to share some or all of that data with parties they had specified, for specified purposes and for a set period of time, and for which the consumer would receive monetary or other incentives. The intermediary would create a consent dashboard for the consumer enabling them to vary or revoke their consents whenever they chose to do so. This could therefore form part of a long-term solution to the problem of consent fatigue. 6.138 We have engaged with a variety of PIM businesses, which in principle could play a comparable function to the new banking intermediaries using Open Banking, and mirror the ongoing development in the utility sectors of services which negotiate good deals on customers' behalf. However, it seems to us that these services have a long way to go to be commercially viable. 6.139 There are a number of reasons for this and a potential role for regulation in addressing these issues. First, Article 20 of the GDPR states that the right to data portability applies to personal data provided to the controller by the data subject, and therefore does not cover 'inferred' or 'derived' data - whilst the GDPR as a whole applies to derived and inferred data where it is personal data, the specific right in Article 20 does not (for example, regarding 'derived' data, an individual could make a subject access request but not a portability request).340 These data sharing requirements may therefore need to be strengthened. 6.140 Second, the PIM may find it difficult to create the right incentives for advertisers and consumers to participate: consumers would be unlikely to sign up unless advertiser-funded incentives were available, but advertisers would be unlikely to use a PIM until sufficient customers had joined. Some of the regulatory changes we have discussed above may start to create stronger awareness of the value of their data among consumers and stronger incentive to engage in such initiatives in the future. 6.141 There is also a potential role for a future regulatory body in providing certain safeguards which support confidence and data security for approved intermediaries, then it is an area where innovation could develop. We discuss these services further in Appendix L. We would welcome views on whether this form of data mobility has merit in principle, and what if any form of regulatory intervention is required to support it. ## - Privacy-Enhancing Technologies 6.142 In the current system, data generated by consumers can be used to track their identities across online and offline activities, serve individually targeted ads, and measure how these ads affect their behaviour. For these purposes, data gathered from consumers' devices is processed remotely by various actors in the supply chain. 6.143 Privacy-enhancing technologies (PETs) are a class of technologies that seek to mitigate privacy risks associated with the collection, transfer, and analysis of data, while still allowing for useful results to be obtained from said data. PETs encompass a wide range of approaches, with different degrees of maturity and applicability. 6.144 One particular type of PET, client-side (or on-device) PETs, seek to shift a significant proportion of the data processing to the device itself, reducing the amount and granularity of the information that gets transferred away from it. In this way, the ability of ad tech actors to identify and profile individual consumers during their online activity is potentially curtailed. Nevertheless, these approaches preserve some of the ability for advertisers to provide ads that are targeted to consumers' interests. The fundamental difference is that a higher proportion of the processing (eg assigning consumers to segments or matching impressions to ads) happens on the device, rather than remotely. 6.145 The attraction of these approaches in principle is that they can potentially be implemented without compromising the free ad-supported model that underlies a significant proportion of online content creation by publishers, while reducing the need of large-scale data collection, storage, and resale with digital advertising, which can constitute a significant challenge to privacy. 6.146 A version of this approach has been proposed by Brave, which recently launched a new advertising platform that operates on top of Brave browser. The platform pushes to the consumer's devices both a catalogue of ads and a targeting model, which is used to decide which ads from the catalogue are to be shown. In this way, no data about the consumer's identity or browsing habits leaves the device. Consumers are rewarded with 70% of the gross ad revenue, in the form of 'Basic Attention Tokens'. These tokens can be transferred by consumers to publishers and content creators of their choice. 6.147 To achieve roll out of these approaches at scale, there may be a case for regulatory intervention to facilitate coordination around an appropriate set of privacy-preserving standards. In particular, since most proposed privacypreserving approaches in digital advertising are implemented in browsers, having these technologies rolled out by default in commonly used browsers and devices would provide a powerful incentive for publishers and advertisers to adhere. This could potentially be directly mandated as a standard. 6.148 There is a possibility that many of the functions of a PIMS provider (discussed above in the section on data mobility) may be performed on-device, and thus combining the features of both PIMS and privacy-enhancing technologies. 6.149 Again, we would welcome views on whether the potential costs and benefits of client-side privacy-enhancing approaches (or indeed, other types of PETs that are applicable to online platforms and digital advertising), and whether any regulatory intervention is desirable to facilitate their development. 6.150 See Appendix L for a more detailed consideration of these potential interventions, and a list of specific consultation questions. ## Potential Interventions To Address Concerns Around Transparency, Conflicts And Market Power In Digital Advertising Markets 6.151 As set out in Chapter 5, our initial view is that Google and Facebook's market power in the sale of their own advertising inventory could lead to worse outcomes for advertisers in search and display advertising respectively, ultimately leading to worse outcomes for consumers. The main sources of this market power appear to come from barriers to entry and expansion on the consumer side in search and social media. We have set out above the possible ways that these barriers might be addressed. However, Chapter 5 also identified specific features of the digital advertising market which might exacerbate the concerns about outcomes for advertisers and publishers. 6.152 In the open display market, we noted Google's strong position stemming from its access to advertising inventory and user data, combined with its very high share of supply in publisher ad serving and other parts of the ad tech chain. This leads to potential concerns about: - conflicts of interest between Google's role on the buy and sell sides of the open display market; - its ability to exploit lack of transparency in costs and fees in advertising intermediation to increase returns; and - the potential for Google to leverage its market power from its owned and operated advertising inventory into the open display market and to foreclose potential competitors in advertising intermediation. 6.153 We also noted specific concerns from publishers about lack of transparency over fees in the open display market. This may limit the extent of competition between SSPs, reduce the competitive pressure faced by DSPs, and lead to publishers earning lower overall revenues from selling their advertising inventory. 6.154 More generally, we identified a series of broader issues relating to lack of transparency and the data advantages of the large platforms which could limit competition in digital advertising: - the large platforms' processes for auctioning inventory are not transparent and there is limited ability to independently verify the effectiveness of advertising because of lack of access to data; and - the data advantages of the large platforms in targeting advertising means they can monetise their content much more effectively than other platforms/publishers, increasing their market power. 6.155 We expect that a code of conduct as discussed above may in the short-term be the most effective way to address some of these problems. It could require platforms to trade on fair and reasonable terms, including a reasonable transfer of data to and from the platforms. In the open display market, the code of conduct could require platforms not to prefer their own customers over third parties who use other intermediaries. A code of conduct could also resolve disputes about how Google runs its ad tech auctions, for example requiring Google's auctions to give equal treatment to Google and third-party exchanges. 6.156 However, a potential limitation of a code of conduct is that it may not restrict all of Google and Facebook's incentives to exploit the market position that they have built up to their own advantage. A code of conduct can set rules that restrict certain behaviours, but in a fast moving and very complex market such as digital advertising it may be difficult for the regulator to monitor every change that is made by the incumbents. 6.157 We therefore consider in this section the case for additional interventions, over and above a code of conduct, designed to tackle directly the lack of transparency and conflicts of interest that we have observed. We consider first potential separation remedies and then remedies to improve transparency. ## Options For The Separation Of Integrated Platforms 6.158 One of the more intrusive remedies available to competition authorities and regulators is to require vertically integrated firms to separate their businesses to address competition problems that arise from operating in multiple markets. The idea of 'breaking up' the large tech firms has been highlighted in some submissions to us, as a way to limit the effects of market power across the multiple markets in which they operate. 6.159 Separation, and particularly ownership separation, has the potential to deliver significant benefits in markets where one large player is able to affect the proper working of competition across a number of markets. In such circumstances, separation can be most effective where it can be used to reestablish a more effective competitive process, which can bring new products to consumers and lower prices to businesses. 6.160 We have considered the case for interventions to separate aspects of the businesses of large integrated platforms, encompassing a range of options from accounting and management separation to full ownership separation. We are aware that the threshold for such interventions is high and that we need to think very carefully about the likely costs and benefits arising from them. Our aim in surfacing these options now is to attract views from a range of affected stakeholders on these questions. 6.161 We have received several representations that there is a strong case for separating aspects of Google's vertically integrated business in the intermediated open display market. This is an area where our analysis suggests that there are material conflicts of interest arising from Google's position on several sides of the market and where we have heard a range of concerns from market participants about Google's incentive and ability to leverage its market power to undermine competition. Accordingly, this has been the main focus of our assessment. 6.162 Recognising that conflicts of interest in the intermediated open display market are not limited to Google, we have also considered whether separation might also be appropriate where other firms operate in conflicting parts of the value chain, such as those operating both demand-side and supply-side platforms. 6.163 We are seeking views on the potential benefits and costs of the following interventions, which represent different forms of separation in the intermediated display market: - whether Google should be required to separate its publisher ad server or operate this service independently; - whether Google and other platforms operating both a DSP and an SSP should be required to separate these activities to avoid a conflict of interest; and - whether Google should be required to separate the operations of its advertising business from certain aspects of its data businesses. 6.164 These are illustrated in Figure 6.3. Source: CMA. 6.165 In relation to the first of these options, we understand that Google Ad Manager has a share of supply of over 90% for publisher ad serving. Publishers tell us that Google uses its publisher ad server to exercise control over the auction process for intermediated display advertising and favour its own businesses. The potential benefit of separation would be to address this conflict of interest and associated self-preferencing behaviour, strengthening competition in the intermediated market. There would also be potential costs, arising from the loss of efficiency gains from Ad Manager integration. 6.166 More broadly, if Google were required to establish a separated and independent publisher ad server, it is likely that this would change the competitive dynamics in this part of the ad tech value chain quite substantially. Publishers told us that Ad Manager (which currently integrates ad server and exchange functions) is a high quality product, which compares well with other ad servers in terms of reporting and integration with demand. We have also heard that there are some benefits in the integration of ad server and exchange functions in Google Ad Manager, including operational efficiencies, more effective yield management and reduced impression loss. The consequences of a separation involving Ad Manager for how publishers procure advertising would therefore need to be carefully assessed. 6.167 A further option for addressing concerns around conflicts of interest in publisher-facing services would be to require separation of SSP and DSP services. Google operates its SSP and DSP services together and determines the rules of multiple auctions in a way which works for both its SSP and DSP businesses, as do some other ad tech intermediaries. Both customers and competitors have suggested this may represent a conflict of interest, as the SSP and DSP should be acting independently, in the interests of publishers and advertisers respectively. The benefit of separation here would be to address the conflict of interest and potential for arbitrage behaviour arising from it, while we would also need to consider potential efficiency losses from separation. 6.168 Finally, the analytics parts of Google's business could in principle be separated from the rest of Google's advertising business. Currently, Google has a competitive advantage over third-party advertising firms because it has access to more data than any of its competitors, gathering data through its user-facing services, Android and its analytics businesses including Google Tags. Separating Google's analytics business from its other activities could help to address these competitive advantages and also deal with a number of concerns relating to conflicts and a lack of independent verification of outcomes in the market. 6.169 At this stage, this appears to be the most challenging option for separation, given the extent of integration of these aspects of Google's business. As an alternative, and subject to privacy considerations, Google might be required to offer analytics services to third parties on comparable terms. A remedy which required Google to provide access to certain data where only Google currently has access would need careful design, but if it could be made to work, it could be positive for competition and innovation in digital advertising. 6.170 There are multiple forms of separation, each of which could apply to the above options. Full ownership separation ('divestiture') is the strongest form of separation, which requires the owner of the common businesses to first separate and then sell one of the businesses to be separated. This remedy is sometimes used in merger control and has the advantage of being clear-cut and requiring no ongoing regulatory supervision. Where separation is expected to result in a significant increase in dynamic competition and innovation, divestiture is most likely to achieve these benefits. However, we are conscious that a remedy of this type would be likely to have significant impacts on other markets outside the UK and may need to be coordinated with other authorities internationally. 6.171 Operational separation, sometimes called ring-fencing, is a less intrusive version of separation, which requires firms to put in place measures which ensure that different businesses operate independently. This could include internal measures such as separate management responsibility, separate incentives, requirements to trade at arms-length, or even physical separation of different activities. Under operational separation, there would be no obligation to divest either of the separate businesses, and operational separation therefore relies on a common owner having limited ability to control the behaviour of the separated businesses that it owns. Operational separation is sometimes used by utility regulators seeking to ensure that incumbent businesses do not favour their own businesses operating in competitive markets.341 A more limited form of ring-fencing is also used in markets such as financial services, where there are legal requirements on buy-side and sell-side operations to act independently. 6.172 Our initial view is that operational separation may be feasible in respect of Google's ad server or SSP businesses, which we understand already both trade with both Google's own digital advertising businesses and third-party digital advertising intermediaries. An operational separation would include a requirement on Google to treat these internal and external digital advertising businesses consistently.342 In practice would require ongoing monitoring and evaluation by a regulatory body, and there would be challenges in designing the operational separation. In particular, defining a form of operational separation and a definition of equivalent treatment between Google's own businesses and third parties may be difficult. It is likely that operational separation would need a combination of regulatory oversight and also some changes in how Google operates to be truly effective. 6.173 A more limited form of separation is accounting separation, which is designed to ensure that the separated entities are required to report as if they were independent firms, with the intention that it would also encourage the firms to act independently. Accounting separation is normally imposed alongside other remedies such as mandatory access or operating separation. We expect that accounting separation could be required if we or a future regulatory body were to implement the operational separation or access requirements which we have identified in this section. 6.174 We would welcome views on each of these options and on the appropriate timescales for any interventions. For example, we would welcome views on whether we should consider separation options in the near term, or only once the code of conduct has been in place for a sufficiently long time to establish whether it is sufficient for dealing with the concerns we have identified. ## Access To Inventory 6.175 One of the issues identified by a wide range of stakeholders was that an additional advantage Google has in digital advertising intermediation is that it has preferential access to its own inventory. A number of participants have expressed concerns about Google's decision to offer its YouTube inventory only through its own DSP, which also participates in the intermediated display and video digital advertising markets. 6.176 An effective code of conduct could address most of the issues that we are aware of relating to Google's inventory. It could address concerns that Google does not offer comparable access to third parties when it auctions this inventory in the open market. The code of conduct might not however address the concern that Google does not offer YouTube inventory at all in the intermediated market, even though the display and video advertising on YouTube is comparable to those on other publishers' websites. Until 2016, Google offered at least some of its YouTube inventory to third-party intermediaries. We welcome views on whether Google could be required to offer access to some or all of its YouTube inventory on reasonable request to third-party DSPs. ## Interventions Addressing A Lack Of Transparency In Digital Advertising 6.177 We are also considering the case for specific interventions to address the concerns that digital advertising markets do not work well because there is insufficient transparency for advertisers and publishers. Some of these could be particular obligations on SMS platforms to comply with rules, where there is evidence that their behaviour is driving the lack of transparency, while others might apply to all firms. 6.178 We would welcome views on the following interventions, drawing on views we have heard in the first half of the study: (a) A requirement to provide transparency over fees charged for intermediary services. Both publishers and advertisers have raised concerns that there is an 'ad tech tax' imposed by intermediaries which is hidden by the existence of multiple auctions and the lack of evidence linking what is paid by advertisers for digital advertising to what is received by publishers. A rule requiring all intermediaries to disclose evidence as to the fees that they extract from the process of buying and selling digital advertising could enhance trust and transparency in the sector; (b) A requirement to apply a consistent transaction ID for each digital advertising transaction to allow more effective monitoring and verification. Advertisers have said they are frustrated by the challenges involved in identifying what they are buying when they purchase digital advertising, how they can be sure that advertising is properly verified and not fraudulent, and how they can assess the return on investment for what they are buying. In turn, publishers have expressed concerns at recent moves to reduce the transparency of bid data. We understand there are a number of initiatives to move towards industry standards in respect of transaction IDs, and welcome views on whether these could be made to work across the sector; (c) A requirement to provide sufficient data to allow for effective ad verification and attribution analysis. We are told that some platforms and other intermediaries do not provide enough data to advertisers or publishers to properly understand the effectiveness of ad campaigns. Platforms may be able to provide extensive information about attribution, but will not provide the underlying data to allow the advertisers or intermediaries acting on their behalf to interpret that information. A rule which specified what data should be provided, at least by SMS platforms, may improve trust in the information which is provided on the effectiveness of different forms of digital advertising; (d) **Sharing of bid data with publishers.** Google Ad Manager is the ad server for the large majority of publishers. We have heard concerns about the level and quality of information provided to publishers relating to bids for inventory, and the fact that this has recently been reduced. While there are some competition concerns to be considered, in principle, a requirement to provide better quality data to market participants could improve both trust in the outcomes of the auction process and the ability of publishers to plan their approach to managing and monetising future digital advertising inventory. We are seeking views on what data it is reasonable to expect Google and other intermediaries to share with the publishers of digital advertising. 6.179 While the above interventions would involve the provision of data to market participants, we have also considered whether in some cases, notably where the provision of data would raise privacy, competition or fraud concerns, trust might be increased through allowing a regulator to carry out scrutiny on behalf of market participants. 6.180 Such an approach might be taken to the operation of auctions, for example, which, as discussed in Chapter 5, create concerns relating to a lack of transparency about how digital advertising is sold and at what price. A regulatory body might be able to audit the processes followed by both platforms and intermediaries. We welcome views on the feasibility of an effective auditing regime for the process followed in undertaking auctions of digital advertising. 6.181 We would welcome views on whether the above improvements to transparency are technically and commercially feasible, and desirable, both from the perspective of privacy and competition. If so, we seek views on whether industry should be able to agree standards to provide additional transparency, or whether an enforceable set of rules or standards should be applied by a regulatory body. 6.182 See Appendix M for a more detailed consideration of these potential interventions, and a list of specific consultation questions. ## Initial Findings 6.183 In this chapter, we have explained why we consider there to be a strong argument for the development of an ex ante regulatory regime to govern the activities of large online platforms funded by digital advertising. 6.184 Our initial view is that an enforceable code of conduct has a number of advantages over ex post enforcement and would be a valuable tool in helping to address the competition concerns we have identified in consumer-facing and digital advertising markets. 6.185 We have considered criteria that could be used to assess whether a digital platform that is funded by digital advertising should be considered to have SMS, and hence be subject to the code of conduct. At this stage, we consider that Google and Facebook would likely be considered to have SMS against these criteria. 6.186 Our initial view is that these platforms should be subject to three overarching principles: **fair trading**, which would require the SMS platform to trade on fair and reasonable terms for services where they are an unavoidable trading partner as a result of their market position; **open choices**, which would be intended to require the SMS platform to allow users to choose freely between elements of the platform's services and those offered by competitors; and trust and transparency, designed to ensure that SMS platforms provide sufficient information to users, including both consumers and businesses which transact with the platform. 6.187 This chapter also sets out certain specific interventions that have the potential to address the sources of market power, lack of transparency and conflicts of interest in search, social media and digital advertising markets. These include data access remedies, interventions to increase interoperability, measures to give consumers greater control over their data and separation remedies. We recognise that some of these interventions would be very significant and would need to be considered very carefully. 6.188 We have an open mind regarding the merits of these potential regulatory interventions, some of which are explored in further detail within Appendices I- M, which also contain a number of consultation questions. We welcome views on these specific proposals, as well as responses to the key questions set out in Chapter 8 of our interim report. ## 7. Views On A Market Investigation Reference 7.1 Since issuing our market study notice on 3 July 2019, we have received five representations from parties for us to make a market investigation reference (MIR). 7.2 We are therefore required to consult on a proposal within six months of launching the study (by 2 January 2020) on whether to make a market investigation reference. The timing of this interim report is a result of that requirement. We are required to publish our decision on whether to launch a market investigation in our final report, which we must publish on or before 2 July 2020. 7.3 We received representations to make a MIR from: - a UK media company; - an online platform; - Dr Ryan and Dr Lynksey; - The News Media Association; and - Privacy International. 7.4 These representations are summarised in Appendix B, which sets out the key points made by stakeholders in response to our statement of scope. These five stakeholders have raised different concerns that they wish to see addressed through a market investigation. For example, the News Media Association told us it would like a market investigation to ensure that publishers earn a fair return for their content, whereas Privacy International told us it would like an investigation to include the aim of strengthening the enforcement of consumers' rights against abusive practices. 7.5 The CMA can make a market investigation reference when: - the findings of a market study give rise to reasonable grounds for suspecting that a feature or combination of features of a market or markets in the UK prevents, restricts or distorts competition;343 and - a market investigation reference appears to be an appropriate and proportionate response. 7.6 We have published the following four criteria that we consider as part of any decision:344 - the scale of the suspected problem is such that a reference would be an appropriate response (ie that the adverse effect on competition is likely to be significant based on the size of the market, the proportion of the market that is affected and the persistence of the market features); - there is a reasonable chance that appropriate remedies would be available; - it would not be more appropriate to address the concerns through undertakings in lieu of a reference (UILs); and - it would not be more appropriate to address the competition issues through alternative powers available to the CMA or through the powers of sectoral regulators. 7.7 We have drawn the scope of our market study broadly, covering a wide range of related markets, so that we can better understand the full range of challenges and concerns that arise in relation to online platforms that are funded by digital advertising, and the relationships between these issues. There are, therefore, several individual markets that could in principle be reviewed through a market investigation. 7.8 Based on our initial findings, as well as the representations made by the parties above, we believe there are reasonable grounds for suspecting that features of the following markets could be restricting or distorting competition in the UK: - the open display advertising market, with a focus on the lack of transparency, Google's market power and the conflicts of interest Google faces at several parts of its vertically integrated chain of intermediaries; - general search and search advertising, with a focus on barriers to entry and expansion arising from Google's scale advantages in data and Google's payments to be the default search engine on devices and browsers; and - social media and display advertising, with a focus on the network effects enjoyed by Facebook and the lack of interoperability between Facebook and rival services. 7.9 Given the size and value of these individual markets, and the number of consumers affected by them, a market investigation would appear to be a proportionate response. Some of the potential interventions we discussed in the previous chapter could be implemented through the order making powers available to the CMA within a market investigation. 7.10 For example, order making powers could be used to introduce increased interoperability in social media, or third-party access to click and query data in search, or changes to the arrangements for determining the default search engine on browsers and devices. We could in principle also use them to make one-off interventions to tackle the structural issues within the open display advertising market. 7.11 We therefore consider a decision on whether to propose a market investigation in any or all of these areas to rest primarily on whether it is the most appropriate mechanism for assessing the issues and delivering the required outcomes. 7.12 We said in our statement of scope that we see recommendations to government as the most likely outcome of the study, as we did not 'expect that a "one-off" intervention by the CMA, such as could be achieved through a market investigation, would be sufficient to provide a sustainable long-term framework for the sector.'345 This reflected the fast-evolving nature of concerns in these markets, suggesting that an ongoing regulatory regime would be more appropriate. Although it is a finely balanced judgement, we continue to hold this view and have concluded that we should consult on not making a market investigation reference at this stage. There are three key factors behind our current thinking. 7.13 First, the government has been committed to regulatory reform in this area. If this remains the case, we believe there are good prospects that any recommendations coming from our study would be implemented in practice. 7.14 Our judgement is that a market investigation reference is not at this stage the most appropriate way forward in either of general search and search advertising, or social media and display advertising. Two of the main potential interventions that we have identified within these two areas would be specific applications of the Furman Review proposals for data remedies, which it said should be implemented and overseen by the proposed Digital Markets Unit. Given that the government has committed to the setting up of the Digital Markets Unit,346 and to regulatory reform more broadly in relation to online platforms, covering a wider range of issues than those we have considered in this study, we think that it is better to inform the development of that regulatory regime through recommendations rather than risk cutting across it through a major intervention at this stage. 7.15 The Furman Review did not study the open display advertising market in any detail, recommending instead that we conduct this market study. It is therefore less clear whether the interventions proposed by the Furman Review could, if taken forward by government, be implemented in such a way that would effectively tackle the structural issues we have surfaced. However, there is a case for reviewing the scope and potential impact of a new ex ante regime - and in particular a code of conduct, which would attempt to address the concerns arising from the exercise of market power - before deciding to take forward more intrusive measures. 7.16 Second, the concerns we have identified regarding online platforms such as Google and Facebook are a truly global antitrust challenge facing governments and regulators. Therefore, in relation to some of the interventions we are considering, and in particular any significant structural remedies, such as those involving ownership separation, we need to be pragmatic about what changes could efficiently be pursued unilaterally by the UK. 7.17 This is an important factor behind our proposal not to make a market investigation reference into the open display advertising market at this stage. We have been engaging extensively with our international counterparts, and have made significant progress in identifying areas of shared interest and common understanding. We will continue this work with the aim of developing a coordinated position and response. We hope that the government can assist us in driving forward this programme of international cooperation to the fullest extent possible. 7.18 Third, we still have considerable work to do to understand the nature and extent of the issues in the market, and what the appropriate range of remedies might be to address them. We hope to test our initial findings through this consultation, gather more evidence through the second half of the study, and come to more precise judgements in our final report. At this stage we cannot confidently say which set of interventions should be taken forward, and so the most appropriate mechanism for implementation is similarly unclear. 7.19 Based on these three factors, we are not minded to propose a market investigation reference at this stage. Our preferred approach to tackling the problems we have identified continues to be through recommendations to government for regulatory reform. 7.20 We will revisit this conclusion in the light of consultation responses that we receive, our assessment of market developments including through continued engagement with our international partners, and the UK government's emerging position on regulatory reform in this area. 7.21 We would like to receive views from a broad range of parties on this proposed way forward. ## 8. Next Steps 8.1 This document provides an update on the progress we have made to date in this market study. It sets out our initial findings on a wide range of potential concerns within each of our three themes, including on: - barriers to entry and expansion in general search and social media markets; - consumers' control over collection of their personal data; and - concerns around transparency, conflicts of interest and market power in digital advertising markets. 8.2 Going forwards, we want to gather more evidence to test and refine our thinking in these areas, and to identify which are the most appropriate interventions for tackling these issues. This consultation is an important first step in that process. ## This Consultation 8.3 We are using this consultation to gather views and information from stakeholders on the following five topics: - our understanding of the markets within our scope; - our initial findings and concerns under each theme; - the merits and challenges of the potential interventions identified; - the case a market investigation; and - the further work we propose to do over the second half of the study. 8.4 The key questions we have under each topic are set out in Box 9.1. ## Box 9.1: Our Key Questions Our Understanding Of The Markets Within Our Scope 1) Do you agree with our descriptions of general search services and social media service, as set out in Chapters 2 and 3? 2) Do you agree with our explanation of the different forms of digital advertising, as set out in Chapter 5? 3) Do you agree with our explanation of how the intermediated open display market operates, as set out in appendix H? 4) Do you agree with our understanding of the role of data, as set out in Appendix E? ## Our Initial Findings And Concerns Under Each Theme 5) Do you agree with our analysis and findings in relation to competition in search and social media, as set out in Chapter 3? 6) Do you agree with our analysis and findings in relation to consumer control over data, as set out in Chapter 4? 7) Do you agree with our analysis and findings in relation to competition in digital advertising, as set out in Chapter 5? ## The Merits And Challenges Of The Potential Interventions Identified 8) Do you agree with our assessment of the merits of a code of conduct for large online platforms funded by digital advertising? 9) Do you agree with the range of possible practices we have identified that could be considered under such a code of conduct? 10) Have we identified the appropriate range of potential interventions to address the sources of market power for Google and Facebook? 11) Have we identified the appropriate range of remedies to improve consumers' control over their data? 12) Have we identified the appropriate range of remedies to address conflicts of interest and a lack of transparency in digital advertising markets? 13) We have set out a number of specific questions relating to the potential interventions, which are discussed in the following appendices: I: Potential practices to be tackled through a code of conduct J: Potential interventions to address market power in general search K: Potential interventions to address market power in social media L: Potential interventions to improve personal data mobility M: Potential interventions in digital advertising markets Do you have any views on the more specific questions in these documents? 14) Do you have any views about the appropriate sequencing of the remedies we have identified? ## Market Investigation 15) Do you agree with our assessment of the potential candidates for a market investigation, and what are your views on the merits of each? 16) Do you agree with our proposal not to make a market investigation reference at this stage? 17) Do you support recommendations to government as an effective route to implementing interventions in these areas? ## Further Work We Propose To Do Over The Second Half Of The Study 18) Do you agree we have identified the right areas for further work in the second half of the study (set out below), and are there any significant gaps? ## How To Respond 8.5 To respond to this consultation, please email or post your submission to: Email: onlineplatforms@cma.gov.uk Post: Online Platforms Market Study Competition and Markets Authority 25 Cabot Square London E14 4QZ 8.6 Please respond by no later than 5pm on 12 February 2020. 8.7 For transparency and to inform public debate, we intend to publish all responses we receive. In providing responses: - Please supply a brief summary of the interests or organisations you represent, where appropriate. - Please consider whether you are providing any material that you consider to be confidential, and explain why this is the case. Please provide both a confidential and non-confidential version of your response. 8.8 If you are an individual (ie you are not representing an organisation), please indicate whether you wish for your response to be attributed to you by name or published anonymously.347 ## The Next Six Months Further Work 8.9 During the second half of the study, we will focus on obtaining further evidence on specific issues to develop our assessment, as well as continuing to review the evidence we have obtained, and progressing our assessment of the potential interventions. Specific areas for further and more detailed analysis that we have identified include: - market outcomes in search, social media, and digital advertising markets; - fees and revenues in the open display advertising value chain; - the characteristics, objectives, and behaviour of advertisers; - the interaction between controls over data at the platform level and those at the device or browser level; - the controls given to consumers over the use of their data by publishers; - the ability of platforms to influence auction outcomes; - the merits of each potential intervention, and the risks and challenges to implementing them, including practices most suited to inclusion within a code of conduct to govern online platforms with a strategic market status. 8.10 In addition to reviewing the responses we receive to this interim report, we will gather more evidence through continued engagement with stakeholders, further requests for information from parties, and remain open to conducting or commissioning targeted research. ## Our Final Report 8.11 We will publish our final report by 2 July 2020, which will include a decision on whether we will make a market investigation reference. 8.12 It will set out our findings on the extent of competition faced by the largest online platforms funded by digital advertising, and on the extent of concerns in the markets within which they operate. It will also include our conclusions on the most appropriate interventions to solve the range of issues we identify. As indicated in Chapter 6 of this document, we currently expect this to include a number of recommendations to government for regulatory reform.
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National Paediatric Diabetes Audit NPDA National Paediatric Diabetes Audit Report 2012-13 Part 1: Care Processes and Outcomes National Paediatric Diabetes Audit Report 2012-13 Report 1: Care Processes and Outcomes October 2014 Report produced by the National Paediatric Diabetes Audit, Royal College of Paediatrics and Child Health ## List Of Tables And Figures Table number Title Page number 1 Diabetes registrations by country, age and English region in 2012-13 13 2 Number of children and young people with diabetes by gender and age band, for England and Wales combined in 2012-13 14 3 Percentage of children and young people with diabetes by ethnic group in 2012-13 15 4 Percentage of children and young people with diabetes by sex and type, for England and Wales in 2012-13 17 5 Percentage of children and young people with diabetes by type and ethnic group, England and Wales in 2012-13 18 6a Type 1 diabetes incidence rates per 100,000 persons by age group and sex in 2012-13 19 6b Numbers of newly diagnosed children and young people with Type 1 diabetes by country, gender and age group in 2012-13 19 23 7 Percentage of children and young people cared for in a PDU having key age-specific care processes recorded (for HbA1c this is all ages) from 2004-05 to 2012-13 8 Percentage of children and young people with HbA1c measured, by age and sex in 2012-13 25 29 9 Number and percentage of children and young people with diabetes achieving the HbA1c target of <58 mmol/mol, ≥58 mmol/mol to ≤80 mmol/mol, and >80 mmol/mol, by country and sex in 2012-13 10 Percentage by HbA1c target band achieved, England and Wales in 2010-11, 2011-12 and 2012-13 30 11 HbA1c (mmol/mol) target band achieved (number and %) by ethnic group for England and Wales in 2012-13 30 12 Mean and standard deviation, median and interquartile ranges for HbA1c in mmol/mol by country and English region in 2012-13. 33 13 Multiple regression showing the predictive risk factors for patient HbA1c in England and Wales in 2012-13 41 44 14 Logistic regression model of risk factors for proportion of children and young people with diabetes in England and Wales with an HbA1c greater than 80 mmol/mol in 2012-13   Figure number Title Page number 1 PDUs that submitted data to the NPDA in 2012-13 12 2 Number of children and young people with diabetes by gender and age band, for England and Wales combined in 2012-13 14 3 Percentage of children and young people with diabetes by ethnic group in 2012-13 16 4a Age-Sex Type 1 diabetes incidence rates by country 20 4b Time trends in Age-Specific Type 1 diabetes incidence rates for England and Wales combined 20 5a Type 1 diabetes incidence rate by country and English region in 2012-13 22 5b Time trends in the incidence of Type 1 diabetes by country and region from 2010-11 to 2012-13 21 6 Percentage of children and young people with diabetes aged 12 years and over, having all care processes recorded from 2004-05 to 2012-13 23 7 Percentage of care process incomplete (except HbA1c) by Paediatric Diabetes Unit in 2012-13 24 8a Percentage of males who had their HbA1c measured in England and wales 26 8b Percentage of females who had their HbA1c measured in England and wales 26 9 Percentage who did NOT have the HbA1c care process completed, England and Wales by Paediatric Diabetes Unit in 2012-13 27 29 10 Percentage of children and young people achieving the NICE recommended HbA1c target of <58 mmol/mol, ≥58 mmol/mol to ≤80 mmol/mol, and >80 mmol/mol, by country in 2012-13 11 Percentage of children and young people with diabetes by HbA1c target band achieved and ethnic group in 2012-13 31 12 Percentage achievement of HbA1c target of <58 mmol/mol by Paediatric Diabetes Unit in 2012-13 32 13 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, Wales in 2012-13 34 14 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, East of England in 2012-13 34 15 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, Yorkshire and the Humber in 2012-13 35 16 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, East Midlands in 2012-13 36 17 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, West Midlands in 2012-13 36 18 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, South Central in 2012-13 36 19 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, North West in 2012-13 37 20 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, North East in 2012-13 37 21 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, South West in 2012-13 38 22 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, London in 2012-13 38 23 Box and whisker plots of HbA1c by Paediatric Diabetes Unit, South East in 2012-13 39 40 24 Funnel plot showing the unadjusted mean HbA1c for PDUs in England and Wales by unit size in 2012-13 42 25 Funnel plot showing the adjusted mean HbA1c for PDUs in England and Wales by unit size in 2012-13 43 26 Funnel plot showing the unadjusted proportion of children and young people with diabetes in England and Wales with HbA1c greater than 80 mmol/mol against unit size 45 27 Funnel plot showing the adjusted proportion (%) of children and young people with diabetes in England and Wales with HbA1c greater than 80 mmol/mol against unit size in 2012-13 Foreword   We are delighted to introduce the third annual National Paediatric Diabetes Audit (NPDA) report prepared by the Royal College of Paediatrics and Child Health (RCPCH) which covers the audit period 2012-13 for the Paediatric Diabetes Units (PDUs) in England and Wales. The NPDA has been running in its entirety for 10 years and has become a powerful measuring tool for providing benchmarked information relating to outcomes and quality of care for children and young people with diabetes. The NPDA has undergone several changes over the last three years including the collection of some new data items and use of median HbA1c for the Audit year, rather than simply relying on the HbA1c value for each individual patient. This has put extra burden on centres submitting data but is clearly important, as it brings the NPDA into line with other international registries and audits, making benchmarking against other countries more meaningful. The NPDA project team are aware of the challenges that exist when submitting to the Audit, together with the considerable amount of time taken to collect and prepare data that is of good quality and as complete as possible. The NPDA recognises the significant additional investment in Paediatric Diabetes, particularly in England where the 'Best Practice Tariff' together with the quality assurance peer review programme should lead to improved quality of care and outcomes. The first round of peer review visits to PDUs will be complete for both England and Wales by the end of 2014. We recognise the considerable burden that has been placed on each PDU, not only in submitting their data to the NPDA, but also preparing for their peer review quality assurance visit alongside striving to deliver their diabetes services at 'Best Practice Tariff' standard. Results from the NPDA over the last 10 years have been disappointing, with little evidence of any change in outcomes. Therefore, questions have to be asked as to whether recent investment both of finance and time has made a difference. This year's NPDA report demonstrates some positive changes for England and Wales with a downward trend in the median HbA1c by 2 mmol/mol from the previous year which now represents the third consecutive year where there has been improvement in the national median HbA1c. This may not feel like a large improvement, but is coherent with rates of change seen in other European countries where measures have already been taken to improve outcomes. There is still work to be done as, despite this overall improvement in the median HbA1c, the percentage of children and young people with diabetes who have a median HbA1c less than 58 mmol/mol remains low and the number with an HbA1c greater than 80 mmol/mol remains stubbornly high. Furthermore, children and young people with diabetes from ethnic minority groups perform less well than those from white ethnic backgrounds. However, it is not clear why these differences exist. Of concern is the large variability in outcome measures that persist across regional diabetes networks and PDUs. Even after statistical adjustments for known confounding influences, such as ethnicity, social deprivation, gender, age and diabetes duration, over 90% of the variation in HbA1c is unaccounted for. This suggests that much of the variation is due to differences in service provision and delivery which needs addressing. Network working and 'peer review' are paving the way towards the sharing of good practice and the NPDA fully endorse this approach. It is recommended that PDUs use the 'casemix' adjustments presented in this report to identify their outlier status, and benchmark themselves against others with a similar patient demographic, location or size and work within networks to employ strategies to improve outcomes and reduce variability. Finally, we would like to thank the NHS clinical teams who have provided the data to support this important Audit and applaud the clinical leadership that has led to these improvements. With this strong support of the NPDA together with the work being carried out across the regional diabetes networks, we have confidence in steady ongoing improvements of care across England and Wales. Children and young people with diabetes deserve nothing less.       Dr Justin Warner RCPCH NPDA Clinical Lead Consultant in Paediatric Endocrinology and Diabetes University Hospital of Wales Dr Fiona Campbell Chair of NPDA dataset working group Consultant Paediatric Diabetologist Leeds Teaching Hospitals NHS Trust ## 1. Summary Of Key Findings   Coverage of children and young people with diabetes by the National Paediatric Diabetes Unit (NPDA) has remained stable. Records from 25,314 children and young people with diabetes were submitted to the 2012-13 NPDA, compared with 25,390 in 2011-12. The reported year of 2012-13 is the second year of the new dataset and data collection process. A total of 25,221 children and young people under the age of 25 years with a diagnosis of diabetes who were cared for in Paediatric Diabetes Units (PDUs) in 2012-13 were suitable for analysis by the NPDA reporting from 178 PDUs. This represents 100% of all PDUs where children and young people in England and Wales receive their diabetes care. Key improvements offered by this report are in recording of individual care processes from previous years. The percentage of children and young people diagnosed with diabetes for at least one year and over the age of 12 years at the start of the Audit year with all care processes recorded, as recommended by the National Institute for Health and Care Excellence (NICE), has almost doubled from 6.7% in 2011-12 to 12.1% in 2012-13. This higher proportion is very encouraging, but continues to fall short of similar data from the 2011-12 National Diabetes Audit (NDA) report for adults with diabetes. The proportion of adults receiving all eight adult care processes was 42.4% for Type 1 diabetes for England and Wales. The number of patient visits, or records of HbA1c and other tests submitted per patient, has continued to increase. During 2012-13, there were 106,333 reported visits from 25,221 patients, an average of four visits per patient. There has been a marked increase in HbA1c measurement. In England, 98.6% of males and females under the age of 25 years had their HbA1c measured, compared with 89% in 2011-12. In Wales, the corresponding figures are 98.9% and 87%. This shows a continued improvement on 2010-11 when the completion rate for this care process was 85%. There has been a small decrease in the percentage of children and young people with diabetes who achieve an HbA1c less than 58 mmol/mol (from 17.4% in 2011-12 to 15.8% in 2012-13). However, this still represents either an improvement or similarity to 2009-10 and 2010-11 where the figures were 14.5% and 15.8% respectively. The greatest numbers (58.4%) of patients have an HbA1c between 58 mmol/mol and 80 mmol/mol. Just over one quarter of children and young people have an unacceptable HbA1c of greater than 80 mmol/mol. A much higher proportion of children and young people with diabetes from ethnic minorities (26.4% to 36.4% depending on the ethnic group) have an HbA1c level greater than the 80 mmol/mol. In 2012-13 the median HbA1c for England and Wales was 69 mmol/mol, down from 71 mmol/mol in 2011-12. This represents the third consecutive year where there has been a sustained fall in the national median HbA1c. However, there is variability between nations and regional networks ranging from a median of 68-72 mmol/mol. Casemix adjustment has demonstrated that only 8% of the variability in the mean HbA1c, and 7% of the variability of the proportion with an HbA1c >80 mmol/mol, across PDUs can be explained by factors such as ethnicity, social deprivation, gender, age and diabetes duration. Therefore, over 90% must be explained by service related factors such as structure, resource and delivery of care. The NPDA calls for a concerted effort to reduce this variability which is already being addressed through networking and the peer review accountability programme. The funnel plots presented in this report identify outliers for two measures, mean HbA1c and percentage of patients with HbA1c greater than 80 mmol/mol. The NPDA urge PDUs to take notice of this data and implement strategies to improve the status of all PDUs where performance is suboptimal. Alongside this report, there will be a separate complications report covering the 2012-13 hospital admissions data relating to diabetic ketoacidosis hypoglycaemia and 'without complications'. ## 2. Introduction The National Paediatric Diabetes Audit (NPDA) report highlights the main findings on the quality of care for children and young people with diabetes mellitus in England and Wales. This is the 10th report and covers data submitted for patients under the age of 25 years and cared for in Paediatric Diabetes Units (PDUs) in 2012-13. This is the third report from the Royal College of Paediatric and Child Health (RCPCH). The NPDA is commissioned and sponsored by the Healthcare Quality Improvement Partnership (HQIP) as part of their National Clinical Audit Programme. The programme is funded by NHS England and the Welsh Government. The NPDA covers the components of the National Service Framework (NSF) for diabetes and includes details on the number of children and young people with diabetes in England and Wales, together with the care processes they receive and outcome measures, including inpatient admissions for diabetic ketoacidosis. This report covers the care process and outcome data only, with complications data to follow in a separate report. The National Diabetes Audit (NDA) for adults reports on the provision of core diabetes care for everyone with diabetes. This provides commissioners with age, ethnicity and social deprivation-related perspectives across the whole population for which they are responsible. The NDA also reports to participating individual General Practices and adult specialist services, allowing them to benchmark their care against their peers. The NPDA reports separately to individual participating PDUs regarding their provision of diabetes care for the children and young people attending their services. Those reviewing the NDA and NPDA reports side-by-side need to be aware of these differences but, equally, those wanting to get the most complete picture of local needs and service provision should consider the two reports together** Following the launch of a new dataset in 2011-12, 2012-13 has been a year of consolidation for the NPDA. Over the 10 years that the NPDA has been the basis for data collection on process and outcome measures of care for children and young people with diabetes, there have been many changes in the way services are structured and delivered. Participation in the NPDA is now a mandatory standard for PDUs and hospital trusts to receive tariff in England. Currently, no such commissioning arrangements exist for Wales. Peer review, as part of a quality assurance programme, has completed its first self-assessment exercise in England with ongoing review visits taking place in 2014. Wales is following this programme of peer review, which should also be complete by the end of 2014. The NPDA acts as the measuring arm of any quality assurance programme and it is therefore encouraging to see the early signs of improvement in outcome, with a third consecutive yearly fall in the median HbA1c. However, there are variations across regional networks, which will require close and careful monitoring over the next few years. For the first time this year, each PDU has been provided with their unadjusted and adjusted mean HbA1c and percentage of children and young people that would be expected to have an HbA1c greater than 80 mmol/mol based on the population characteristics of their geographical area. This will allow units to compare their crude outcomes with those adjusted for their 'casemix' which allows a more equitable comparison of Units. Furthermore, the use of funnel plots provides a technique for identifying outliers and is now the recognised statistical methodology for this purpose used by other national audits across England and Wales. Data quality is of paramount importance when submitting data and PDUs are reminded to check the data quality report provided by the RCPCH and act on any outstanding issues. The NPDA can only analyse data that fulfil the data entry criteria. Data submitted for patients must include a valid NHS number, date of birth, date of diagnosis and gender to be eligible for any analysis. Furthermore, they must be assigned a PDU PZ code. Care processes and outcomes can only be analysed if the result is a valid response and the date of measurement falls within the Audit year. When submitting data, one row of data represents one visit and multiple entries within one cell of a csv format spreadsheet are unacceptable. In the past, much data submitted had to be excluded, as it does not fulfil these criteria. The NPDA would urge submitting PDUs to check their data quality and accuracy to avoid any data being excluded. The NPDA hope that PDUs will use the data presented in this annual report to continue to benchmark their own centres against others and explore methods of driving up quality of care for their patients. The RCPCH and the NPDA would like to thank every PDU that submitted data to the 2012-13 Audit. The team recognises that this can be a timeconsuming process, particularly where there is a lack of resource and/or computer software to aid data collection.   ** Because the care of adults and children with diabetes is mixed between GP services (this includes ALL patients) and hospital, paediatric and community specialist services (these each include SOME patients), the different 'views' that the two national audits NDA and NPDA give to the providers of the services will inevitably include overlapping patients. Thus someone with diabetes attending a specialist service should also appear in the relevant GP report. The NDA integrates data from participating specialist and GP services for adults with diabetes so that if a care process or treatment target is recorded by one but not the other both get the complete data reported back to them i.e. a 'whole person' view. This makes sense because it reflects the fact that there is no clinical value in duplicating something carried out elsewhere. The population level NDA reports include all people with diabetes in a geographical area irrespective of their mix of provider services and use integrated data where they are available. The NPDA runs independently of the NDA and of GP services so its data are not integrated making it possible that GP reports do not include all care processes or treatment targets measured in specialist paediatric units and vice versa. Specialist paediatric diabetes units are primarily responsible for the care of most children and young people with diabetes and for the collection of their care process and outcome data. Although GPs do not provide the majority of care for children and young people living with diabetes they do prescribe all their medications. Therefore it is in this age group, and also adults with Type 1 or complex diabetes that attend specialist services not participating in NDA, where lack of data integration is most likely to result in a slightly deficient 'whole systems' view. Furthermore, for under-17s, the age cut-off for the QOF GP incentive scheme means that there is no financial value to the practice in replicating results from external services. Nonetheless, because less than 10% of all people with Type 1 diabetes, and less than 1% of people with diabetes in general are under 17 years old, the overall impact on population level NDA results is minimal. ## 3. Coverage And Participation A total of 178 PDUs in England and Wales successfully submitted data to the 2012-13 NPDA. A PDU is defined as a unit which delivers a paediatric diabetes healthcare service. It may represent one or more hospitals, as some services provide care across multiple sites. Data were received from 164 PDUs in England and from 14 PDUs within the six Health Boards in Wales, comprising all services registered with the NPDA for both nations. ## 4. Demographic And Population Assessment 4.1 Registrations Records from 25,314 children and young people with diabetes were submitted to the 2012- 13 NPDA, a similar number to the 25,390 submitted in 2011-12. A total of 157 of these patients were registered in two or more regions. Since multiple patient visits can be entered for each patient, there were a total of 107,657 visits submitted to the 2012-13 NPDA. However, 1,324 of these visit records have been excluded from the 2012-13 analysis for a combination of reasons, including, for example, missing patient NHS number, missing date of birth, more than one valid date of birth for the same NHS number and age greater than 25 years. Therefore, for England and Wales combined, there was a total of 106,333 visits recorded for 25,221 children and young people under the age of 25 years old registered with diabetes and with a valid age and sex attached to their record, reported from 178 PDUs. This equates to approximately four patient visits per annum. Table 1 shows the breakdown in registration by country, age and English region. The age breakdown categories are the same as in the Census and other Office for National Statistics publications. Within England, the maximum number of registrations across all age groups was observed in the North West and the South East of England regions. It has not been possible to disaggregate the South East region into its two networks because of Census 2011 changes to both regions and local authorities (LAs) within them. In both England and Wales, age groups 10-14 and 15-19 years comprised the two largest groups of registered children and young people with diabetes. Age Group 0-4 5-9 10-14 15-19 20-24 Total England and Wales 1,470 5,009 10,759 7,895 83 25,216 England 1,384 4,732 10,129 7,474 82 23,801 Wales 87 278 634 426 <5 1,426 Regions in England East of England 152 515 1,072 912 13 2,664 East Midlands 105 388 774 525 0 1,792 London 176 548 1,000 722 <5 2,449 North East 67 212 522 369 <5 1,172 North West 210 645 1,420 883 44 3,202 South Central 121 453 940 743 9 2,266 South East 178 597 1,281 871 5 2,932 South West 113 390 909 717 7 2,136 West Midlands 148 520 1,138 914 6 2,726 Yorkshire and the Humber 139 508 1,123 833 <5 2,605 157 patients were registered in 2 or more regions. Patient counts reflect unique patients at each level of aggregation, and therefore may not balance across region and country totals. ## 4.1.1 Registrations By Age And Sex Table 2 and Figure 2 show registrations for males and females in each age band. Patients in age groups 10-14 and 15-19 comprise the highest proportion of registrations in England and Wales. Slightly more young males have been registered with diabetes than females. | | 0-4 | 5-9 | 10-14 | 15-19 | 20-24 | Total under 25 | |----------------|--------|--------|----------|----------|----------|-------------------| | Boys | | | | | | | | 759 | 2,559 | 5,435 | 4,136 | 45 | 12,934 | | | Girls | | | | | | | | 702 | 2,391 | 5,207 | 3,708 | 38 | 12,046 | | | Not Specified* | | | | | | | | 9 | 59 | 117 | 51 | 0 | 236 | | | Total under 25 | 1,470 | 5,009 | 10,759 | 7,895 | 83 | 25,216 | * Includes responses '*9 Not Specified*', blank and records where both male and female genders had been recorded for the same patient. ## 4.1.2 Registrations By Ethnicity And Region Table 3 and Figure 3 show the percentage of children and young people registered with diabetes by ethnic group for 2012-13. Ethnicity coding is taken from the Information Standards Board (ISB) for Health and Social Care. A fundamental principle of ethnic category data collection is that the person to be categorised is responsible for classifying themselves, and that their reply is their own perception of their ethnic category, and not that of the healthcare professional. However, the Department of Health guidance acknowledges that there are some unavoidable exceptions (such as for those who for reasons of illness are unable to respond or be understood) where it may not be possible or appropriate to collect this data. The NPDA is not able to verify that this process has taken place. The majority of children and young people with diabetes are white but there is regional variability. In England, Asians and Mixed ethnic groups were the two next largest. Of 25,374 records, 4,269 had an ethnicity recorded as 'not stated'. The national code of '*not stated'* means that the person has been asked and has declined to respond either because they do not wish to provide this information, or due to a genuine inability to choose a response, it does not mean the ethnic category is unknown. The ethnicity of an additional 759 patients were invalid or left blank, so were classified as 'unknown' in accordance with NHS Data Dictionary ethnicity definitions. For PDUs in Wales, 99.2% of records provide some form of ethnic origin; the corresponding figure from England is 96.9%, which is significantly improved from 2010-11 when 72.6% of registrations from England specified ethnic origin. However, 17.7% of records from England are 'not stated' whereas in Wales 2.1% are 'not stated'. It seems likely that this difference could be due to some PDUs misclassifying 'unknown' ethnicity as 'not stated'. This seems to be particularly prevalent in North East, North West and West Midlands regions. The NPDA has reminded PDUs of the correct process for classifying ethnicity for the 2013-14 data submission.   White Asian Black Mixed Other Not stated Unknown* England and Wales 70.2 4.4 1.8 2.5 1.3 16.8 3.0 England 68.7 4.6 1.9 2.6 1.4 17.7 3.1 Wales 94.5 0.8 0.2 1.3 0.4 2.1 0.8 Regions in England East of England 73.9 2.6 0.4 2.1 0.8 15.1 5.1 East Midlands 87.3 6.1 0.9 2.3 0.6 2.1 0.8 London 42.6 9.8 10.7 8.5 5.2 19.2 3.9 North East 65.4 0.4 0.1 0.3 0.1 33.4 0.3 North West 69.1 3.7 0.7 1.0 1.1 23.5 0.8 South Central 71.7 1.8 0.5 1.8 0.4 19.3 4.4 South East 70.1 5.3 2.6 3.2 1.9 12.3 4.6 South West 76.9 0.7 0.9 1.5 0.2 11.1 8.7 West Midlands 59.3 5.9 0.5 2.5 1.6 28.7 1.5 Yorkshire and the Humber 75.4 7.0 0.6 1.4 1.0 14.1 0.6 *Unknown includes patients with blank or invalid ethnicity values in all their records   *Unknown includes patients with blank or invalid ethnicity values in all their records  ## 4.1.3 Registrations By Diabetes Type Over 98% of the records submitted to the Audit had a diabetes type recorded. Table 4 shows the breakdown of diabetes type by sex, country and English region. The vast majority of children and young people with diabetes have Type 1 diabetes, although there is variability across regions in England. In both England and Wales there were slightly more male patients with Type 1 diabetes. The second major group was those with Type 2 diabetes. forms of Mellitus* Diabetes Not Specified forms of Mellitus* Diabetes Other specified forms of Diabetes Monogenic (gene unknown) forms of Diabetes Monogenic (gene known) Related Diabetes Cystic Fibrosis Type 2 Mellitus Diabetes Mellitus Type 1 Diabetes | | |-----------------| | Boys | | Girls | | Boys | | Girls | | Boys | | Girls | | Boys | | Girls | | Boys | | Girls | | Boys | | Girls | | Boys | | Girls | | England and | | Wales | | 97.0 | | 94.3 | | 1.0 | | 2.7 | | 0.3 | | 0.7 | | 0.3 | | 0.3 | | 0.1 | | 0.0 | | 0.4 | | 0.7 | | 0.9 | | 1.3 | | England | | 97.0 | | 94.2 | | 1.1 | | 2.8 | | 0.3 | | 0.6 | | 0.3 | | 0.3 | | 0.1 | | 0.0 | | 0.5 | | 0.7 | | 0.9 | | 1.3 | | Wales | | 98.1 | | 96.0 | | 0.5 | | 1.8 | | 0.3 | | 1.2 | | 0.3 | | 0.4 | | 0.0 | | 0.1 | | 0.1 | | 0.1 | | 0.7 | | 0.3 | | Regions in | | England | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | East of England | | 94.2 | | 91.7 | | 0.4 | | 1.1 | | 0.3 | | 0.4 | | 0.3 | | 0.2 | | 0.0 | | 0.0 | | 0.5 | | 0.2 | | 4.2 | | 6.4 | | East Midlands | | 97.8 | | 96.6 | | 0.9 | | 2.2 | | 0.1 | | 0.4 | | 0.3 | | 0.0 | | 0.0 | | 0.1 | | 0.3 | | 0.2 | | 0.6 | | 0.5 | | London | | 96.3 | | 91.4 | | 2.0 | | 5.4 | | 0.6 | | 1.1 | | 0.1 | | 0.4 | | 0.2 | | 0.0 | | 0.5 | | 1.0 | | 0.3 | | 0.6 | | North East | | 98.5 | | 96.5 | | 0.6 | | 2.9 | | 0.2 | | 0.0 | | 0.0 | | 0.0 | | 0.0 | | 0.0 | | 0.0 | | 0.0 | | 0.6 | | 0.6 | | North West | | 96.7 | | 93.7 | | 0.8 | | 2.0 | | 0.2 | | 0.9 | | 0.7 | | 0.5 | | 0.1 | | 0.0 | | 0.8 | | 1.4 | | 0.9 | | 1.5 | South Central 98.4 95.5 0.7 2.3 0.5 0.6 0.2 0.7 0.0 0.1 0.1 0.6 0.1 0.3 South East 97.7 95.6 1.3 2.5 0.0 0.4 0.2 0.1 0.0 0.0 0.1 0.7 0.6 0.6 South West 98.4 95.4 0.5 1.9 0.6 1.8 0.3 0.8 0.1 0.0 0.2 0.1 0.0 0.0 West Midlands 97.6 94.5 1.7 4.2 0.0 0.0 0.0 0.1 0.1 0.0 0.1 0.2 0.5 1.1 Yorkshire and the Humber 95.5 93.9 1.5 2.6 0.5 0.6 0.3 0.6 0.2 0.0 1.6 1.8 0.4 0.5 * Patients were recorded as 'other specified forms of diabetes mellitus' where there is a recognised cause of diabetes (e.g. post organ transplantation, steroid induced diabetes, post pancreatitis/pancreatectomy) or related to a syndrome (e.g. Prader Willi or Lawrence Moon Biedl Syndrome). Where the patient has diabetes but the cause is unknown they are classified as 'not specified forms of Diabetes Mellitus'. Monogenic forms of diabetes include neonatal diabetes. Due to rounding to one decimal place, the total may not add to 100 per cent. ## 4.1.4 Registrations By Diabetes Type And Ethnicity Table 5 shows the breakdown of children and young people with diabetes by type and ethnicity for England and Wales combined. There are a much higher proportion of children and young people with Type 2 diabetes in Asian, Black, Mixed and Other ethnicities compared to the White ethnic group. | Diabetes type | White | Asian | Black | Mixed | Other | |-------------------|----------|----------|----------|----------|----------| | Not | | | | | | | | | | | | | | Type 1 | | | | | | | Diabetes | | | | | | | Mellitus | | | | | | | 96.7 | 84.8 | 92.7 | 92 | 92.6 | 95.8 | | Type 2 | | | | | | | Diabetes | | | | | | | Mellitus | | | | | | | 1.0 | 8 | | | | | | 8.9 | 5.8 | 4.6 | 4.2 | 2.3 | 4.2 | | Cystic Fibrosis | | | | | | | Related | | | | | | | Diabetes | | | | | | | 0.5 | 0.3 | 0 | 0.6 | 0 | 0.2 | | 0.3 | 0.6 | 0.2 | 0.2 | 0 | 0.3 | | England | | | | | | | Monogenic | | | | | | | forms of | | | | | | | Diabetes (gene | | | | | | | known) | | | | | | | and | | | | | | | Wales | | | | | | | 0.0 | 0.3 | 0 | 0 | 0 | 0.1 | | Monogenic | | | | | | | forms of | | | | | | | diabetes (gene | | | | | | | unknown) | | | | | | | 0.5 | 2.9 | 0.4 | 1.3 | 0 | 0.3 | | Other | | | | | | | specified | | | | | | | forms of | | | | | | | Diabetes | | | | | | | Mellitus | | | | | | | 1.0 | 2.2 | 0.9 | 1.3 | 3.3 | 1 | | Not Specified | | | | | | | forms of | | | | | | | Diabetes | | | | | | | Mellitus | | | | | | stated Unknown ## 4.2 Incidence Rates 4.2.1 Incidence rates by country for Type 1 diabetes This section includes age and sex-specific diabetes population incidence rates for Type 1 diabetes for 2012-13. The age-specific incidence rate is defined as the number of newly diagnosed cases of diabetes in a specific age group over a specific time period (i.e. 2012-13 year period) per total number of children and young people in that age group in the general population. Recent evidence suggests that the incidence of Type 1 diabetes in children is rising and may double by 2020, which has important health care implications.5 NPDA incidence time trends need to be interpreted with caution, as the increase may be due to better coverage or ascertainment of patients with diabetes, rather than to a true increase in incidence. However, as numbers of cases have stabilised ascertainment is likely to be close to 100%. Table 6a and Figure 4a show Type 1 diabetes incidence rates by age and sex for England and Wales in 2012-13. The age group of 10-14 years had the highest rate of incidence of Type 1 diabetes. In England and Wales, males had a higher rate of incidence than females, except in the 5-9 year age group. As the number of newly diagnosed patients aged 20-24 years cared for in a PDU is small, the incidence rate is not shown. Table 6b shows the numbers of newly diagnosed children and young people with Type 1 diabetes for England and Wales. There were 2,642 newly diagnosed patients with Type 1 diabetes, under the age of 20 years, in England and Wales during 2012-13 cared for in a PDU, with slightly more boys than girls. Figure 3b shows the overall incidence time trends by age over the last 3 audit year cycles. There have been minor changes in incidence but no clear trend in any direction. England Wales England and Wales Age Group Boys Girls Boys Girls Boys Girls 0-4 14.5 13.8 19.5 19.4 14.7 14.1 5-9 22.9 24.3 23.3 33.1 22.9 24.8 10-14 37.7 31.5 30.7 31.2 37.3 31.5 15-19 8.2 6.0 7.9 5.2 8.2 6.0 Total under 20 20.3 18.5 19.9 21.5 20.3 18.7 England Wales England and Wales Age Group Boys Girls Not Specified Total Boys Girls Not Specified Total Boys Girls Not Specified Total 0-4 251 229 <5 481 18 17 0 35 269 246 <5 516 5-9 361 366 5 732 20 27 0 47 381 393 5 779 .10-14 580 462 <5 1,046 27 26 0 53 607 488 <5 1,099 15-19 138 96 <5 235 8 5 0 13 146 101 <5 248 Total under 20 1,330 1,153 11 2,494 73 75 0 148 1,403 1,228 11 2,642 *The NPDA has not been able to show rates for the South Central region since it has not been possible to disaggregate the South East region into its two networks due to this no longer existing as an NHS administrative region and population estimates have not been available from ONS since 2011. 5b) Time trends in the incidence of Type 1 diabetes by country and region from 2010-11 to 2012-13 *The NPDA has not been able to show rates for the South Central region since it has not been possible to disaggregate the South East region into its two networks due to this no longer existing as an NHS administrative region and population estimates have not been available from ONS since 2011. 5. Care processes and treatment targets Audit question: What proportion of children and young people with diabetes are getting the key age-specific processes of diabetes care, and what proportion achieve treatment targets? The NPDA collects information on the key care processes, recommended by the National Institute for Health and Clinical Excellence (NICE) for children and young people with diabetes.1 The NPDA measures the percentage of children and young people with diabetes who are receiving the seven key processes of care which include: x Glycated Haemoglobin A1c (HbA1c) x Body Mass Index (BMI) (both height and weight being recorded) x Blood pressure x Urinary albumin x Cholesterol x Eye screening x Foot examination Key care processes are recorded to monitor diabetes management and detect long-term complications at the earliest treatable stage. Guidelines specify a starting age of 12 years for commencing all care processes with the exception of HbA1c, which should be recorded in children and young people of all ages. The NPDA incorporates data collection for the agerelevant care process and provides analysis on this information. In the analysis, children and young people were included if they had received a complete year of care, i.e. for 2012-13 had been diagnosed prior to 01 April 2012 and for all care processes, except HbA1c, were 12 years of age or older on 01 April 2012. Furthermore, the data entered needed to be valid and have a date of measurement recorded that was within the Audit year. 5.1 Care processes During 2012-13 there has been a marked improvement in the completion of all the individual key care processes (Table 7). The percentage of children and young people over the age of 12 years with all care processes recorded has almost doubled from 6.7% in 2011-12 to 12.1% in 2012-13 (Table 7 and Figure 6). It is recognised that achieving a 100% completion rate for any particular care process within an audit year is not always possible due to nonattendance at clinics by some patients. Also, there may still be significant under-reporting of the care process being performed, but not recorded for audit purposes. The NPDA cannot validate this without a case note analysis for which it does not have permission. Continued improvement is required even to meet the completion rate of key care processes for adults with diabetes. The proportion receiving all checks in the National Diabetes Audit (NDA) 2011-12 for adults is 42.4% for those with Type 1 diabetes.2 2004- 05 2005- 06 2006- 07 2007- 08 2008- 09 2009- 10 2010- 11 2011- 12 2012- 13 HbA1c 73.2 77.6 84.7 89.1 89.6 90.1 92.8 89.3 97.6 BMI 50.5 53.0 60.5 73.2 66 70.2 75.3 64.7 87.9 Blood Pressure 44.1 40.6 53.3 60.1 57.1 58.8 62.7 67.7 77.3 Urinary Albumin 18.7 23.3 30.3 34.1 32.2 36.5 40.3 40.7 49.5 Cholesterol 18.2 17.5 22.6 32.1 30.5 29.9 34.9 44.4 52.7 Eye screening 17.7 15.3 25.2 25.7 26.9 25.8 35.8 36.9 49.7 Foot examination 17.4 15.4 21.3 23.5 23.1 24.5 31.9 34.4 39.5 2.0 2.6 3.6 5.0 5.2 4.1 5.8 6.7 12.1 % (over 12) with all care processes recorded ## Units can be identified in Appendix A by their PZ number. There was only one PDU that returned a result of 100% incompleteness, compared with four in 2011-12, with a wide variation for others. This is much improved on 2010-11 when there were 20 PDUs with 100% incompleteness of care processes. *A list of Paediatric Diabetes Unit PZ codes and corresponding Unit names can be found in Appendix A ## 5.2 Hba1C Analysis This section focuses specifically on the HbA1c care process as it is recommended as the best indicator of long-term diabetes control.1 The following analysis examines the percentage of children and young people, of all ages, who had their HbA1c checked and recorded as part of a care process. The outcome data for HbA1c are presented in section 6. In the analysis, children and young people with diabetes were included if they had receieved a complete year of care, i.e. for 2012-13 had been diagnosed prior to 01 April, 2012, and had at least one recorded HbA1c value. Table 8 and Figure 8 show the percentage of children and young people in different age groups by sex and nation that had their HbA1c measured. In England 97.6% of males and females under the age of 25 years had their HbA1c measured and 98.9% in Wales. This is considerably improved from 2011-12, where 89.3% of males and females in England and Wales had their HbA1c measured. | | | | Boys | Girls | |----------------|---------|-------|---------|----------| | | England | Wales | England | Wales | | 0-4 | | | | | | 97.7 | 97.1 | 96.4 | 100.0 | | | 5-9 | | | | | | 97.8 | 99.2 | 97.6 | 99.1 | | | 10-14 | | | | | | 98.0 | 99.7 | 97.9 | 97.6 | | | 15-19 | | | | | | 97.3 | 100.0 | 96.8 | 99.3 | | | 20-24 | | | | | | 87.9 | 0.0 | 94.3 | 0.0 | | | Total Under 25 | | | | | | 97.7 | 99.5 | 97.4 | 98.2 | | ## 6. Outcomes Of Care 6.1 Treatment Targets Treatment targets can be viewed as part of the process of care or as an 'intermediate outcome', i.e. an intermediary step between a care process of the patient and a 'hard' endpoint such as development of complications. For 2012-13 the NPDA has reported HbA1c values in accordance with the International Federation of Clinical Chemistry and Laboratory Medicine (IFCC), i.e. standardised concentrations of mmol/mol only. HbA1c values submitted to the NPDA using the Diabetes Control and Complications Trial (DCCT) aligned measures of percentage (%) were converted to mmol/mol using the formula: IFCC (mmol/mol) = (10.93 x DCT (%)) - 23.50 In addition, from 2011-12, multiple HbA1cs have been submitted on each patient to give a more representative measure of diabetes control over the year of care, and to bring the analysis into line with other international reporting audits and registries, making benchmarking more representative. There were a total of 76,011 HbA1c values submitted to the NPDA which could be included in this year's analysis, after excluding 1,570 observations which contained no diagnosis date for the patient. HbA1c values recorded less than three months from diagnosis were then excluded as they are not representative of patients overall diabetes control, leaving 73,068 values. After data cleaning (removal of invalid values, date of measurement outside the Audit year, invalid PDU code, invalid gender), a total of 67,806 HbA1c values were retained. In keeping with other international audits and registries the median HbA1c value, rather than the mean for the year for each patient, was used in the analysis. Furthermore, there was little difference between means and medians at patient level. There was a total of 21,348 patients with at least one HbA1c recorded during the Audit year, giving an average of 3.1 HbA1c values per patient (range 1 to 19). ## 6.1.1 Hba1C Target Achievement Table 9 shows the percentage of children and young people with diabetes achieving the HbA1c target ranges of less than 58 mmol/mol, equal to or greater than 58 mmol/mol to equal to or less than 80 mmol/mol, and greater than 80 mmol/mol by country and sex in 2012-13. There has been a small decrease in the overall percentage of children and young people with diabetes achieving an HbA1c less than 58 mmol/mol from 17.4% in 2011-12 to 15.8% in 2012-13. However, this still represents either an improvement or similarity to 2009- 10 and 2010-11 where the figures were 14.5% and 15.8%, respectively. The greatest numbers (58.4%) of patients have an HbA1c between 58 mmol/mol and 80 mmol/mol. Just over one quarter of children and young people have an unacceptable HbA1c greater than 80 mmol/mol. | | HbA1c <58 mmol/mol | |-------------------|-----------------------| | HbA1C | | | ≥ | | | 58 to | | | ≤ | | | 80 mmol/mol | | | HbA1 >80 mmol/mol | | | | Female Male | | specified | specified | | England | | | 1,479 | 1,724 | | % | | | 15.3 | 16.5 | | Wales | | | 77 | 82 | | % | | | 13.4 | 13.4 | | England | | | and Wales | | | 1,556 | 1,806 | | % | | | 15.1 | 16.4 | decline year on year of the percentage of children and young people with an HbA1c greater interpretation of this change, due to the difference in the analysis of HbA1c summarised above. In addition, results are not exactly comparable with those from 2010-11 where only one HbA1c value was submitted to the Audit compared to multiple HbA1cs from 2011-12 onwards. England Wales England and Wales 2010-11 2011-12 2012-13 2010-11 2011-12 2012-13 2010-11 2011-12 2012-13 <48 4.3 3.8 3.6 4.6 3.8 2.8 4.3 3.8 3.6 ≥48 and <58 11.4 13.6 12.3 12.9 13.5 10.6 11.5 13.6 12.2 Total <58 15.7 17.4 15.9 17.5 17.3 13.4 15.8 17.4 15.8 ≥58 and ≤80 55.5 56.2 58.3 56.8 55.4 59.5 55.5 56.2 58.4 >80 and ≤102 21.0 19.5 19.1 17.8 20.1 19.7 20.8 19.5 19.1 >102 and ≤124 5.6 5.0 4.7 6.0 5.3 5.3 5.7 5.1 4.8 >124 and ≤147 2.0 1.7 1.9 1.9 1.9 2.0 2.0 1.7 1.9 >147and ≤169 0.2 0.1 0.0 0.0 0.0 0.1 0.2 0.1 0.0 >169 0.0 0.0 0.0 0.0 0.1 0.0 0.0 0 0.0 White Asian Black Mixed Other Not stated Unknown Total HbA1c <58 Number 65 162 43 46 593 18 3,345 % 15.9 12.5 15.7 12.0 16.0 16.3 18.6 15.8 Number 9,040 265 540 157 166 2,127 54 12,349 HbA1 ≥58 to ≤80 % 59.4 51.1 52.3 43.7 57.6 58.5 55.7 58.4 HbA1 >80 Number 3,768 189 331 159 76 917 25 5,465 % 24.8 36.4 32.0 44.3 26.4 25.2 25.8 25.8 Total Number 15,226 519 1,033 359 288 3,637 97 21,159 % 100 100 100 100 100 100 100 100 Please note: where the percentage of incomplete HbA1c data is high, or the number of patients submitted low, the validity of the percentage with an HbA1c less than 58 mmol/mol for an individual PDU should be interpreted with caution, as it may not truly represent that unit's overall outcome. Incomplete HbA1c data for a patient is defined as: no HbA1c submitted, invalid HbA1c result, no date attached to the result or date outside the Audit period. See Appendix A for further details for each PDU. *A list of PDU PZ codes and corresponding Unit names can be found in Appendix A. ## 6.1.2 Paediatric Diabetes Unit Variation In Hba1C Table 12 shows mean and standard deviation, median and interquartile range for HbA1c for England, Wales and the English regions. Overall for England and Wales there has been no change in the mean but a decrease in the median HbA1c by 2 mmol/mol from 2011-12 to 2012-13. The change is more marked in England where the median has reduced by 2 mmol/mol with the mean remaining the same, whereas in Wales the fall in median was 1 mmol/mol with an increase in the mean of 1 mmol/mol. The mean and median values for each region in England are similar, with means ranging between 70 and 75 mmol/mol, and medians between 67 and 72 mmol/mol. This is an improvement from 2011-12 where the respective figures were between 68 and 76 mmol/mol for mean and 67 to 73 mmol/mol for median HbA1c by region. Every region within England (apart from the median in the North West and mean in South Central) has either shown an improvement or kept the same mean and median HbA1c between 2011-12 and 2012-13. 25th 75th Interquartile Mean Median Standard deviation percentile percentile range England 73 (73) 69 (71) 18 61 81 20 Wales 74 (73) 70 (71) 18 62 81 20 England and Wales 73 (73) 69 (71) 18 61 81 20 Regions in England East 75 (75) 72 (72) 18 63 83 20 East Midlands 70 (71) 68 (68) 17 60 78 18 London 73 (74) 70 (71) 19 61 83 22 North East 72 (73) 69 (71) 17 61 79 18 North West 72 (72) 69 (68) 17 61 80 19 South Central 70(68) 67 (67) 16 60 77 17 South East 73 (74) 70 (71) 18 62 81 19 South West 72 (73) 68 (71) 18 61 80 19 West Midlands 74 (76) 71 (73) 19 62 83 21 Yorkshire and the Humber 72 (73) 69 (71) 17 60 80 19 The following box plots (Figures 13 to Figure 23) show the median, interquartile range and outlying values of HbA1c measurements by region and by PDU (refer to Appendix A for the identification of each PDU). The PDUs have been separated by the various countries and regions in England. Please note: Where the % of incomplete HbA1c data is high, or the number of submitted patients low, care must be taken in the interpretation of the results for an individual PDU. Refer to Appendix A for details of incomplete HbA1c data and patient numbers.   respectively. Reference lines represent the upper and lower NICE HbA1c targets of 58 mmol/mol and 80 mmol/mol respectively. 6.2 Funnel plots of mean HbA1c and %>80mmol/mol by Paediatric Diabetes Unit   'Funnel plots' are recommended as a graphical aid for institutional comparisons, in which an estimate of an underlying quantity is plotted against an interpretable measure of its precision.3 They are named this way because they include 'control limits' constructed from significance limits or confidence intervals, which form a funnel around the target outcome, in an analogy to control charts used for industrial quality improvement. They are flexible, attractively simple and avoid spurious ranking of institutions into league tables. They can be used for comparing proportions and changes in rates, assessing association between outcome and volume of cases. They have been recommended as a method of comparing healthcare providers by the National Clinical Audit Advisory Group.4 Figure 24 shows a funnel plot of unadjusted mean HbA1c for PDUs in England and Wales, obtained from the unit mean of individual patient median HbA1c values. PDUs can be identified using Appendix B which provides the unit size and unadjusted mean HbA1c which can be used as x and y coordinates to find an individual unit. The limits for the outliers have been set as 5% and 2% which was recommended by the National Clinical Audit Advisory Group (4). These limits represent an 'alert' or an 'alarm' respectively for the performance indicator of an individual unit. *Refer to Appendix B to identify an individual PDU. The National Clinical Audit Advisory Group also recommends that funnel plots should be statistically adjusted to take account of 'casemix' variation between providers' treatment populations. Adjustment is a method of dealing with over-dispersion in the raw data due to unmeasured risk factors i.e. patient characteristics. NPDA data contains some, but by no means all, the patient risk factors which may affect target achievement. Table 13 shows a multivariate multiple regression analysis of patient risk/predictive factors for HbA1c. A negative regression coefficient denotes a negative effect on the outcome and vice versa for a positive coefficient. The proportion of the variance in values explained by a regression model is given by the R-squared statistic. The R-squared for this model is 0.083 i.e. the variables included explains 8.3% of the variance. | HbA1c value (mmol/mol) | Coef. | |------------------------------|---------------| | 95% Confidence | | | Age (years) | | | 0.92 | [0.86-0.99] | | Gender | | | | | | | | | Male | | | 0 | | | | | | Female | 1.12 | | Not specified | -2.86 | | Ethnicity | | | | | | | | | White | | | 0 | | | | | | | | | Asian | 4.96 | | Black | 0.79 | | Mixed | 5.54 | | Other | 0.28 | | Not stated | 0.04 | | Unknown | 0.67 | | Deprivation (quintiles) | | | | | | | | | 1st | 0 | | | | | 2nd | 1.18 | | 3rd | 3.22 | | 4th | 5.34 | | 5th | 5.73 | | Duration of diabetes (years) | | | 0.39 | [0.33-0.44] | | Constant | | | 55.28 | [54.35-56.21] | The results of the regression modelling can be used to predict HbA1c values for each patient using the significant risk factors in Table 13. Figure 25 shows a funnel plot of the adjusted mean HbA1c by PDU which takes into account the 'casemix' for each individual PDU. PDUs can be identified using Appendix B which provides the unit size and adjusted mean HbA1c which can be used as x and y coordinates to find an individual unit. The adjusted mean HbA1c in this model does not take into account the effect of any remaining unmeasured risk factors, which we know from the R-squared value comprise the majority of the variance. If the variables used for adjustment only explain a small proportion of the differences in patients' HbA1c, the adjusted values will show less variation than the observed values but more than would be present if data was included for all risk factors. This is because many other risk factors are contributing to the variance which has not been included in the model. interval p-value Std. Err. The reduction in dispersion can be seen by comparing Figure 25 to Figure 24. By reference to Appendix B individual PDUs can obtain their unadjusted and adjusted mean HbA1c. The adjusted mean HbA1c gives a measure of performance taking into account the significant variables in the population that influence it. For some units this influences where they lie within the funnel plot and whether they are defined as an outlier or not. *Refer to Appendix B to identify an individual PDU. In a similar manner to using the mean HbA1c for a PDU, funnel plots for thresholds can be created using pre-defined 'cut-offs'. Figure 26 shows a funnel plot of the unadjusted proportion of patients with an HbA1c above 80 mmol/mol. PDUs can be identified using Appendix B, which provides the unit size and unadjusted percentage of patients with an HbA1c greater than 80 mmol/mol which can be used as x and y coordinates to find an individual unit. *Refer to Appendix B to identify an individual PDU. Using a threshold which has been adjusted in the same way as mean HbA1c is problematic because of the reduction in variation mentioned above. An alternative is to fit a logistic regression model, which can be used to predict the probability that HbA1c levels meet or do not meet a defined threshold. Table 14 displays a logistic regression model of risk factors for the proportion of children and young people with diabetes with an HbA1c greater than 80 mmol/mol. Logistic regression generates odds ratios (ORs) rather than regression coefficients; an OR of unity means there is no effect, an OR greater than 1 means an increase in the outcome, and vice versa for an OR less than 1. The R-squared for this model is 0.071 i.e. 7.1% of the variability is explained by the variables in the model. | Above 80 (mmol/mol) | Odds Ratio | |------------------------------|-----------------| | 95% Confidence | | | Age (years) | | | 1.17 | [1.15-1.18] | | Gender | | | | | | Male | | | 1 | | | | | | Female | 1.13 | | Not specified | 1.00 | | Ethnicity | | | | | | White | | | 1 | | | | | | | | | Asian | 1.83 | | Black | 1.30 | | Mixed | 2.27 | | Other | 1.01 | | Not stated | 1.04 | | Unknown | 1.15 | | Deprivation (quintiles) | | | | | | 1st | | | 1 | | | | | | 2nd | 1.18 | | 3rd | 1.58 | | 4th | 2.06 | | 5th | 2.15 | | Duration of diabetes (years) | | | 1.03 | [1.0196-1.0351] | interval p-value Std. Err. *Refer to Appendix B to identify an individual PDU. ## 7. Conclusions And Recommendations The results from this 2012-13 NPDA report for England and Wales indicates that those delivering care to children and young people with diabetes are developing strategies demonstrating quality improvement. There have been significant improvements in the recording of individual care processes, albeit that the proportion of patients receiving all seven care processes is still extremely low. The median HbA1c has fallen by 2 mmol/mol since 2011-12, with this rate of fall being consistent with those identified in other European countries in which improvements have already taken place. Furthermore, this now represents the third year where there has been a fall in median HbA1c. Casemix adjustment in mean HbA1c and percentage of patients with poor outcomes (greater than 80 mmol/mol) for each PDU have been reported for the first time in 2012-13, allowing PDUs to observe their outlier status before and after adjustment for their patient characteristics. However, the models of adjustment can only take into account those patient related variables that are collected by the NPDA. For mean HbA1c the model only accounts for just over 8% of the variability and for the proportion of patients with an HbA1c >80mmol/mol the model only accounts for just over 7% of the variability. Clearly, therefore over 90% of the variability in outcome must be explained by service related factors such as structure, resource and delivery of care. It is likely that the improvements demonstrated in this report have been achieved by the concerted efforts of all PDUs to engage in the work of their regional diabetes networks. The peer review quality assurance programme has facilitated the sharing of all the good practices that influence improved outcomes and it has facilitated their early adoption across the nation. This should lead to a reduction in the variability in outcomes. In England, the Best Practice Tariff introduced in 2012 will undoubtedly start to provide the ability to financially resource PDUs in a manner that will provide improved quality of care. It is still probably too early for the 2012-13 NPDA data collection and report to demonstrate the influence that its introduction may have had. Furthermore, any change is going to be slow as the population of children and young people with diabetes in England and Wales is large. The peer review quality assurance programme, which will complete its first round of site visits for both England and Wales by the end of 2014, will be able to help PDU's to identify their strengths and weaknesses, and encourage all PDUs to develop ongoing work plans to drive up quality of care. All PDUs should utilise the data provided in this report in a positive manner. In addition, discussions and actions at both local and regional network level should be employed to develop the strategies that will lead to the delivery of better quality care and improved outcomes. These will continue to be measured by ongoing participation in the NPDA. Despite the improvements demonstrated in the report, it is not the time to rest on our laurels. There is clearly much work to be done to reduce variability and improve outcomes across England and Wales. PDUs and all healthcare professionals involved in the care of children and young people with diabetes have a responsibility to ensure optimal achievable outcomes for their patients so they can live as normal, and complication free, lifestyles as possible. ## 8. Acknowledgements And Collaborators National Paediatric Diabetes Audit Project Board  Dr Jeremy Allgrove, Consultant Paediatric Endocrinologist, Barts Health NHS Trust (IT Solutions Adviser)  Ms Katie Beddows, Paediatric Diabetes Specialist Nurse, Stockport NHS Foundation Trust (Senior User)  Dr Fiona Campbell, Consultant Paediatric Diabetologist, Leeds Teaching Hospitals NHS Trust  Ms Kate Fazakerley, Parent representative  Dr Michael Soljak, Clinical Research Fellow, Imperial College London  Dr Justin Warner, Clinical Lead, RCPCH and Consultant in Paediatric Endocrinology and Diabetes, University of Wales Hospital Project Management  Mr Siôn Morris, Project Manager, RCPCH,  Dr Alison Elderfield, Project Manager, RCPCH  Ms Tyler Moorehead, Programme Manager, RCPCH ## Project Support  Ms Naima Hussein, Project Administrator, RCPCH  Ms Melanie David-Feveck, Project Administrator, RCPCH Data Analysis  Dr Michael Soljak (Clinical Research Fellow, Imperial College London)  Emilie Kottenmeier (Research Assistant, Imperial College London) National Paediatric Diabetes Audit Dataset Working Group  Dr Fiona Campbell, Consultant Paediatric Diabetologist, Leeds Teaching Hospitals NHS Trust (Chair)  Dr Rakesh Amin, Consultant in Paediatric and Adolescent Endocrinology and Diabetes, Great Ormond Street Hospital for Children NHS Trust  Dr James Greening, Consultant Paediatric Endocrinologist and Diabetologist, University Hospitals Leicester NHS Trust  Dr Piyusha Kapila, Consultant Paediatrician, North Middlesex University Hospital NHS Trust)  Ms Helen Thornton, Paediatric Diabetes Specialist Nurse, St Helens and Knowsley Teaching Hospitals NHS Trust National Paediatric Diabetes Audit Patient Reported Experience and Outcome Measures Working Group  Dr Deborah Christie, Consultant Clinical Psychologist and Reader in Paediatric and Adolescent Psychology, University College London Hospitals NHS Foundation Trust (Chair)  Ms Judith Campbell, Paediatric Diabetes Specialist Nurse, Central Manchester University Hospitals NHS Foundation Trust  Ms Kate Fazakerley, Parent representative  Professor Peter Hindmarsh, Professor of Paediatric Endocrinology, University College London  Mr Neil Musgrove, Parent representative  Dr Shakeel Rahman, Consultant Paediatrician, Harrogate Health Care NHS Trust  Dr Nicola Trevelyan, Consultant Paediatrician, Southampton University Hospitals NHS Trust National Paediatric Diabetes Audit Collaborators  Association of Children's Diabetes Clinicians  British Dietetic Association  The British Psychological Society  British Society for Paediatric Endocrinology and Diabetes  Diabetes UK  Royal College of Nursing  Juvenile Diabetes Research Foundation (JDRF) ## 9. References   1. National Institute for Health and Clinical Excellence. Diagnosis and management of Type 1 diabetes in children, young people and adults: National Institute for Health and Clinical Excellence, 2004. 2. Health and Social Care Information Centre. National Diabetes Audit 2011–2012 Report 1: Care Processes and Treatment Targets. Leeds: Health and Social Care Information Centre, 2013. 3. Spiegelhalter DJ. Funnel plots for comparing institutional performance. Statistics in Medicine 2005;24(8):1185-202 doi: 10.1002/sim.1970 [published Online First: Epub Date]. 4. National Clinical Audit Advisory Group. Detection and management of outliers: guidance prepared by National Clinical Audit Advisory Group: Healthcare Quality Improvement Partnership, 2011. 5. Department of Health. National Service Framework for Diabetes: London: Department of Health, 2001. care % of processes records of incomplete mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c outcome excluded from HbA1c Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for to NPDA Total no. submitted of patients PDU code PDU Name ## Appendix A: Data On Paediatric Diabetes Units In The 2012-13 National Paediatric Diabetes Audit NOTE: Where the percentage of incomplete HbA1c data is high, or the number of patients submitted low, the validity of the percentage with an HbA1c <58 mmol/mol (7.5%), mean and median HbA1c for an individual Paediatric Diabetes Unit should be interpreted with caution, as it may not truly represent that unit's overall outcome. Incomplete data is defined as: no HbA1c submitted, invalid HbA1c result, no date attached to the result or date outside the Audit period. HbA1c result less than 3 months from diagnosis are not included in the analysis. *Eligible patients were those greater than 3 month post diagnosis. **For HbA1c to be included in the analysis the patient needed a valid date of diagnosis, a valid submitted value and a date of submission which was within the Audit year. Where more than one HbA1c was submitted for a patient the median value was used for the Audit year. except Hba1c analysis analysis 88 84 56 28 33.3% 12.5% 73.9 68.8 22.3% 211 211 172 39 18.5% 12.8% 72.8 68.0 39.2% 136 133 108 25 18.8% 12.0% 70.3 69.4 30.6% 148 145 123 22 15.2% 29.3% 66.2 64.5 23.4% 257 254 223 31 12.2% 20.6% 70.0 68.0 29.1% PZ001 Singleton Hospital, Abertawe Bro Morgannwg University Health Board, Wales PZ002 Norfolk and Norwich University Hospital, Norfolk and Norwich University Hospital Trust, East of England PZ004 Northampton General Hospital, Northampton General Hospital NHS Trust, East Midlands PZ005 Derbyshire Children's Hospital, Derby Hospitals NHS Foundation Trust, East Midlands PZ006 Doncaster Royal Infirmary, Doncaster and Bassetlaw Hospitals NHS Foundation Trust, Yorkshire and the Humber PZ007 John Radcliffe Hospital, Oxford 344 340 299 41 12.1% 29.8% 64.0 63.0 29.0% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 75 75 75 0 0.0% 6.7% 76.2 70.5 56.4% 121 116 106 10 8.6% 11.3% 75.5 72.1 38.9% 126 126 105 21 16.7% 4.8% 80.3 78.0 39.9% to NPDA Total no. submitted of patients Radcliffe Hospitals NHS Trust, South Central PDU code PDU Name PZ009 Macclesfield District General Hospital, East Cheshire NHS Trust, North West 96 95 84 11 11.6% 21.4% 69.9 66.3 30.1% PZ010 Luton and Dunstable Hospital, Luton and Dunstable Hospital NHS Foundation Trust, East of England PZ011 Glan Clwyd District General Hospital, Besti Cadwaladr University Health Board, Wales PZ012 Barnet Hospital, Barnet and Chase Farm Hospitals NHS Trust, London and South East 55 53 47 6 11.3% 12.8% 76.5 73.0 56.1% 67 65 58 7 10.8% 24.1% 71.2 68.3 33.8% 94 92 83 9 9.8% 20.5% 70.6 66.1 22.3% 90 89 55 34 38.2% 10.9% 70.7 67.2 52.0% 234 232 201 31 13.4% 10.5% 75.0 72.7 73.9% PZ014 Chase Farm Hospital, Barnet and Chase Farm Hospitals NHS Trust, London and South East PZ015 Wythenshawe Hospital, University Hospital of South Manchester NHS Foundation Trust, North West PZ016 Bassetlaw Hospital, Doncaster and Bassetlaw Hospitals NHS Foundation Trust, Yorkshire and the Humber PZ017 Dorset County Hospital, Dorset County Hospital NHS Foundation Trust, South Central PZ018 Worthing Hospital, Western Sussex Hospitals NHS, London and South East 130 129 118 11 8.5% 12.7% 76.4 71.9 21.6% PZ019 Basildon Hospital, Basildon and Thurrock University Hospitals NHS Foundation Trust, East of England care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 38 36 34 2 5.6% 5.9% 76.5 68.7 64.8% 118 117 0 117 100.0% NO DATA NO DATA NO DATA 92.9% 114 113 93 20 17.7% 11.8% 78.6 76.0 30.6% 167 165 139 26 15.8% 20.1% 71.5 68.0 39.1% to NPDA Total no. submitted of patients PDU code PDU Name PZ020 Diana Princess Of Wales Hospital, Northern Lincolnshire and Goole Hospitals NHS Foundation Trust, Yorkshire and the Humber PZ021 Wexham Park Hospital, Heatherwood and Wexham Park Hospitals Trust, South Central PZ022 West Cumberland Hospital, North Cumbria University Hospitals NHS Trust, North West PZ023 St George's Hospital, St George's Healthcare NHS Trust, London and South East 95 90 77 13 14.4% 11.7% 73.9 70.0 19.1% 64 60 55 5 8.3% 18.2% 69.9 70.0 34.7% 327 325 281 44 13.5% 13.2% 74.9 72.0 16.0% 258 256 230 26 10.2% 11.7% 75.4 71.0 67.3% PZ024 East Kent Hospitals NHS Trust, East Kent Hospitals University NHS Foundation Trust, London and South East PZ026 Hull Royal Infirmary, Hull and East Yorkshire Hospitals NHS Trust, Yorkshire and the Humber PZ027 Friarage Hospital, South Tees Hospitals NHS Trust, Yorkshire and the Humber/ North East PZ028 Stoke Mandeville Hospital, Buckinghamshire Hospitals NHS Trust, South Central PZ030 Leighton Hospital, Mid-Cheshire Hospitals NHS Trust, North West 110 107 98 9 8.4% 26.5% 65.5 64.0 40.7% PZ031 St Richard's Hospital, Western Sussex Hospitals NHS Trust, London and South 88 88 81 7 8.0% 8.6% 74.0 72.7 45.3% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 121 121 98 23 19.0% 13.3% 71.0 67.5 27.1% 251 244 209 35 14.3% 24.4% 67.2 64.0 34.9% 143 139 124 15 10.8% 12.9% 73.3 69.0 58.7% to NPDA Total no. submitted of patients East PDU code PDU Name PZ032 Royal Victoria Infirmary, The Newcastle Upon Tyne Hospital Trust, North East 322 318 283 35 11.0% 15.6% 71.8 67.7 41.4% PZ033 Queens Hospital, Burton Hospitals NHS Trust, West Midlands 115 114 105 9 7.9% 9.5% 72.3 69.4 55.8% PZ034 Royal Hampshire County Hospital, Winchester and Eastleigh Healthcare NHS Trust, South Central PZ035 Royal Berkshire Hospital, Royal Berkshire NHS Foundation Trust, South Central PZ036 Whipps Cross University Hospital, Whipps Cross University NHS Trust, London and South East 66 65 56 9 13.8% 8.9% 81.2 76.0 57.3% 276 256 239 17 6.6% 11.7% 74.0 70.0 45.5% 242 242 207 35 14.5% 8.2% 80.2 77.1 60.7% 293 293 264 29 9.9% 28.8% 65.6 65.0 57.5% PZ038 Wycombe General, Buckinghamshire Hospitals NHS Trust, South Central 114 113 102 11 9.7% 11.8% 75.5 72.8 13.7% PZ040 Birmingham Heartlands Hospital, Heart of England NHS Foundation Trust, West Midlands PZ041 Addenbrooke's Hospital, Cambridge University Hospitals NHS Foundation Trust, East of England PZ042 Nottingham Children's Hospital, Nottingham University Hospitals NHS Trust, East Midlands PZ045 Whittington Hospital, Whittington Hospital NHS Trust, London and South East PZ047 Airedale General Hospital, Whittington 74 73 66 7 9.6% 10.6% 70.2 67.0 28.3% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 121 120 107 13 10.8% 14.0% 72.9 70.0 49.7% 155 151 140 11 7.3% 20.0% 67.4 66.3 21.7% 120 122 101 21 17.2% 11.9% 78.0 75.0 11.9% to NPDA Total no. submitted of patients Hospital NHS Trust, Yorkshire and the Humber PDU code PDU Name PZ048 Lincoln County Hospital, United Lincolnshire Hospitals NHS Trust, East Midlands PZ049 Warrington General Hospital, Warrington and Halton Hospitals NHS Foundation Trust, North West PZ050 Queen Mary's Hospital for Children, Epsom and St Helier Trust, London and South East PZ052 Nevill Hall Hospital, Aneurin Bevan Health Board, Wales 92 91 66 25 27.5% 12.1% 76.2 75.5 38.2% 101 99 79 20 20.2% 11.4% 74.3 73.0 16.1% 109 108 90 18 16.7% 11.1% 79.0 79.0 30.5% 385 380 325 55 14.5% 10.5% 73.6 69.4 0.0% PZ053 Scunthorpe General Hospital, Northern Lincolnshire and Goole Hospitals NHS Foundation Trust, Yorkshire and the Humber PZ054 Poole General Hospital, Poole Hospital NHS Trust, South Central 194 193 161 32 16.6% 14.9% 70.1 68.0 27.8% PZ055 Leicester Royal Infirmary, University Hospitals Leicester NHS Trust, East Midlands PZ056 West Wales General Hospital, Hywel Dda Health Board, Wales 73 70 56 14 20.0% 14.3% 69.1 67.2 8.6% PZ057 Kingston Hospital, Kingston Hospital NHS Trust, London and South East 153 149 132 17 11.4% 22.7% 65.7 63.8 82.1% PZ058 Newham General Hospital, Newham University Hospital NHS Trust, London and South East care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 96 93 83 10 10.8% 10.8% 75.4 73.0 10.2% 113 111 104 7 6.3% 13.5% 76.3 71.0 64.3% 195 190 161 29 15.3% 22.4% 70.0 67.0 39.3% 136 136 112 24 17.6% 13.4% 71.5 70.2 30.8% 190 187 159 28 15.0% 10.1% 75.8 72.0 100.0% to NPDA Total no. submitted of patients PDU code PDU Name PZ059 The Royal London Hospital, Barts and the London NHS Trust, London and South East PZ060 Royal Devon and Exeter, Royal Devon and Exeter NHS Foundation Trust, South West PZ062 Croydon University Hospital, Croydon Health Services NHS Trust, London and South East PZ064 Chesterfield Royal Hospital, Chesterfield Royal Hospital NHS Foundation Trust, East Midlands PZ065 Staffordshire General Hospital, Mid- Staffordshire NHS Foundation Trust, West Midlands 93 93 83 10 10.8% 7.2% 74.6 71.0 29.7% 212 210 175 35 16.7% 14.3% 75.6 72.0 17.4% 204 202 17 185 91.6% 23.5% 71.6 66.0 21.3% PZ067 Royal Cornwall Hospital, Royal Cornwall Hospitals NHS Trust, South West PZ068 Royal United Bath Hospital, Royal United Hospital Bath NHS Trust, South West PZ069 Stepping Hill Hospital, Stockport NHS Foundation Trust, North West 140 138 122 16 11.6% 20.5% 68.1 66.0 61.0% PZ072 West Suffolk Hospital, West Suffolk Hospital NHS Trust, East of England 129 127 108 19 15.0% 20.4% 67.1 65.6 54.7% PZ073 Alexandra Hospital, Worcestershire Acute Hospitals NHS Trust, West Midlands PZ074 Alder Hey Hospital, Alder Hey Children's NHS Foundation Trust, North 248 246 211 35 14.2% 16.6% 72.4 69.0 25.4% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 167 169 149 20 11.8% 16.1% 68.5 66.0 29.5% 189 179 167 12 6.7% 1.2% 81.6 80.3 11.1% 220 220 189 31 14.1% 12.2% 75.0 72.1 51.0% to NPDA Total no. submitted of patients West PDU code PDU Name PZ075 St. Mary's Hospital, Isle of Wight Healthcare NHS Trust, South Central 53 53 45 8 15.1% 17.8% 75.7 68.3 38.5% PZ076 Colchester General Hospital, Colchester Hospital University NHS Foundation Trust, East of England PZ078 North Staffordshire Hospital, University Hospital of North Staffordshire NHS Trust, West Midlands PZ080 Sunderland Royal Hospital, City Hospitals Sunderland NHS Trust, North East 51 50 42 8 16.0% 35.7% 61.7 59.3 97.8% 63 63 59 4 6.3% 17.0% 75.7 69.5 24.3% 96 96 83 13 13.5% 8.4% 73.5 71.6 48.8% 94 94 83 11 11.7% 8.4% 81.8 78.7 40.6% 112 103 88 15 14.6% 17.1% 69.2 66.1 27.4% PZ082 Evelina Children's Hospital at St Thomas Hospital, Guy's and St Thomas' NHS Foundation Trust, London and South East PZ084 Kidderminster General Hospital, Worcestershire Acute Hospitals NHS Trust, West Midlands PZ085 Princess Royal University Hospital, Bromley, South London Healthcare NHS Trust, London and South East PZ086 Hinchingbrooke Hospital, Hinchingbrooke Health Care NHS Trust, East of England PZ088 Royal Surrey County Hospital, The Royal Surrey County Hospital NHS Foundation Trust, London and South East care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 81 81 73 8 9.9% 16.4% 77.3 74.0 51.7% 106 104 21 83 79.8% 14.3% 83.2 81.0 62.1% 190 187 172 15 8.0% 14.5% 71.2 67.3 24.1% 262 260 222 38 14.6% 15.8% 71.5 66.8 45.6% to NPDA Total no. submitted of patients PDU code PDU Name PZ089 Northwick Park Hospital, North West London Hospitals NHS Trust, London and South East PZ090 Pontefract General Infirmary, The Mid- Yorkshire Hospitals NHS Trust, Yorkshire and the Humber PZ091 East Lancashire Diabetic Service, East Lancashire Hospitals NHS Trust, North West PZ092 Princess of Wales Hospital, Abertawe Bro Morgannwg University Health Board, Wales PZ094 The Princess Royal, Royal Shrewsbury Hospitals NHS Trust, West Midlands 260 257 225 32 12.5% 16.0% 73.0 70.0 49.9% 65 34 28 6 17.6% 14.3% 72.7 67.5 21.2% 86 86 70 16 18.6% 20.0% 69.6 65.3 50.0% 225 222 216 6 2.7% 13.9% 72.3 68.3 28.2% 350 337 295 42 12.5% 27.5% 67.1 65.0 26.6% PZ096 Derriford Hospital, Plymouth Hospitals NHS Trust, South West 176 175 153 22 12.6% 21.6% 66.4 65.0 20.2% PZ097 City Hospital Birmingham, Sandwell and West Birmingham Hospitals NHS Trust, West Midlands PZ099 East and North Herts NHS Trust - incorp: Queen Elizabeth II , The Lister, East and North Hertfordshire NHS Trust, East of England PZ100 North Devon District Hospital, Northern Devon Healthcare NHS Trust, South West PZ101 Leeds Children's Hospital, Leeds Teaching Hospitals NHS Trust, Yorkshire and the Humber PZ102 Hillingdon Hospital, Hillingdon Hospital 153 143 131 12 8.4% 13.0% 76.5 72.7 22.4% care % of processes records of incomplete except Hba1c 5 mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 84 84 84 0 0.0% 11.9% 78.5 74.5 21.5% 126 124 107 17 13.7% 17.8% 74.8 71.6 35.2% 195 193 156 37 19.2% 12.8% 76.9 75.5 56.2% to NPDA Total no. submitted of patients NHS Trust, London and South East PDU code PDU Name PZ104 Royal Albert Edward Infirmary, Wrightington, Wigan and Leigh NHS Foundation Trust, North West PZ105 St Luke's Hospital, Bradford Teaching Hospitals NHS Trust, Yorkshire and the Humber PZ106 Victoria Hospital, Blackpool, Fylde and Wyre Hospitals NHS Trust, North West 112 111 94 17 15.3% 17.0% 70.4 69.8 51.8% PZ107 Queen Elizabeth Hospital, Gateshead Health NHS Foundation Trust, North East 92 91 83 8 8.8% 14.5% 67.7 65.6 38.3% 102 102 92 10 9.8% 28.3% 69.7 65.0 51.2% 343 339 286 53 15.6% 22.4% 70.2 67.2 65.4% 249 247 215 32 13.0% 19.1% 69.7 67.2 19.0% PZ108 Birmingham Children's Hospital, Birmingham Children's Hospital NHS Foundation Trust, West Midlands PZ109 Southampton General Hospital, Southampton University Hospitals NHS Trust, South Central PZ110 Ormskirk District General Hospital, Southport and Ormskirk NHS Trust, North West PZ111 Hereford County Hospital, Wye Valley NHS Trust, West Midlands 67 66 60 6 9.1% 21.7% 68.9 67.2 27.2% PZ112 Scarborough General Hospital, Scarborough and North East Yorkshire Healthcare NHS Trust, Yorkshire and the Humber PZ113 University Hospital of Wales, Cardiff and Vale University Health Board, 226 225 192 33 14.7% 10.9% 77.8 76.2 37.5% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 85 84 69 15 17.9% 15.9% 67.0 66.7 25.0% 115 111 83 28 25.2% 20.5% 74.2 68.0 17.5% 116 114 101 13 11.4% 10.9% 73.3 71.0 50.9% 158 157 153 4 2.5% 16.3% 69.7 66.0 51.0% to NPDA Total no. submitted of patients Wales PDU code PDU Name PZ114 York District Hospital, York Teaching Hospital NHS Foundation Trust, Yorkshire and the Humber PZ118 University Hospital Lewisham, Lewisham and Greenwich NHS Trust, London and South East PZ119 Darent Valley Hospital, Dartford and Gravesham NHS Trust, London and South East PZ120 North Tyneside General Hospital, North Shields, Northumbria Healthcare NHS Foundation Trust, North East 95 95 87 8 8.4% 20.7% 68.2 67.0 77.0% 121 120 103 17 14.2% 8.7% 75.7 71.6 39.5% 185 182 157 25 13.7% 10.2% 78.4 75.0 52.6% 247 246 213 33 13.4% 15.5% 74.5 71.6 47.6% PZ121 George Eliot Hospital, George Elliot Hospital NHS Trust, West Midlands 76 76 53 23 30.3% 20.8% 74.4 74.0 41.9% PZ122 University Hospital Coventry, University Hospitals Coventry and Warwickshire NHS Trust, West Midlands PZ125 Maidstone Hospital, Maidstone and Tunbridge Wells Area and NHS Trust, London and South East PZ126 Medway Maritime Hospital, Medway NHS Foundation Trust, London and South East PZ127 James Paget Hospital, James Paget University Hospitals NHS Foundation Trust, East of England PZ128 Pilgrim Hospital, United Lincolnshire 94 91 73 18 19.8% 19.2% 68.7 66.0 48.9% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 75 75 65 10 13.3% 18.5% 70.8 69.5 57.0% 171 168 152 16 9.5% 13.8% 73.3 71.0 19.8% 115 113 86 27 23.9% 10.5% 74.9 70.0 47.3% 172 171 153 18 10.5% 9.8% 75.9 73.0 26.7% to NPDA Total no. submitted of patients Hospitals NHS Trust, East Midlands PDU code PDU Name PZ129 Harrogate General Hospital, Harrogate and District NHS Foundation Trust, Yorkshire and the Humber PZ130 Chelsea and Westminster Hospital, Chelsea and Westminster Hospital NHS Trust, London and South East PZ131 Peterborough General, Peterborough and Stamford Hospitals NHS Trust, East of England PZ132 Ysbyty Gwynedd Hospital, Besti Cadwaladr University Health Board, Wales 241 231 188 43 18.6% 22.3% 72.0 69.8 54.4% 186 183 165 18 9.8% 20.6% 72.1 68.5 54.6% 164 162 144 18 11.1% 17.4% 71.5 69.0 30.7% PZ133 James Cook University Hospital, South Tees Hospitals NHS Trust, North East 140 139 122 17 12.2% 21.3% 68.9 64.4 35.0% PZ134 Trafford General Hospital, Trafford Healthcare NHS Trust, North West 69 69 64 5 7.2% 12.5% 76.0 72.0 23.8% PZ135 Royal Alexandra Hospital, Brighton and Sussex University Hospitals NHS Trust, London and South East PZ136 Royal Manchester Children's Hospital, Central Manchester University Hospitals NHS Foundation Trust, North West PZ137 Musgrove Park Hospital, Taunton and Somerset NHS Foundation Trust, South West PZ138 Warwick Hospital 92 91 79 12 13.2% 10.1% 76.2 75.0 29.0% PZ139 Bristol Royal Hospital for Children, 471 466 403 63 13.5% 24.8% 69.0 66.0 30.4% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 63 61 54 7 11.5% 5.6% 75.7 72.1 16.7% 138 128 102 26 20.3% 13.7% 77.8 74.5 66.9% to NPDA Total no. submitted of patients University Hospitals Bristol NHS Foundation Trust, South West PDU code PDU Name PZ140 Tameside General, Tameside Hospital NHS Foundation Trust, North West 66 63 53 10 15.9% 5.7% 79.4 76.0 39.5% PZ141 South Tyneside District Hospital, South Tyneside NHS Foundation Trust, North East PZ143 King George Hospital, Barking, Havering and Redbridge University Hospitals NHS Trust, London and South East PZ144 Good Hope Hospital, Heart of England NHS Foundation Trust, West Midlands 146 144 125 19 13.2% 8.8% 77.9 72.7 52.4% 113 112 95 17 15.2% 19.0% 69.0 67.2 59.1% 114 113 94 19 16.8% 10.6% 78.8 79.2 51.2% 128 125 110 15 12.0% 10.0% 73.8 70.5 19.1% 120 119 100 19 16.0% 13.0% 74.5 71.6 66.7% 104 104 91 13 12.5% 15.4% 74.6 73.8 63.1% PZ145 Milton Keynes Hospital, Milton Keynes Hospital NHS Foundation Trust, South Central PZ146 Southend General Hospital, Southend University Hospital NHS Foundation Trust, East of England PZ149 Barnsley District General Hospital, Barnsley Hospital NHS Foundation Trust, Yorkshire and the Humber PZ150 Cumberland Infirmary, Cumbria Partnership NHS Foundation Trust, North East PZ151 Queen Elizabeth Hospital Lewisham and Greenwich NHS Trust, London and South East PZ152 Torbay Hospital, South Devon 108 105 93 12 11.4% 5.4% 77.9 75.0 28.5% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 54 50 44 6 12.0% 6.8% 68.7 66.1 23.2% 66 62 56 6 9.7% 12.5% 72.6 72.0 25.0% 152 147 128 19 12.9% 7.8% 81.4 80.3 44.8% 170 170 141 29 17.1% 16.3% 71.7 68.9 20.0% to NPDA Total no. submitted of patients Healthcare NHS Foundation Trust, South West PDU code PDU Name PZ153 Whiston Hospital, St Helens and Knowsley Teaching Hospitals NHS Trust, North West PZ156 Queen Elizabeth, Kings Lynn, Queen Elizabeth Hospitals NHS Trust, East of England PZ157 Royal Free and University College Hospital, Royal Free Hampstead NHS Trust, London and South East PZ158 Epsom General Hospital, Epsom and St Helier University Hospitals NHS Trust, London and South East 110 109 101 8 7.3% 15.8% 73.1 68.0 28.2% 135 135 99 36 26.7% 15.2% 73.6 71.5 70.7% 142 141 127 14 9.9% 19.7% 69.4 66.1 39.0% 147 143 128 15 10.5% 14.8% 71.1 69.5 44.3% 149 147 124 23 15.6% 5.7% 72.1 69.0 32.6% PZ159 Basingstoke and North Hampshire Hospital, Basingstoke and North Hampshire NHS Foundation Trust, South Central PZ162 Bishop Auckland General Hospital, County Durham and Darlington NHS Foundation Trust, North East PZ163 North Tees General Hospital, North Tees and Hartlepool NHS Trust, North East PZ164 Rotherham General Hospital, The Rotherham NHS Foundation Trust, Yorkshire and the Humber PZ167 University Hospitals of Morecambe Bay NHS Foundation Trust, University Hospitals of Morecambe Bay NHS care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 39 37 35 2 5.4% 20.0% 66.5 66.0 53.3% 121 119 99 20 16.8% 8.1% 78.7 74.0 69.1% 165 164 146 18 11.0% 15.8% 67.2 65.3 32.7% to NPDA Total no. submitted of patients Trust, North West PDU code PDU Name PZ168 Grantham and District Hospital, United Lincolnshire Hospitals NHS Trust, East Midlands PZ169 Salisbury District Hospital, Salisbury NHS Foundation Trust, South Central 108 106 90 16 15.1% 8.9% 74.0 73.3 43.3% PZ170 Arrowe Park Hospital, Wirral University Teaching Hospital NHS Foundation Trust, North West PZ171 Broomfield Hospital, Mid-Essex Hospital Services NHS Trust, East of England 75 75 75 0 0.0% 12.0% 74.4 70.5 13.2% 155 155 139 16 10.3% 15.1% 69.9 67.3 57.5% 129 129 115 14 10.9% 23.5% 64.7 63.9 36.3% PZ172 Watford General Hospital, West Herts Hospitals NHS Trust, East of England 198 195 170 25 12.8% 9.4% 73.0 70.6 39.4% PZ173 Yeovil District Hospital, Yeovil District Hospital NHS Foundation Trust, South West PZ174 Kettering General Hospital, Kettering General Hospital Trust, East Midlands 117 115 100 15 13.0% 13.0% 72.6 69.0 37.8% PZ175 Queen Mary's Hospital, South London Healthcare NHS Trust, London and South East PZ176 St Peter's Hospital, Ashford and St Peter's Hospitals NHS Trust, London and South East PZ177 Royal Bolton Hospital, Bolton Hospital NHS Foundation Trust, North West 108 107 87 20 18.7% 14.9% 69.7 68.0 4.5% PZ178 Manor Hospital, Walsall Healthcare NHS Trust, West Midlands 113 113 19 94 83.2% 5.3% 77.9 73.0 38.0% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 114 114 104 10 8.8% 26.9% 71.5 66.8 29.1% 196 193 175 18 9.3% 13.1% 75.3 73.0 59.4% 146 145 128 17 11.7% 17.2% 67.9 66.1 21.0% 105 104 92 12 11.5% 12.0% 81.2 77.8 44.1% to NPDA Total no. submitted of patients PDU code PDU Name PZ179 Countess of Chester Hospital NHS Foundation Trust, Countess Of Chester Hospital NHS Foundation Trust, North West PZ180 King's Mill Hospital, Sherwood Forest Hospitals NHS Foundation Trust, East Midlands PZ181 Ipswich Hospital, The Ipswich Hospital NHS Trust, East of England 222 219 189 30 13.7% 15.9% 74.8 73.8 29.3% PZ182 West Middlesex University Hospital, West Middlesex University Hospital NHS Trust, London and South East PZ183 Royal Preston Hospital, Lancashire Teaching Hospitals NHS Foundation Trust, North West 57 57 41 16 28.1% 24.4% 68.7 67.0 10.8% 93 93 77 16 17.2% 19.5% 67.6 66.1 12.7% 201 199 173 26 13.1% 16.8% 73.3 70.0 19.6% PZ184 Eastbourne District General Hospital, East Sussex NHS Trust, London and South East PZ185 Bronglais General Hospital, Hywel Dda Local Health Board, Wales 44 43 42 1 2.3% 23.8% 68.9 68.3 10.8% PZ186 Huddersfield Royal Infirmary, Calderdale and Huddersfield NHS Foundation Trust, Yorkshire and the Humber PZ187 Wrexham Maelor Hospital, Besti Cadwaladr University Health Board, Wales PZ188 Royal Gwent Hospital, Aneurin Bevan Health Board, Wales 199 199 165 34 17.1% 9.1% 77.4 73.0 47.4% PZ189 Royal Glamorgan Hospital, Cwm Taf 81 80 69 11 13.8% 20.3% 70.7 69.0 9.5% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 32 29 11 18 62.1% 72.7% 53.9 47.5 50.8% 79 72 62 10 13.9% 9.7% 87.7 87.0 53.8% 45 45 36 9 20.0% 11.1% 68.6 69.0 48.0% to NPDA Total no. submitted of patients Health Board, Wales PDU code PDU Name PZ190 Withybush General Hospital, Hywel Dda Health Board, Wales 52 52 47 5 9.6% 4.3% 76.0 72.0 27.1% PZ191 Ealing Hospital, Ealing Hospital NHS Trust, London and South East 124 120 105 15 12.5% 7.6% 83.3 80.3 81.1% PZ193 Neath Port Talbot Hospital, Abertawe Bro Morgannwg University Health Board, Wales PZ195 Central Middlesex Hospital, North West London Hospitals NHS Trust, London and South East PZ196 Great Ormond Street Hospital, London, Great Ormond Street Hospital for Children NHS Trust, London and South East 93 91 74 17 18.7% 5.4% 74.7 71.0 4.2% 121 114 104 10 8.8% 10.6% 74.3 71.3 22.3% 90 84 74 10 11.9% 5.4% 81.5 76.5 30.5% 380 342 304 38 11.1% 33.2% 64.1 61.8 89.9% PZ199 North Middlesex University Hospital, North Middlesex University Hospital NHS Trust, London and South East PZ200 The Princess Alexandra, The Princess Alexandra Hospital NHS Trust, East of England PZ202 St Marys Hospital, Imperial College Healthcare NHS Trust, London and South East PZ203 University College Hospital, University College London Hospitals NHS Foundation Trust, London and South East PZ213 East Surrey Hospital, Surrey and Sussex NHS Trust, London and South 166 162 133 29 17.9% 11.3% 71.6 68.9 34.8% care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 97 97 84 13 13.4% 21.4% 67.9 65.3 73.1% 161 155 135 20 12.9% 17.0% 71.0 67.0 33.5% 135 132 123 9 6.8% 9.8% 80.5 77.1 49.2% 228 227 197 30 13.2% 26.4% 68.2 66.1 34.2% to NPDA Total no. submitted of patients East PDU code PDU Name PZ215 King's College Hospital, King's College Hospital NHS Trust, London and South East PZ216 Tunbridge Wells Hospital, Maidstone and Tunbridge Wells Area and NHS Trust, London and South East PZ218 Frimley Park Hospital, Frimley Park Hospital NHS Trust, London and South East PZ219 Sheffield Children's Hospital, Sheffield Children's NHS Foundation Trust, Yorkshire and the Humber 82 81 69 12 14.8% 10.1% 77.7 75.0 57.5% 119 118 96 22 18.6% 31.3% 67.3 64.8 12.1% 179 179 154 25 14.0% 13.6% 73.6 70.0 12.7% 143 142 123 19 13.4% 14.6% 77.2 73.5 62.2% 124 123 112 11 8.9% 15.2% 75.5 73.0 23.0% PZ220 Bedford Hospital, Bedford Hospital NHS Trust, East of England 124 122 104 18 14.8% 7.7% 79.1 76.0 66.2% PZ221 The Great Western Hospital, Great Western Hospitals NHS Foundation Trust, South West PZ222 New Cross Hospital, The Royal Wolverhampton Hospitals NHS Trust, West Midlands PZ223 Sandwell General Hospital, Sandwell and West Birmingham Hospitals NHS Trust, West Midlands PZ225 Worcester Hospital, Worcestershire Acute Hospitals NHS Trust, West Midlands PZ226 Dewsbury and District Hospital, The Mid Yorkshire Hospitals NHS Trust, Yorkshire and the Humber care % of processes records of incomplete except Hba1c mol) HbA1c Median (mmol/ Mean /mol) HbA1c (mmol 58 mol % with mmol/ HbA1c< % from HbA1c analysis outcome excluded from HbA1c analysis Patients outcome excluded HbA1c Patients used for out-come analysis ** HbA1c analysis* Total no. of patients eligible for 167 163 143 20 12.3% 11.9% 76.1 73.0 47.6% 277 275 152 123 44.7% 13.8% 72.3 69.4 64.9% to NPDA Total no. submitted of patients PDU code PDU Name PZ228 Prince Charles Hospital, Cwm Taf Health Board, Wales 69 69 65 4 5.8% 35.4% 62.1 59.0 3.9% PZ230 Conquest Hospital, East Sussex NHS Trust, London and South East 49 46 40 6 13.0% 15.0% 73.2 70.8 34.2% PZ231 Salford Royal Hospital, Salford Royal NHS Foundation Trust, North West 140 140 126 14 10.0% 17.5% 71.5 67.5 23.3% PZ232 Queens Hospital, Barking, Havering and Redbridge University Hospitals NHS Trust, London and South East PZ234 North Manchester General Hospital, The Pennine Acute Hospitals NHS Trust, North West 156 155 103 52 33.5% 7.8% 74.1 72.7 79.2% 296 296 239 57 19.3% 15.5% 70.3 67.0 49.0% PZ238 Queen Alexandra Hospital, Portsmouth Hospitals NHS Trust, South West 221 216 189 27 12.5% 13.2% 70.3 69.0 36.2% PZ240 Russell's Hall Hospital, The Dudley Group of Hospitals NHS Foundation Trust, West Midlands PZ242 Cheltenham and Gloucester Hospital, Gloucestershire Hospitals NHS Trust, South West *Eligible patients were those greater than 3 month post diagnosis. **For HbA1c to be included in the analysis the patient needed a valid date of diagnosis, a valid submitted value and a date of submission which was within the Audit year. Where more than one HbA1c was submitted for a patient the median value was used for the Audit year. PZ003 PZ003 Pinderfields General Hospital, Wakefield (submitted via PZ090) The Mid Yorkshire Hospitals NHS Trust PZ013 PZ013 Furness General Hospital (submitted via PZ167) University Hospitals of Morecambe Bay NHS Foundation Trust PZ029 PZ029 Fairfield General Hospital, Bury, PZ206 Rochdale Infirmary and PZ044 Royal Oldham Hospital (Submitted via PZ234) The Pennine Acute Hospitals NHS Trust Fairfield General Hospital, Bury PZ043 PZ043 St Mary's Hospital for Women and Children Manchester (submitted via PZ136) Central Manchester University Hospitals NHS Foundation Trust NW PZ044 PZ044 Royal Oldham Hospital (submitted via PZ206) The Pennine Acute Hospitals NHS Trust Submitted via PZ234 PZ046 PZ046 Horton Hospital (submitted via PZ007) Oxford Radcliffe Hospitals NHS Trust SC *The following Paediatric Diabetes Units submitted their data through other Units: PZ095 PZ095 Royal Shrewsbury Hospital (submitted via PZ094) The Shrewsbury and Telford Hospital NHS Trust WM PZ116 PZ116 Nottingham University Hospital (submitted via PZ042) Nottingham University Hospitals NHS Trust EM PZ161 PZ161 Darlington Memorial Hospital and PZ160 Bishop Auckland General Hospital (submitted via PZ162) County Durham and Darlington NHS Foundation Trust PZ208 PZ208 Westmoreland General Hospital (submitted via PZ167) University Hospitals of Morecambe Bay NHS Foundation PZ210 PZ210 University Hospital of Hartlepool (submitted via PZ163) North Tees and Hartlepool NHS Trust NE ## 10. Appendix B: Unadjusted And Adjusted Paediatric Diabetes Unit Co-Ordinates For Funnel Plots | Unadjusted | Adjusted | |----------------|--------------| | Proportion (%) | | | PDU code | | | PDU | | | Mean | | | size | | | with HbA1c >80 | | | HbA1c | | | mmol/mol | | | PZ001 | | | 108 | 70.3 | | PZ002 | | | 56 | 73.9 | | PZ004 | | | 172 | 72.8 | | PZ005 | | | 223 | 70 | | PZ006 | | | 123 | 66.2 | | PZ007 | | | 299 | 64 | | PZ009 | | | 84 | 69.9 | | PZ010 | | | 106 | 75.5 | | PZ011 | | | 105 | 80.3 | | PZ012 | | | 75 | 76.2 | | PZ014 | | | 47 | 76.5 | | PZ015 | | | 55 | 70.7 | | PZ016 | | | 58 | 71.2 | | PZ017 | | | 83 | 70.6 | | PZ018 | | | 118 | 76.4 | | PZ019 | | | 201 | 75 | | PZ020 | | | 93 | 78.6 | | PZ021 | | | 139 | 71.5 | | PZ022 | | | 34 | 76.5 | | PZ024 | | | 281 | 74.9 | | PZ026 | | | 230 | 75.4 | | PZ027 | | | 55 | 69.9 | | PZ028 | | | 77 | 73.9 | | PZ030 | | | 98 | 65.5 | | PZ031 | | | 81 | 74 | | PZ032 | | | 283 | 71.8 | | PZ033 | | | 105 | 72.3 | | PZ034 | | | 124 | 73.3 | | PZ035 | | | 209 | 67.2 | | PZ036 | | | 98 | 71 | | PZ038 | | | 102 | 75.5 | | PZ040 | | | 207 | 80.2 | | PZ041 | | | 239 | 74 | | PZ042 | | | 264 | 65.6 | | PZ045 | | | 56 | 81.2 | Proportion (%) Mean with HbA1c >80 HbA1c mmol/mol | | | |----------------|----------------| | Unadjusted | Adjusted | | PDU code | PDU | | Proportion (%) | | | size | | | Mean | with HbA1c >80 | | HbA1c | mmol/mol | | PZ047 | | | 66 | 70.2 | | PZ048 | | | 107 | 72.9 | | PZ049 | | | 140 | 67.4 | | PZ050 | | | 101 | 78.0 | | PZ052 | | | 66 | 76.2 | | PZ053 | | | 79 | 74.3 | | PZ054 | | | 161 | 70.1 | | PZ055 | | | 325 | 73.6 | | PZ056 | | | 56 | 69.1 | | PZ057 | | | 132 | 65.7 | | PZ058 | | | 90 | 79.0 | | PZ059 | | | 161 | 70.0 | | PZ060 | | | 159 | 75.8 | | PZ062 | | | 83 | 75.4 | | PZ064 | | | 112 | 71.5 | | PZ065 | | | 104 | 76.3 | | PZ067 | | | 17 | 71.6 | | PZ068 | | | 175 | 75.6 | | PZ069 | | | 122 | 68.1 | | PZ072 | | | 108 | 67.1 | | PZ073 | | | 83 | 74.6 | | PZ074 | | | 211 | 72.4 | | PZ075 | | | 45 | 75.7 | | PZ076 | | | 167 | 81.6 | | PZ078 | | | 189 | 75.0 | | PZ080 | | | 149 | 68.5 | | PZ082 | | | 83 | 81.8 | | PZ084 | | | 59 | 75.7 | | PZ085 | | | 88 | 69.2 | | PZ086 | | | 83 | 73.5 | | PZ088 | | | 42 | 61.7 | | PZ089 | | | 21 | 83.2 | | PZ090 | | | 172 | 71.2 | | PZ091 | | | 222 | 71.5 | | PZ092 | | | 73 | 77.3 | | PZ094 | | | 225 | 73.0 | | PZ096 | | | 153 | 66.4 | | PZ097 | | | 28 | 72.7 | | PZ099 | | | 216 | 72.3 | | PZ100 | | | 70 | 69.6 | | PZ101 | | | 295 | 67.1 | | PZ102 | | | 131 | 76.5 | Proportion (%) Mean with HbA1c >80 HbA1c mmol/mol | | | |----------------|----------------| | Unadjusted | Adjusted | | PDU code | PDU | | Proportion (%) | | | size | | | Mean | with HbA1c >80 | | HbA1c | | | | | | mmol/mol | | | | | | PZ104 | | | 107 | 74.8 | | PZ105 | | | 156 | 76.9 | | PZ106 | | | 94 | 70.4 | | PZ107 | | | 84 | 78.5 | | PZ108 | | | 286 | 70.2 | | PZ109 | | | 215 | 69.7 | | PZ110 | | | 92 | 69.7 | | PZ111 | | | 60 | 68.9 | | PZ112 | | | 83 | 67.7 | | PZ113 | | | 192 | 77.8 | | PZ114 | | | 153 | 69.7 | | PZ118 | | | 83 | 74.2 | | PZ119 | | | 69 | 67.0 | | PZ120 | | | 101 | 73.3 | | PZ121 | | | 53 | 74.4 | | PZ122 | | | 157 | 78.4 | | PZ125 | | | 87 | 68.2 | | PZ126 | | | 213 | 74.5 | | PZ127 | | | 103 | 75.7 | | PZ128 | | | 73 | 68.7 | | PZ129 | | | 65 | 70.8 | | PZ130 | | | 152 | 73.3 | | PZ131 | | | 153 | 75.9 | | PZ132 | | | 86 | 74.9 | | PZ133 | | | 122 | 68.9 | | PZ134 | | | 64 | 76.0 | | PZ135 | | | 144 | 71.5 | | PZ136 | | | 188 | 72.0 | | PZ137 | | | 165 | 72.1 | | PZ138 | | | 79 | 76.2 | | PZ139 | | | 403 | 69.0 | | PZ140 | | | 53 | 79.4 | | PZ141 | | | 54 | 75.7 | | PZ143 | | | 102 | 77.8 | | PZ144 | | | 125 | 77.9 | | PZ145 | | | 95 | 69.0 | | PZ146 | | | 100 | 74.5 | | PZ149 | | | 110 | 73.8 | | PZ150 | | | 91 | 74.6 | | PZ151 | | | 94 | 78.8 | | PZ152 | | | 93 | 77.9 | | PZ153 | | | 141 | 71.7 | Proportion (%) Mean with HbA1c >80 HbA1c mmol/mol | | | |----------------|----------------| | Unadjusted | Adjusted | | PDU code | PDU | | Proportion (%) | | | size | | | Mean | with HbA1c >80 | | HbA1c | mmol/mol | | PZ156 | | | 128 | 81.4 | | PZ157 | | | 44 | 68.7 | | PZ158 | | | 56 | 72.6 | | PZ159 | | | 127 | 69.4 | | PZ162 | | | 99 | 73.6 | | PZ163 | | | 128 | 71.1 | | PZ164 | | | 101 | 73.1 | | PZ167 | | | 124 | 72.1 | | PZ168 | | | 35 | 66.5 | | PZ169 | | | 90 | 74.0 | | PZ170 | | | 99 | 78.7 | | PZ171 | | | 146 | 67.2 | | PZ172 | | | 170 | 73.0 | | PZ173 | | | 75 | 74.4 | | PZ174 | | | 100 | 72.6 | | PZ175 | | | 115 | 64.7 | | PZ176 | | | 139 | 69.9 | | PZ177 | | | 87 | 69.7 | | PZ178 | | | 19 | 77.9 | | PZ179 | | | 104 | 71.5 | | PZ180 | | | 128 | 67.9 | | PZ181 | | | 189 | 74.8 | | PZ182 | | | 92 | 81.2 | | PZ183 | | | 175 | 75.3 | | PZ184 | | | 41 | 68.7 | | PZ185 | | | 42 | 68.9 | | PZ186 | | | 173 | 73.3 | | PZ187 | | | 77 | 67.6 | | PZ188 | | | 165 | 77.4 | | PZ189 | | | 69 | 70.7 | | PZ190 | | | 47 | 76.0 | | PZ191 | | | 105 | 83.3 | | PZ193 | | | 36 | 68.6 | | PZ195 | | | 62 | 87.7 | | PZ196 | | | 11 | 53.9 | | PZ199 | | | 104 | 74.3 | | PZ200 | | | 74 | 81.5 | | PZ202 | | | 74 | 74.7 | | PZ203 | | | 304 | 64.1 | | PZ213 | | | 133 | 71.6 | | PZ215 | | | 123 | 80.5 | | PZ216 | | | 84 | 67.9 | Proportion (%) Mean with HbA1c >80 HbA1c mmol/mol | Unadjusted | Adjusted | |----------------|----------------| | | | | PDU code | | | Proportion (%) | | | | | | PDU | | | size | | | Mean | with HbA1c >80 | | HbA1c | mmol/mol | | PZ218 | | | 135 | 71.0 | | PZ219 | | | 197 | 68.2 | | PZ220 | | | 104 | 79.1 | | PZ221 | | | 123 | 77.2 | | PZ222 | | | 154 | 73.6 | | PZ223 | | | 96 | 67.3 | | PZ225 | | | 112 | 75.5 | | PZ226 | | | 69 | 77.7 | | PZ228 | | | 65 | 62.1 | | PZ230 | | | 40 | 73.2 | | PZ231 | | | 126 | 71.5 | | PZ232 | | | 143 | 76.1 | | PZ234 | | | 152 | 72.3 | | PZ238 | | | 189 | 70.3 | | PZ240 | | | 103 | 74.1 | | PZ242 | | | 239 | 70.3 | Proportion (%) Mean with HbA1c >80 HbA1c mmol/mol Royal College of Paediatrics and Child Health 5-11 Theobalds Road, London, WC1X 8SH The Royal College of Paediatrics and Child Health (RCPCH) is a registered charity in England and Wales (1057744) and in Scotland (SC038299).
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# Major Projects Authority Annual Report 2013-2014 ## Contents 2 CEO's introduction 4 The portfolio: transforming Britain through major projects 10 Being open about the challenges 14 Improving our delivery of major projects 18 Statistical annex: The data on the Government's Major Projects Portfolio ## Foreword Minister For The Cabinet Office This report, which includes the Major Project Authority (MPA)'s candid red/amber/green ratings, gives unprecedented insight into the government's portfolio of 199 transformative major projects. Everyone in the country will be touched in some way by these projects, whose lifetime costs stretch to over £400 billion. Yet despite their crucial importance and eye-watering budgets, successive governments failed to deliver major projects effectively. A lack of project management skills across the Civil Service; too fast a turnover of project leaders; inadequate assurance processes and institutional knowledge: all these led to the squandering of enormous sums of money from hard-working taxpayers. We knew this had to change, so after the last General Election the Prime Minister established the MPA to provide central assurance over projects and to support colleagues across departments to build skills and improve delivery. Since then we have made significant progress. This year, half of the projects with the most significant challenges improved, while our work to develop our people has meant we are relying less on costly consultants. Delivering major projects will never be easy - they are some of the biggest and most complex things the Government will do. But we must not pretend problems don't exist. Instead, we must identify and address them early on before they become an issue. By being open and realistic about the challenges we face, we can find solutions. That's nothing less than what the public should expect from us, and what we, through this Annual Report, are committed to delivering. ## Foreword Chief Secretary To The Treasury We are forecast to invest over £400 billion of taxpayers' money in our major projects, delivering benefits that will be transformational for our economy and for society. We always have a responsibility to ensure that public money is spent wisely and never more so than in the current challenging economic circumstances. The Treasury remains committed to the important work that this government is undertaking to improve the successful delivery of our most important projects. We know that a key to the success of major projects is to ensure that the right work is done to set them up properly by the time they receive approval to proceed from the Treasury. We will work in partnership with colleagues across government to improve further the way in which we do this. In making commitments of the scale of our major projects, it is vital that we are as clear as we can be on what we are trying to achieve, that we have considered all of the right options, and that we have identified the resources we need to deliver them successfully. ## Ceo'S Introduction A central part of improving our performance is being open about the challenges associated with delivering a major project, and the MPA Annual Report is an important move in that direction. With 199 projects in the portfolio, this report can only be an overview - you will find a more detailed analysis of the projects, including financial and schedule data, in the departments' own individual reports, published alongside this report on gov.uk. We have an impressive range of projects underway that will change people's lives for years to come, from new railways, better schools and the latest in medical treatment, to major advances in defence systems, and significant IT development projects that will set up our public services for the 21st century. The benefits these projects will bring to the country are enormous, and the overall investment is a real commitment to change. As this report details, we have made significant progress in the last year. Welcome to the MPA's second annual report. The aim of this report is to give you an overview of the most important projects being delivered by the government, and to set out the steps that we will take to continue to improve the way they are delivered. Projects of this scale and complexity are always going to be challenging - even more so in the public sector where there are many stakeholders involved, along with high levels of media scrutiny. There are four key areas on which we will focus our efforts to meet the challenges. First, getting major projects right requires outstanding leadership - and in my first few months in the job, it has been encouraging to meet some excellent project leaders, and to see how the Major Projects Leadership Academy is helping them develop their skills still further. We will continue this important work to build a world-class civil service. " Success is fundamentally about people. In my early days in government I have been encouraged by the talent and commitment of many of the people that I have met. We are making progress towards our aspiration to build a world-class civil service, capable of delivering the ambitious projects that this country needs. I look forward to continuing this important work." Second, leaders need to be empowered to get the job done, with clear accountability and responsibility for delivery. We are progressively clarifying the accountabilities and delegated authorities to enable focused and accountable leadership. Third, successful projects require detailed and substantial planning and analysis of the potential options before implementation begins. Such early clarification of objectives and implementation plans, the alignment of interests, and detailed understanding of the required resources, leads to the successful set-up of a project. While we currently devote significant efforts to this, there remain substantial opportunities for improvement. Lastly, getting major projects right requires a culture of openness and realism which gives people the confidence to identify challenges at any stage of a project so that solutions can be developed. Transparent publication of the data on our major projects through the MPA Annual Report and associated departmental reports, now in their second year, is an important example of our commitment to this culture of realism. To date, the MPA's role in reviewing, challenging, and advising projects has been important in enabling the kind of openness we need to be confident of success. Going forward, the MPA will offer project teams a greater level of support, offering valuable objective advice, asking the right questions, finding the right people to help - and, through the Major Projects Leadership Academy, providing training to enable leaders to develop the skills they need to deliver the challenging results expected of them. We are in the early days of the government's drive to improve the delivery of major projects, and success will take time. In setting up the MPA in 2011, the Government clearly signalled the importance of delivery alongside policy development. We are already making progress, and I am optimistic that we can continue and accelerate that journey. With a portfolio of this magnitude, improvements in efficiency mean we will complete projects at less cost to the taxpayer, as well as ensuring that we secure the benefits to public services and infrastructure that these projects promise. ## The Portfolio: Transforming Britain Through Major Projects Over the course of the last year, 39 projects have left the Government Major Projects Portfolio (GMPP), and many of these have been brought to a successful conclusion. In other cases, projects left the GMPP where they have transitioned to business as usual, or been redefined. A total of 75 further projects are due to complete by April 2015. Examples of the projects that completed successfully this year and are already delivering benefits across the country include: n The Home Office's New Passport Programme, which has utilised new manufacturing technology to produce the world's most secure identity document. Major projects delivered by the government are amongst the most ambitious and important in the country: they will transform public services and deliver infrastructure that will last for generations. We have committed £488bn to 199 major projects which are due to complete at various times over the next 20 years.1 n The Department of Environment, Food and Rural Affairs' project to establish a charitable organisation, the Canal & River Trust, to care for 2,000 miles of the country's canal and river network. n Ministry of Justice projects to increase the efficiency of the operation and management of the prison and prison escort services. n A number of major Department for Transport projects, such as the Greater Anglia Rail refranchising, that will provide better rail services for most passengers in East Anglia. The benefits these projects will bring go well beyond the 2.5% of annual government expenditure they represent: major infrastructure, for example Crossrail or Thameslink; connecting the nation through broadband; building hospitals and schools; transforming key parts of the UK economy, such as reforming the energy market; ensuring the future defence of the country and our ability to influence events overseas through the equipment of our armed forces; or the development of national icons such as Tate Modern or the British Museum. Significant progress is being made in even the longest-term projects. In moving from policy to delivery, major projects must pass through a series of key government approval points designed to ensure that they are set up successfully. Twenty-two projects received final business case approval from the Treasury during the year, allowing them to make the substantial financial commitments that will lead to implementation. A further 21 projects received outline business case approval, allowing them to proceed to more detailed planning. ## The Government'S Major Projects In Numbers The establishment of the GMPP in 2011 allowed us to understand the scope and scale of our most important projects for the first time. The GMPP is composed of the largest, most impactful, and highest risk projects being undertaken by the government. Projects to be included in the GMPP are agreed between the MPA, HM Treasury and the relevant government departments, and they report data to the MPA every quarter. £488bn whole life cost £19bn 2013-14 budget 28%scheduled to complete by September 2014 76%scheduled to complete by the end of the decade 24%scheduled to complete in the 2020s or 2030s Military equipment, energy generation and efficiency, and railway infrastructure represent over 65% of the whole life costs of the portfolio 199 projects 2 Largest investments: Rehabilitation and Transforming Youth Custody Programmes will reduce the level of reoffending, by bringing a broader range of partners in to provide rehabilitation services, expanding the coverage of those services, and by significantly improving the education provided to young offenders. The number of major projects across different departments in September 2012 and September 2013 is shown in figure 1. The total number of projects in the GMPP increased from 191 to 199 in the year to September 2013. Over the course of the year, 39 projects exited the GMPP due to completion, being redesigned into other projects or, in a few cases, being halted. Forty-seven new projects were incorporated within the GMPP reflecting the progress that we are making in turning the government's policies into projects to deliver change. Examples of projects that have started this year include a series of initiatives in the Department of Health, including the Seasonal Flu Extension to Children Programme that will mean that all children at primary school will receive the flu vaccine, and the Health Visitors Programme to recruit 4,200 extra health visitors by April 2015 to provide care for people at home. The Ministry of Justice's Transforming Figure 2 shows the distribution of the whole life costs of projects by department. This highlights the significance by cost to three departments in particular: the Department of Energy and Climate Change; the Department for Transport; and the Ministry of Defence. This reflects the high capital costs of energy and transport infrastructure and military equipment. The impact and significance of projects is not, however, illustrated by cost alone. Transformation projects can have comparatively low direct costs, but the reforms to the delivery of major public services that they introduce can influence the way in which very significant sums of ongoing government or private money is spent. Rather than physical infrastructure, the majority of projects in our portfolio are major transformation progammes to modernise the delivery of public services. The popular image of major projects is one of major infrastructure like railways or roads, or military equipment. However, as illustrated in figure 3, there is far more to the GMPP than these two categories. In fact the majority of our projects consist of programmes to deliver radical transformation of our public services, improving the quality of services while saving taxpayers hundreds of millions of pounds. Improving services requires us to undertake a major modernisation of the way in which government is structured, the means by which services are delivered and accessed, and our relationships with the companies and organisations with which we work to deliver them. As part of this, we are creating world-class digital public services, increasing the accessibility and efficiency of these services. The number of major transformation and IT projects demonstrates the scale of this ambition. Examples of projects of this type include the joint Department of Health, Ministry of Justice, and Home Office Liaison and Diversion Services Programme, which will improve the health of and reduce reoffending rates in adults and children in the criminal justice system who have complex physical and mental health needs, such as psychological illness or substance misuse; and the Beyond 2011 Census Programme that will consider innovative alternatives for collecting information for the 2021 census. The projects in the GMPP vary significantly in length and cost, as illustrated in figures 4 and 5. Thirty-five of our projects are not due to complete until after 2020, and some, such as the Successor Nuclear Deterrent submarines, are scheduled to run well into the 2030s. Across government, the range of projects that we are delivering therefore covers a range of scale, length and type, bringing with it a similar range of challenges that must be overcome. ## Schools Fit For The Next Generation Developing State-Of-The-Art Cancer Treatment For Children The £250m Proton Beam Therapy project is an innovative new form of radiotherapy that is transforming the prognosis of many hard-to-reach cancers. Through two major new facilities at University College Hospital, London and Christie Hospital, in Manchester, this advanced technology that accelerates hydrogen atoms to two thirds the speed of light, will change the lives of around 1,500 people - particularly children - each year. The Department for Education set up the Priority School Building Programme in 2011 to rebuild or repair over 250 of the country's most rundown schools. To ensure value for money, the schools were grouped to make the projects more commercially attractive and to drive stronger competition from bidders for the contracts. All schools within the programme will have been refurbished by the end of 2017. ## Tackling The Threat From Serious And Organised Crime The establishment of the National Crime Agency (NCA) will enable the UK to tackle more effectively serious and organised crime such as money laundering, cyber-crime or human trafficking. This project has required a major transformation, bringing together staff from a variety of bodies, including the National Policing Improvement Agency, the National Fraud Authority, the Metropolitan Police Service and the UK Border Agency. ## Protecting Britain'S Interests Abroad In The 21St Century Type 45 destroyers will provide the backbone of the UK's naval air defences for the next 30 years and beyond, as well as carrying out a wide range of operations, including anti-piracy and anti-smuggling activities, disaster relief work and surveillance operations. The first Type 45, HMS Daring, arrived in Portsmouth in January 2009. HMS Duncan, the final of the six Type 45s, entered service in January 2014. ## Being Open About The Challenges n New information technology. Our digital transformation agenda aims to provide world-class digital services; typically, this involves redesigning public services involving millions of people and hundreds of millions of transactions. n Scale. There are more than 10 projects in the portfolio with costs of over £10bn, while many will have impacts across the whole of the UK, for example national vaccination projects, the electoral register, or national tax and benefit reform. Major projects are complex and ambitious. Getting them right is a huge challenge, and even the best-run projects rarely go smoothly from start to finish. However, of the projects we reported as facing the most significant challenges a year ago, over half have improved significantly, thanks to determined efforts to resolve issues. n Multiple delivery partners. Most of our major projects have many delivery partners spanning both the public and private sectors, while a high proportion involve complex private sector procurement exercises. In the context of health, for example, developing new IT programmes requires hundreds of semi-independent organisations and trusts across public health and social care to work together to share information. Given the number, complexity and scale of the challenges facing major projects, it is essential that we are realistic about what we can achieve, which means developing a culture of realism about these challenges. This kind of approach allows teams to find solutions before problems spiral out of control. Among the challenges are: n New organisational structures. Because they are not 'business as usual', managing and delivering major projects usually requires the development of new temporary structures, either within government or in collaboration with partners. On occasion these may be entirely new organisations such as the Olympic Delivery Authority. n Technological complexity. Many of our major projects incorporate some of the most innovative and technologically advanced engineering in the world. For example, the Department of Energy and Climate Change's Carbon Capture and Storage Project will support the development of new technologies to lead the fight against climate change, while the Astute and Successor class nuclear submarines being designed and built by the Ministry of Defence are amongst the most technologically advanced machines that have ever been created. High Speed Rail (HS2) is a high-profile example of a project that displays many of these challenges. It is not unusual for projects of this scale to have a lower delivery confidence assessment early in their project life, highlighting the substantial issues that inevitably remain to be resolved. Significant " Government and industry share the challenge that large scale projects are difficult to manage, and the evidence shows that both suffer issues with late delivery and going over budget. The only significant difference between the public and private sectors is around transparency, where major projects undertaken by government face more regular questions about whether the large budgets involved are well spent." Dr Paul Chapman, Oxford Saïd Business School progress has been made in the last year on HS2, for example in depositing the High Speed Rail Bill in Parliament and securing successful second reading in the Commons. The amber/red delivery confidence assessment on HS2, like other projects with a similar assessment, indicates that the focused attention that is being applied to addressing the remaining issues must continue. Realism about the challenges of major projects: the MPA's assurance review The MPA's assurance review process is an important component of a culture of identifying and addressing the challenges of delivering major projects. It consists of internal - but independent - reviews at key decision points in a project's life-cycle, identifying what is going well, and providing recommendations to address issues. Since the MPA was established, we have initiated well over 500 assurance reviews. As part of our commitment to creating a culture of realism, the MPA maintains a 'Delivery Confidence Assessment' (DCA) of all projects in the GMPP , enabling attention to be focused across government where it is most required. The DCA gives an overall summary of the state of a project, and is reported as a traffic light system ranging from green for the projects judged with the lowest risks to success, to red for those projects facing the most serious challenges.1 The DCA gives an overall summary of the state of a project. The ambition and level of risk associated with many of our major projects means that, particularly at their earliest stages, projects are likely to be rated no higher than amber, and frequently amber/red or occasionally red. It is important to note that a red or amber/red rating does not mean a project will be or should be cancelled, and the delivery confidence of many projects rated red and amber/red increases significantly as solutions are identified to challenges. Though some projects will likely pass through stages of red or amber/red on the path to successful delivery, there will also be instances where a red rating signifies that a project is unachievable within reasonable timescales and to a reasonable budget without urgent remedial action. Red and red/amber ratings signal to Ministers and officials that action is required and suitable mitigating measures put in place. The MPA formally updates DCA ratings each quarter, and the ratings (as of the previous September) are published each year in the MPA Annual Report as part of our commitment to increased transparency. The overall quarterly DCA is informed by a range of evidence, including the ratings from any recent assurance reviews. The MPA's assurance reviews are not published, in order to allow these reviews to encourage a culture of candid identification of the challenges and issues with projects. Where we are now: delivery confidence of major projects in September 2013 In line with our commitment to transparency, last year's Annual Report marked the first publication of the MPA's DCAs of projects in the GMPP , and this year, with the publication of comparative figures, we can begin to track progress. The overall DCA across the portfolio at September 2012 and September 2013 is shown in figure 6 overleaf. The figures show a spread of confidence in delivery, with the highest proportions of projects rated amber and amber/ green in both years. This time last year, we rated 31 projects red or amber/red. The change in our assessment of these is shown in figure 8 opposite. Of these 31 projects, more than half did better this year and only one has got worse - being open about the challenges and allowing managers to focus on the problems has meant that even those projects with the greatest challenges have been put on a firmer footing. Those showing an improved DCA included: n The Department for Transport's Thameslink, Southern and Great Northern Franchise Competition to secure the future operation of major parts of the rail network. Between September 2012 and September 2013 there was an increase in the percentage of projects rated amber/red and a decrease in the percentage rated green. The main reason for this is that 47 new projects joined the GMPP this year. Since they are projects in the early stages of planning, we are naturally at this stage less confident in their delivery than in those projects that left the portfolio during the year. Projects in the earlier stages of planning receive, on average, lower DCAs because they are still working through the process of identifying solutions to the challenges that they inevitably face. This is illustrated in figure 7, which shows the higher DCAs of those projects that exited the portfolio this year compared with those that joined. n The Department of Health's London Programme for IT to deliver patient administration systems in the London area. By contrast, the overall DCA of the projects that have been in the portfolio in both years has remained largely unchanged. Of the 122 projects whose DCAs were published in both years, 35 have improved and 25 have declined.5 n HMRC's One Click project to bring many businesses' tax needs together in one place and online. n The Department of Work and Pensions' Benefit Cap, to limit the total amount of benefit that working-age people can receive so that households on out-of-work benefits will no longer receive more in welfare payments than the average weekly wage for working households. n The Office for National Statistics's Web Data Access project to allow the dissemination of 2011 Census data online. Of the eight projects that we rated red in September 2012, only one was still rated red in September 2013, the Queen Elizabeth Class Aircraft Carrier project. However, since September 2013, the Ministry of Defence has reported that a new contract has been agreed with the Aircraft Carrier Alliance. Announcing this new contract in Parliament on 6th November 2013, the Secretary of State confirmed that it was based on a detailed analysis of costs, and on improved commercial terms that provide stronger incentives for the shipbuilding industry to construct the ships to the agreed budget. One project went from an amber/red rating to a red rating between September 2012 and 2013. This was the Information Systems and Operational Technology project to upgrade the IT used by the Serious and Organised Crime Agency (SOCA). The red rating was due to a part of the upgrade being delayed, and a correction plan is being developed with the supplier. SOCA ceased to exist in October 2013 and the project is now within the National Crime Agency (NCA). The project is still on track to achieve savings of £213m over 10 years. Analysis of the projects in the GMPP demonstrates that, on average, projects with higher total costs and a longer lifespan have a lower DCA, which is unsurprising given the greater complexity of more costly and longer-lived projects. Furthermore, the number of projects that we rate green or amber/ green decreases in the very early stages of planning, but increases as projects approach their planned completion dates. It is likely that this represents an initial recognition of the challenges that need to be addressed in a project, followed by increasing delivery confidence as solutions are identified. ## Improving Our Delivery Of Major Projects Developing World-Class Project Leaders Across Government Look at any successful project and you will find a good leader. Projects need leaders with the ability to manage complex relationships, to prioritise among alternative approaches, to allocate scarce resources, to pick the right people for the right teams, and to solve problems as they arise. Leaders need good business sense and the right experience, and they must be able to motivate and inspire their teams. We will build and develop our cadre of project leaders, creating a recognised profession of experts who can move across government to deliver our most important projects. We have made some valuable progress in improving our approach to major projects, including through the worldleading Major Projects Leadership Academy. But we still have much to do to become excellent at delivering projects, particularly in planning and prioritisation, as well as further improving the skills and accountability of project leaders. Over the last three years, delivering major projects has had a higher profile within government, enabling problems to be recognised and addressed. Over 500 independent assurance reviews have resulted in recommendations that have improved the delivery of many of the most important projects, while the Major Projects Leadership Academy (MPLA) has made a significant contribution to the development of project leaders. We will continue our drive to deliver these important projects more successfully. In 2012, we established the world-leading MPLA in partnership with the Saïd Business School at the University of Oxford. The MPLA is now an important contributor to the government's Civil Service Reform programme. To date, 200 project leaders have taken part, and our objective is that all eligible leaders of the government's major projects will have started or completed the programme by the end of 2014. Leaders from across government who have participated in this programme have reported that it has helped them improve the delivery of their projects. " Investment of time and resource in a rigorous process at the outset is essential for success, and deficiencies cannot be recovered later." Lord Browne of Madingley, Government Lead Non-Executive Given its success to date, the MPLA will continue to be central to our development of leaders of major projects. In addition, we will expand and deepen our work to develop project leadership across government. We will also develop specific training around particular challenges such as IT and transformation programmes. Leaders also need excellent teams around them to deliver projects, so we are working on a programme to develop and support project delivery skills at every level, in particular through the Civil Service Project Leaders Network, established in March 2012, which allows for best practice to be shared across government. ## Clear Accountability Developing leaders with the right capability is just one part of the story - they must also be given the accountability and authority to lead their projects. Complex accountability structures and unclear lines of responsibility within our major projects can make delivering them more challenging. Senior Responsible Owners (SROs) are the key individuals across government charged with leading projects. We will work progressively to increase the clarity that we provide to SROs over what they are required to deliver, supported by the decisionmaking responsibilities to accompany this. ## Rigorous Upfront Planning And Assurance Being clear about the objectives at the start of a project is fundamental to success, accompanied by a rigorous process to ensure that a range of options are considered as to how these objectives can best be achieved. We already have rigorous processes by which major projects are developed and approved, built around a series of approval points in departments and the Treasury. But there is always room for improvement, and over the coming year we will continue to improve the process by which major projects are initiated. As part of this, we will be looking at the management of the overall portfolio of projects by department, helping departments match their objectives to the resources they have available, and ensuring that the collection of projects across a department works as a whole to deliver policy objectives. ## Developing An Open Culture Delivering projects of the complexity of those in the GMPP requires a recognition of the challenges involved - because it is through such openness that solutions can be found. This can only happen in an open culture, where those responsible for delivering projects feel able to raise issues as and when they arise. Our transparency agenda, exemplified through the MPA's Annual Report, is a crucial component of this culture of openness. ## "A Whole New Dimension To Leadership Training" What Project Leaders Are Saying About The Major Projects Leadership Academy (Mpla) The MPLA's curriculum is designed and delivered by international business leaders and academics. A core part of the programme is to get participants learning from "the world's best" project leaders. Amongst the senior leaders who have led MPLA discussions are Sir Ian Cheshire, Group Chief Executive of Kingfisher; Adrian Ewer, former Chief Executive John Laing; and Lord Browne, former Chief Executive of BP . 340 participants by the end of 2014, increased from 169 at the end of 2013. Leaders from over 45% of our major projects have participated in the MPLA " The MPLA has undoubtedly taught me some new and relevant concepts and given me new enthusiasm about the power of academic rigour. If the MPLA makes only a small difference to the outcome of this £15bn+ acquisition programme, given that the impacts and costs reach 50 years into the future, then the leverage is huge." Director, Carrier Strike, MOD " What I have learnt is being felt every day in how I lead my team and drive the performance of my part of the organisation. I am more skilled in managing the working environment and challenging the internal norm." Dorothy Brown Director Workforce Management/HR Director Enforcement & Compliance, HMRC Ray Long Director, Corporate Services Change, HMRC Chief Secretary to the Treasury " Over the last six months I have become more forensic in my approach to planning projects and have challenged others more on the quality of information they give me. This has already yielded significant financial savings on my project." Michael Hurn Director, Project Sponsorship - Technical & Commercial, HS2 Group, Department for Transport one of the MPLA's external lecturers with commercial expertise " The MPLA brings a whole new dimension to leadership training - the first programme to address the unique issues around delivering major projects and an essential qualification for SROs and Directors of the Government's mega-projects." ## Statistical Annex The Data On The Government'S Major Projects Portfolio Interpreting The Published Data Some context is required to be able to understand the data provided in the Annual Report. In particular, we need to take care when drawing direct year-onyear comparisons in the data given the changing nature of the portfolio. Under the government's commitment to transparency, the data that is recorded by departments for projects in the GMPP is published by departments annually at the same time as the publication of the MPA's Annual Report. n The projects in the GMPP change from quarter to quarter. Since last year's report, 39 projects have left the GMPP - typically because they have been completed or have moved into their business-as-usual phase, or because they have been halted or strategically organised into larger programmes that contain a number of similar projects associated by their common aim. In addition, 47 extra projects have joined the GMPP since September 2012. These include both new projects that have just been initiated and existing projects that have been escalated either in scope or in strategic priority. As a consequence, comparison of the September 2012 data with the September 2013 data is a comparison between two groups of projects which have significant differences in composition. This data is: the MPA's DCA; financial data; schedule data; and the departmental commentary on each of these. The data published this year was submitted to the MPA in September 2013, with exemptions to the publication of data permitted only under exceptional circumstances and in line with Freedom of Information requirements. In a small number of the most sensitive projects, these exemptions are made on grounds of national security. The majority of exemptions are made for projects that are undertaking commercial procurement exercises, where publication of data would harm our ability to secure value for money for the taxpayer. Fewer pieces of data have been exempted from publication this year than at the time of our last Annual Report - only 12% of projects have had one or more pieces of data exempted, compared with 21% last year. n Changes can also occur within projects over the course of a year. For example, the scope of a project may be significantly increased and, as a consequence, the forecast cost may increase. The increase in budget year-on-year in this case would not represent an increase in costs for the achievement of the same objectives. In February 2014, the NAO published a memorandum on the MPA Annual Report 2012-13.1 The NAO recommended that future annual reports include more analysis of the published data, and this has been done in this Annual Report. ## Summary Of Data For All Projects On The Gmpp The distribution, by number of projects, of delivery confidence across the government's portfolio in September 2012 and September 2013 No DCA Exempt Reset Green Amber/green Amber Amber/red Red Delivery confidence, September 2012 0 21 0 32 49 58 23 8 Delivery confidence, September 2013 8 15 1 17 54 63 37 4 Jun 13 Sep 13 Project Director change Senior Responsible Owner change ## Departmental Data | | Number of major projects | Whole life cost (£m) | |------------|------|------------------------| | | September September | excluding exempt data | | Department | 2012 | 2013 | | BIS | | | | 10 | 12 | 14,374 | | CO | | | | 5 | 8 | 1,412 | | DCLG | | | | 4 | 3 | 281 | | DCMS | | | | 6 | 6 | 1,431 | | DECC | | | | 12 | 11 | 94,794 | | DEFRA | | | | 4 | 3 | 4691 | | DfE | | | | 2 | 2 | 10,192 | | DfID | | | | 1 | 1 | 445 | | DfT | | | | 17 | 12 | 83,808 | | DoH | | | | 21 | 35 | 24,536 | | DWP | | | | 12 | 12 | 13,422 | | FCO | | | | 6 | 5 | 577 | | HMRC | | | | 9 | 8 | 1,382 | | HMT | | | | 2 | 1 | 0 | | HO | | | | 20 | 15 | 5,374 | | MoD | | | | 36 | 40 | 135,767 | | MoJ | | | | 18 | 19 | 4,796 | | NS&I | | | | 1 | 1 | 678 | | ONS | | | | 5 | 5 | 647 | | Total | 191 | 199 | ## Description Of Delivery Confidence Assessment (Dca) Ratings | Green | | Successful delivery of the project on time, budget and quality | |------------------------------------------------------------------|---------------------------------------------------------|-------------------------------------------------------------------| | appears highly likely and there are no major outstanding issues | | | | that at this stage appear to threaten delivery significantly. | | | | Amber/green | Successful delivery appears probable; however, constant | | | attention will be needed to ensure risks do not materialise into | | | | major issues threatening delivery. | | | | Amber | | Successful delivery appears feasible but significant issues | | already exist, require management attention. These appear | | | | resolvable at this stage and, if addressed promptly, should not | | | | present a cost/schedule overrun. | | | | Amber/red | | Successful delivery of the project is in doubt, with major risks | | or issues apparent in a number of key areas. Urgent action is | | | | needed to ensure these are addressed, and whether resolution | | | | is feasible. | | | | Red | | Successful delivery of the project appears to be unachievable. | | There are major issues with project definition, schedule, | | | | budget, quality and/or benefits delivery, which at this stage do | | | | not appear to be manageable or resolvable. The project may | | | | need re-scoping and/or its overall viability reassessed. | | | ## Key Of Department Names | BIS | Department for Business, Innovation and Skills | |-------|-----------------------------------------------------| | CO | Cabinet Office | | DCLG | Department for Communities and Local Government | | DCMS | Department for Culture, Media and Sport | | DECC | Department of Energy and Climate Change | | DEFRA | Department for Environment, Food, and Rural Affairs | | DfE | Department for Education | | DfID | Department for International Development | | DfT | Department for Transport | | DoH | Department of Health | | DWP | Department for Work and Pensions | | FCO | Foreign and Commonwealth Office | | HMRC | Her Majesty's Revenue and Customs | | HMT | HM Treasury | | HO | Home Office | | MoD | Ministry of Defence | | MoJ | Ministry of Justice | | NS&I | National Savings and Investment | | ONS | Office for National Statistics | Cabinet Office 70 Whitehall London SW1A 2AS Publication date 23 May 2014 © Crown copyright 2014 Any enquiries regarding this publication should be sent to us at servicedesk@cabinet-office.gsi.gov.uk. You may re-use this information (not including logos) free of charge in any format or medium, under the terms of the Open Government Licence. This publication is available for download at www.official-documents.gov.uk. To view this licence, visit www.nationalarchives. gov.uk/doc/open-government-licence/ or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk.
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# London Councils European Social Fund Borough Employment Programme 2016-2018 # Application Prospectus 7Th February 2017 Deadline for applications: 12 noon, 7th April 2017 www.londoncouncils.gov.uk ## Contents 1. Introduction ....................................................................................................... 3 The European Structural Investment Funds .............................................................. 3 ESF Investment Priorities .......................................................................................... 4 2. Project Specification ....................................................................................... 7 Specification 1 - Hounslow: Digital, Media, Tech and Creative Skills Project ............. 7 3. Participant Target Groups ............................................................................. 17 Core Project Requirements ..................................................................................... 18 4. Project activities, outputs and results ......................................................... 19 Outputs and Results for payment ............................................................................ 20 5. Added value ................................................................................................... 23 6. Partnership working ...................................................................................... 24 7. Submitting an application ............................................................................. 25 8. Horizontal Principles (Formerly Cross Cutting Themes) ........................... 37 9. Monitoring and reporting on your project ................................................... 41 10. Financial information ..................................................................................... 42 11. **Publicity arrangements ................................................................................. 43** 12. Assessment process ..................................................................................... 44 Appeals ................................................................................................................... 45 External panel ......................................................................................................... 45 13. **Payment arrangements ................................................................................. 47** 14. **Contacts ......................................................................................................... 48** 15. **ESF Programme Guidance Documents ....................................................... 50** Annex A ................................................................................................................... 51 ## 1. Introduction Welcome to the prospectus for the London Councils European Social Fund (ESF) Borough Programme 2016-2018. London Councils' ESF Borough programme is part of the European Structural and Investment funds (ESIF) Growth strategy1 for England in 2014-2020. ## The European Structural Investment Funds The European Structural and Investment Funds (ESIFs) are the European Union's main funding programmes for supporting growth and jobs across EU member states. They form a small but important part of the UK Government's overall growth activity. In England, for 2014 to 2020 the programmes consist of the European Regional Development Fund (ERDF), European Social Fund (ESF) and part of the European Agricultural Fund for Rural Development (EAFRD). These have been brought together into a single Growth programme with individual operational programmes aligned to maximise support for jobs and growth. The Growth Programme is delivered across England's 39 Local Enterprise Partnership (LEP) areas, each of which has an ESIF Strategy to support local delivery. The £6 billion funds within the Growth Programme have been notionally distributed to LEP areas. ERDF can fund activity such as support to SMEs, ICT, Low Carbon and research and innovation. ESF supports employment, skills and social inclusion. The London 2014-2020 ESIF Strategy2 sets out the key areas for ESF investment in London and aligns to the London Enterprise Panel's (LEP's) three skills and employment themes: promoting sustainable employment and progression outcomes, ensuring individuals and employers are better informed to drive the skills and employment system and engaging with London's businesses to help drive growth in the Capital. ESF in London is managed by the Greater London Authority's (GLA) European Programmes Management Unit (EPMU) who has been designated by Government as an Intermediate Body for ESF and ERDF. The LEP, through the GLA, London Councils and other local partners, have developed a range of ESF provision to meet local needs. There are five ESF Co-Financing Organisations for 2014-20 in London. They are:  Greater London Authority  Skills Funding Agency  Department for Work and Pensions (DWP)  Big Lottery  National Offender Management Service (NOMS) ## Esf Investment Priorities The 2014-2020 ESF Programme has two main Priority Axes, each with a number of Investment Priorities: ## Priority Axis 1 - Inclusive Labour Markets Priority 1.1 Access to Employment for Job-Seekers and Inactive People - Improving the employability and skills of the unemployed and economically inactive people Priority 1.2 Sustainable Integration of Young People - Employment and Skills activities targeted at young people who are not in education, employment or training (NEET) or at risk of becoming NEET Priority 1.3 Youth Employment Initiative - This will focus on helping young people, particularly those not in education, employment or training (NEET) to participate in the labour market and learning in areas eligible for the Youth Employment Initiative. Priority 1.4 Active Inclusion - To address the root causes of poverty which creates barriers to work so more people move closer or into employment ## Priority Axis 2 - Skills For Growth Priority 2.1 Enhancing Equal Access to Lifelong Learning Priority 2.2 Improving the Labour Market Relevance of Education and Training Systems For more details please see the 2014-20 Operational Programme at https://www.gov.uk/government/publications/european-social-fund-operational-programme- 2014-to-2020 ## The London Councils' Esf Borough Employment Programme - Priority 1.1 - Access To Employment For Job-Seekers And Inactive People The London Councils ESF Borough Employment Programme 2016-18 will focus on delivering the strategic objectives of ESF Priority 1.1 - Access to employment for Job- Seekers and Inactive People. This Programme will specifically fund projects that will assist individuals who are disadvantaged to tackle their barriers to work and sustainable employment. Such activities should include help to identify the barriers individuals face in moving into work (for example; confidence, lack of recent work experience, basic skills, job seeking and job-related skills, or other material barriers like debt) and working with them to tackle these barriers. For this Programme, London Councils and the participating borough of Hounslow welcome applications for grants from organisations and partnerships to deliver projects strategically aligned with ESF Priority 1.1 and can show links with other programmes supporting these Priorities. This is part of a wider London Councils ESF Programme. The project (listed in Table 1 below) should be innovative and add value to the mainstream provision. The Programme will focus on people that are economically inactive and long term unemployed. In this way, the London Councils ESF Borough Employment Programme 2016-2018 can help the London boroughs contribute towards national indicator targets for employment and poverty by targeting workless people. This Prospectus sets out the borough specific projects as well as the criteria and conditions for potential providers applying for this grant funding. Project/s will be funded between the dates specified on the specification. Please note that project/s will start no earlier than 5 June 2017. | Borough(s)/Consortium | Project Name | Funding Value | |------------------------------|-----------------|-------------------| | Hounslow | | | | Digital Media, Technical and | | | | Creative Skills | | | | £175,400 | | | | Total | | £175,400 | | | | |  Please note: The value of the Hounslow project may potentially increase if sufficient borough funding and ESF funding is available. ## Project Specification 2. Project Specification Specification 1 - Hounslow: Digital, Media, Tech And Creative Skills Project Introduction - Hounslow Borough Hounslow Council commissioned the Hounslow Skills and Employment strategy in 2014 which set out its commitment to improving the skills and life chances of the borough's residents. The strategy was developed in response to the shifting wider economic and political context which was part of national skills reform with a sharper focus on economically viable skills led by employers, and a welfare reform system which focused on a stronger emphasis on claimants seeking employment. It was produced in consultation with local employers, skills providers, residents, and other key partners such as Jobcentre Plus. The strategy sets out a new approach to working with employers in the borough, to improve residents' skills and access to the labour market. It followed on from the publication of Hounslow's Local Economic Assessment [2011], and updates to this which were produced in 2013 and presented to members of Hounslow's Economic and Business Forum and Hounslow's Skills, Training and Employment Partnership. The strategy sits within in the framework of the Council's Economic Development Strategy [2013] and wider regeneration plans. The strategy has four key aims which are: 1. To support local employment growth and enterprise through improving access to skills and reducing mismatch between demand and supply 2. Improving all young people's achievement and progression into employment 3. Improving pathways into work for the unemployed and progression in work for low paid residents 4. Improving access to information, advice and guidance and labour market information The Skills and Employment team in partnership with partners work to deliver against the aims and specific targets within the strategy. Hounslow Council is proactive in the local employment and skills agenda and has a number of projects which are helping to support Hounslow residents into employment and apprenticeship opportunities. The Skills and Employment team were successful in securing European Social Fund [ESF] funding for the Digital, Media, Tech and Creative Skills Project, Working People, Working Places and the expansion of the Skills Escalator programme. These innovative projects aim to help support the employment and skills agenda in the borough with a focus on supporting some of the most disadvantaged and vulnerable residents. These projects are leading the way nationally in terms of shaping the thinking about service re-design, new methods of engaging with residents and tackling recurring barriers to employment and skills progression. The project will run for two-years and will aim to ensure adults aged 25 and over who are either long term unemployed or economically inactive are able to move towards securing employment opportunities with local businesses in Hounslow's Digital, Media, Tech and Creative sectors either through obtaining relevant training/qualifications or direct employment. A successful project would aim to deliver against the targets set out in the project specification which would result in building a 'local talent pipeline'. ## Demographic Data Hounslow Has A Total Population Of 265,600 [Nomis, 2014] Projections from the GLA indicate that as of 2015 just over half (51.6%) of Hounslow residents are from black and minority ethnic (BAME) backgrounds. The largest non-white ethnic group in Hounslow is Indian [52,300], followed by Other Asian [30,100] and Pakistani [15,200]. In addition to white British and Irish residents, Hounslow's white population also includes a substantial number of residents from other European countries, particularly EU accession countries such as Poland and Romania. Total working age population is 180,400 [Nomis, 2004] The number of residents who are economically inactive are 40,600 [22.4%] [Jan - Dec2015] The number of JSA claimants in the borough is 2375 [March 2016] Indices of Multiple Deprivation [IMD] - Overall severe relative deprivation in Hounslow seems to have increased slightly since the IMD results were published back in 2010; the borough has 16 LSOAs in the most deprived 20 per cent nationally in the 2015 IMD (including two in the top 10 per cent), compared to 12 (of which one was in the top 10 per cent) in the 2010 IMD. ## Strategic Documents Hounslow Skills and Employment Strategy London Borough of Hounslow - Sectors Research Nesta - Tech Nation 2016: Transforming UK industries ## Sector Information - Local And National Research A research report conducted by Regeneris called 'Hounslow Sectors Research' in 2015 has shown the strength of the Media and ICT and Digital sectors of Hounslow's economy. These sectors are seen as high growth areas for the foreseeable future and we know from national, and local research reports and through discussions with local employers there are skills gaps within these sectors. The Regeneris research has shown - three quarters of these businesses reported they experienced no difficulties in recruiting appropriately skilled staff. However, skills challenges were reported in IT development / software skills which are found in roles across the ICT and Media sectors. The Regeneris research showed the relative strength of Hounslow's Media and ICT/Digital Media in comparison to the other 33 London boroughs. In Hounslow, 13 per cent (18,800 jobs) of the total jobs in the Hounslow economy are based in the Media sector which is the highest proportion of all the London boroughs. This shows the relative strength of the Media sector in Hounslow's economy. The London average for jobs in the Media sector is only 3 per cent. Similarly, 9 per cent (12,900) of the total number of jobs in the Hounslow economy are based in ICT/Digital sector, where Hounslow is 2nd only behind Islington on 10 per cent. The London average for the jobs in ICT/Digital Media is 4.9 per cent. The above tables and information have shown the relative strength of Hounslow's Media and ICT/Digital Media sectors in comparison to the other London boroughs. Below there is a summary of the key points and figures from the key sectors summary which has been produced from the Regeneris report: ## Hounslow Media & Broadcasting Sector  18,800 jobs (13 per cent of total) which increased 8,600 (+84 percent) since 2009  410 businesses (4 per cent of total) increased by (+19 per cent) since 2011  99 percent employ 0-4 people, but a small number of very large companies such as SKY employ the vast majority  This sector is mainly concentrated in the east of the borough, 50 per cent of businesses are located in Turnham Green and Chiswick  Sector trends - Export driven and domestic growth expected - UK entertainment and media market alone is forecast to reach £63bn by 2016  Professions - STEAM subjects, Gaming, Mobile entertainment and media, Animation, e-commerce  Threats to the sector - Fragmented funding landscape, incompatibility of traditional financial products and infrastructure gaps  Local specialisms in Production and broadcasting - 78 per cent of the sector's employment base across almost 300 businesses  Local specialisms in Wider Professional services related to media - 3,400 jobs in 160 businesses  Local specialism in TV Triangle & Enjoy-Work cluster - developing a media tech cluster in west London  Technology - The online presence of the media sector promotes a uniquely large freelance workforce who work from home, with specialist equipment and fibre optic broadband commonly seen as the only necessary tools to do business ## Hounslow'S Ict & Digital Media Sector  12,900 jobs (9 per cent of total) increased + 4,300 (+50 per cent) since 2009  1,900 jobs businesses (16 per cent) and has increased 51 per cent since 2011  Large proportion of micro-businesses - 94% employ 0-4 people compared to 81 % across the overall business base  Location - Relatively diffuse but with business concentrations in Hounslow Town centre (27%) and Turnham Green and Chiswick (20%)  Sector trends - Driven by both its own high value potential and its enabling role, helping to drive innovation and productivity in other sectors  Professions - Big data, new broadcasting technologies and delivery models, mobility and connectivity, need 'work ready' graduates, e-commerce  Threats to the sector - UK is experiencing an annual shortfall of 40,000 scientists, engineers and technicians , while international competition from US and Asia is also a major challenge to growth  Local specialisms in Development and Business activities - includes activities relating to computer consultancy and software development this sub-sector constitutes over half of Hounslow's ICT & Digital sector employment (6,600)  Local specialisms in Wholesale of computers & software - 33 per cent of sector employment (4,300 jobs) ## Ukces - Sector Skills Insights: Digital And Creative Key messages - The sector contributes £92 billion to UK economy, and employs nearly two million people. The UK is ranked 6th in the world for its overall competitiveness in IT but has declined from 3rd. This drop is echoed in other areas of the sector. International competition in the creative sub sector is being driven by policies that are often more ambitious than those in the UK. The digital and creative sector is highly successful. It makes a significant contribution to the economy and enjoys world class status, which needs to be sustained. It is projected to grow and evolve rapidly over the next decade. Partly because of this success several challenges exist which threaten the sector's performance:  The quantity of digital graduates  The quality of creative graduates  The gender balance and lack of financial investment in the workforce There are a number of examples which exist where these challenges are being tackled successfully through employer-led skills solutions. If the sector is to realise its potential this action must be scaled-up and employers must play a greater role in developing the skills they need. Digital and Creative sector - Key Skills Challenges Attracting talent is a key challenge - Applications to computing/IT degree courses have nearly halved in the last decade. The digital sub-sector employs three times more men than women. The creative sub-sector has an oversupply of graduates but they often lack specialist skills. Not enough employers invest in the workforce - Half of employers train their staff, but the proportion that train has fallen in recent years. Although much training is done informally, spend per employee in the sector is below average. Sector specific skills gap - Relatively few employers report staff that are not fully proficient in their jobs. But where they do exist, the most common skills gaps are among professional occupations in the digital sub-sector (27% compared to 9 per cent for the whole economy), and among sales and customer service occupations in the creative subsector (25% compared to 19% for the whole economy). Lack of technology skills - Where technology skills are lacking employers report it impacts on new product development (68% for digital employers, 51% for creative employers and 41% for the whole economy). Outsourcing work - It also impacts meeting business requirements, in terms of outsourcing work (39% of digital employers, 31%of creative employers and 26% for the whole economy). Business and Management skills - There is also a need to improve business and management skills, management, planning and organisational skills. These skills are those most commonly identified as the ones that need improving and these are in demand across the economy. However training levels are falling and international competition is rising. ## Creative And Digital Sector - Developing A Skilled Workforce [Retention] Training - Much of the training undertaken in the Digital and Creative sector is done informally, but more can be done to strength this. Training provision is fragmented and led by learner interest. Only 26% of digital and creative employers reported staff had been trained towards a nationally recognised qualification compared to 44% across all sectors. [Recruitment] Apprenticeships/internships - The sector could do more to grow the specific skills it needs through **apprenticeships/internships** and tackle some perennial problems:  Creative employers often find job-specific skills lacking among graduates  Entry routes to the creative sector are often characterised by knowing people in the industry and means the sector doesn't always provide access to the best talent  Digital employers need to establish alternative entry channels such as Apprenticeships that create 'home grown' talent Digital sub-Sector - Background The digital sub-sector needs to recruit at least 30,000 people qualified at degree level or above each year and currently there are not enough appropriately skilled graduates. Employers need to think creatively about opening up alternative recruitment channels to include; graduates from non-IT courses who can be trained; experienced workers in other sectors who can be retrained and re-entrants to the labour market following career break, early retirement or unemployment. Women make up only a quarter of the workforce in the digital sub-sector and the proportion is falling. As a result, the digital and creative sector is missing out on a significant proportion of the talent pool. This issue is not only at entry level but also retaining women in the sector is just as much of a challenge. Creative sub-sector - Background The creative sector needs to recruit at least 50,000 people qualified at degree level or above each year. There is a good supply of graduates from 18,000 creative and media courses on offer at UK HE institutions. But too many courses are producing graduates without the specialist skills needed by employers. Engagement between HE and Creative Media industries is crucial, and there is scope for further engagement through:  The development of talent and high-level skills for the creative economy  Activities that enhance the employability and enterprise skills of students and graduates  Provision of tailored and high-quality continuing professional development (CPD) to the creative industries ## National Research - Digital Sector Ukces - Technology And Skills In The Digital Industries The Digital sector employs 3 per cent of the UK workforce and contributes nearly £69 billion Gross Value Added to the UK economy (7.4 per cent). Skills shortage vacancies equate to 17 per cent of all vacancies in the sector, and are experienced by 3,000 employers. Hard to fill and skill shortage vacancies are concentrated in Professional and Associate Professional and Technical occupations. The most common skills thought to be lacking are job specific, and advanced IT or software skills. This report is to provide new insights on the role of four emerging technologies which are: cyber security; mobile technologies; Green IT and Cloud Computing, in driving high level skills needs of the wider Digital sector. ## Cyber Security Skills needs - These include a sound base of technical understanding, knowledge and competencies; understanding and awareness of security issues and industry standards; analytical skills, risk analysis and risk management. Communication skills, relationship management, and customer facing presentation skills are also seen critical to achieve active support for Cyber Security from other business leaders. Occupations - There are significant recruitment and skills issues including an inability to source appropriate information security professionals in particular higher level specialists such as Security Architects and Security Analysts. ## Mobile Technologies Skills needs - Agile techniques, technical pre-sales, sales, marketing, account management support and an extensive understanding of customers' industries are noted as key skills requirements alongside the need for a high degree of interaction between technical specialists, the user experience design team and the end client/customer. Occupations - Mobile technology skills are needed in many IT specialist job roles, whether in design and development, management or support. Highly skilled occupations in mobility include: IT Architects, Developers, User Experience Designers and Project Managers. Hard to find occupations were noted as IT Architects, Developers, User Experience Designers, Testers and Sales and Pre-sales staff. ## Green It Skills needs - Key skills requirements are around energy management expertise, data collection and analytics and integration. It was noted that research and development and high level mathematics skills are not readily available, highlighting the need for STEM skills. As found in other technologies investigated for this project, IT skills need to be complemented with sector or domain specific skills (e.g. in construction and logistics). Business and commercial awareness, communication and presentation skills were found to be needed at a higher level to increase awareness of sustainability issues across the business as well as with customers. Occupations - IT architects and Solution Designers are key high level roles for Green IT. Staff working in this area tend to have extensive IT backgrounds, experience and capability before specialising in Green IT. Certifications are less widely used with solid technical background and experience being favoured, perhaps with a higher level degree. ## Cloud Computing Skills needs - A wide range of technical skills are needed for Cloud Computing although security, networking, virtualisation skills and big data analytics are considered to be the key skills for Cloud. However, IT specialists need broader business skill-sets, especially risk management and business stakeholder management, to bridge the divide between IT and wider business operations. Occupations - Employers report that generally competition for higher level skills means that they find it difficult to recruit into cloud roles, relying on contractors/consultants while they redeploy and upskill their existing staff. ## Project Specification The project will aim to improve the employability and skills of long term unemployed and economically inactive Hounslow residents and aim to move them closer to securing opportunities within the local Digital, Media, Tech and Creative sectors. In particular it should focus on skills and roles that local employers identify as a priority, and where there is expected to be ongoing demand, to maximise chances of sustainable employment for participants. Currently, the employment and skills team provides support for residents to secure employment through a general job brokerage service. The aim of the project is to provide specialist job brokerage support to businesses and residents in the Digital, Media, Tech and Creative sector. There are a number of barriers and issues that are experienced by Hounslow residents: Hounslow has a significant demand for English for Speakers of Other Languages (ESOL) provision, with many residents not having English as a first language. In a number of cases migrants who move to the borough are actually highly-skilled from their home countries but because of the language barrier they find themselves in low-paid employment which raises questions about productivity. Hounslow experiences a substantial churn in the composition of its population due to migration changes, and this churn is particularly concentrated on the central part of the borough. Hounslow is also a very diverse borough in terms of its population and its geography - as the West of borough is in close proximity to Heathrow and the East of the borough bordering Acton and Hammersmith. A high number of high value and high paid jobs within the borough are actually carried out by people who live outside the borough and not Hounslow residents and in particular this is case for the Digital, Media, Tech and Creative sectors. The majority of Hounslow residents find themselves in low-paid employment within the borough. The Digital, Media, Tech and Creative Skills Project should engage fully with on-going and existing plans and strategies within the councils and with other key partners, and where possible work with the services delivered by the skills and employment team, and in particular those which are detailed below: Hounslow Job Brokerage Service - Borough wide job and skills brokerage, which works with local employers to ensure their vacancies can be filled by Hounslow residents. The service provides clients tailored one-to-one support on how to get closer to employment by providing information, advice and guidance [IAG] and where possible removing any barriers to work. The job brokerage service also has a Construction Skills and Employment Officer who specialises in working with employers in the construction, transport and logistics sector. This activity includes providing clients for job vacancies and apprenticeships making sure they have the correct accreditation to work within the sector. Careers Coach - This innovative service provides Hounslow residents with information, advice and guidance on employment, skills and training via a state-of-the-art converted truck, fully equipped with computer stations for residents to work on their CV or job application. The coach aims to provide IAG to residents and sign up clients for Job brokerage and Skills Escalator, and also will offer support to low-paid in work residents who do not qualify for our other projects by signing them up for our work clubs and referring them onto NCS if they require further support. Skills Escalator - The Skills Escalator project aims to help people with low incomes to get training and support to help them improve their skills, and increase their income either through increasing their hours in their current role or by supporting them to find higherpaying jobs. ## Project Requirements The Digital, Media, Tech and Creative Skills ESF project should focus on long term unemployed or economically inactive adults aged 25 and over with a particular focus on ESF target groups which are lone parents, women returners, ethnic minorities and people with disabilities. The successful provider will be expected to work with all of these target groups. The project must work to support a number of different activities to help support local Digital, Media, Tech and Creative sectors - these activities will focus on getting local residents interested in the sector and local opportunities; providing residents with the skills and qualifications linked to skills required by the sector and securing residents into direct employment with local Digital Media/Tech employers. The Mayor and the Local Employment Partnership (LEP) in November 2015 announced it was launching a £5m Digital Skills Programme, the programme activity will be focused on the 14-24 age group. This project should expect to engage with the LEP delivery partner in the local area to complement the LEP's activity. Both programmes are supporting different target groups to engage in the same sector and there will be a number of benefits in working together as there might be opportunities for cross-referral and working together to raise awareness of the projects when engaging with both residents and employers. The Digital, Media, Tech and Creative Skills project provider should seek to coordinate employer contact with the LEP delivery partner to minimise duplication. The project will engage:  A number of key stakeholders to successfully deliver the stated outcomes, the expectations will be for the project to develop strong working relationships with key local providers like West Thames College and University of West London to identify appropriate training provision for clients enrolled onto the project.  Local businesses within the Digital, Media, Tech and Creative sectors to understand their skills requirements, current skills shortages and job opportunities. It should be remembered that different methods will be required to engage the large corporate employers and Small and Medium Enterprises (SMEs) in the sector.  Existing employment services which are being delivered by the Skills and Employment team at Hounslow Council to ensure that these services all link up and are coordinated. The project will need to design interactive and creative methods to engage unemployed Hounslow residents from across different parts of the borough to support creating local skilled residents who can work in the local Digital, Media, Tech and Creative sectors. Payments will be on a payment by results/outcome payment model, weighted towards sustained job outcomes as the key outcome-objective of the project. Therefore, funding is allocated against the following measures, and service providers are asked to bid and provide evidence against the numbers and quality of outcomes they propose to deliver against each of the outputs and results in the table below. ## Digital, Media, Tech And Creative Skills Project | Geographical location | Hounslow | |---------------------------------|--------------| | Contract Period | | | | | | Project Timescale | | | 01/09/2016 to 31/12/2018 | | | Outputs for payment | | | % | | | Conversion | | | No. of | | | Participants | | | Unit Cost | Total | | Delivery | | | Number of Participants | | | 90% | 104 | | Participants receiving 6+ hours | | | of support (IAG, job search, | | | mentoring, training) | | | Participants | undertaking | | work placement | | | | 18 | | Participants achieving | | | vocational qualifications | | | | 7 | | Evaluation | | | Results for payment | | | 50% | 57 | | Participants in | | | employment/apprenticeship | | | within 4 weeks of leaving the | | | project | | | 63% | 36 | | Participants who have | | | sustained employment for 26 | | | weeks (out of 32) | | | Maximum funding available | | | | | Timescales ## 3. Participant Target Groups London Councils' ESF Programme 2016-2018 will support the long-term unemployed and economically inactive individuals who are from the specific target groups outlined below. The Programme's target groups and the relative percentage of starters for each target group are also listed (to the right): Economically Inactive 65% Long-term unemployed 35% ESF Target Groups Women 51% Older People (50 years and over) 18% Ethnic Minorities 60% Disabled (self-declared) 22% Lone Parents 16% Your project will be expected to recruit starters from these target groups, and should meet the percentages as shown in the tables above. Note: one individual may be in one or many of the target groups. Applicants will need to consider the appropriate level of childcare to be provided. London Councils expects all projects to provide childcare for participants as required in order to enable them to access this and other support provided on London Councils' ESF programme. Therefore when designing your project and writing the application, you should give careful consideration to which target groups you will be supporting, how you will reach and assist them into employment. Where you do not have experience in reaching and working with certain groups, your application must show an agreed partnership with a delivery partner with the required experience and outreach. If a potential participant is not from any target group, you will still be expected to assist them either directly or through signposting. Where there are insufficient start volumes from the eligible target groups above and the Applicant can demonstrate to the satisfaction of London Councils that this is despite the Applicant's concerted efforts, London Councils in agreement with the funding Borough may consider widening the eligibility criteria with respect to the employment status of participants. ## Payment May Be Withheld If The Agreed Starters Target Groups Percentages Are Not Met. There is provision in the ESF programme - outside the London Councils ESF programme - for individuals who fit within the NEET target group (people aged 16-18 who are not in employment, education or training). In practice, these individuals are not expected to participate on the London Councils ESF Borough Employment Programme 2016-18. Information about programmes for individuals who fit within the NEET target group can be found through the Skills Funding Agency website: https://lep.london/content_page/skills-funding-agency ## Core Project Requirements Eligibility Of Participants And Definitions Economically inactive - "Inactive" are persons currently not part of the labour force (in the sense that they are not employed or unemployed according to the definitions provided). Long-term unemployed - Long-term unemployed persons are unemployed persons who are either: - Youth long-term unemployed (<25 years of age) = more than 6 months continuous spell of unemployment; or - Adult long-term unemployed (25 years of age or more) = more than 12 months continuous spell of unemployment. The target groups for this prospectus are long-term unemployed and the economically inactive. See above for detail. Individuals who fit within the NEET target group (people aged 16-18 who are not in employment, education or training) **are not eligible** for the London Councils ESF Borough Employment Programme 2016-18. In effect, this means that all participants must be aged 19 or over. Participants must also meet the following criteria:  Live within the specified borough: o Or where participants are homeless their registered Jobseeker's Allowance (JSA) office or temporary/ sheltered accommodation is within the specified borough. Participants who engage onto the project, but then 'move out' of the specified borough may continue to be supported through the programme. (Individuals who live outside the specified borough(s) should be referred to other appropriate support services.)  Have the right to work in the UK.  Participants should not be on another ESF funded employment programme where the claimable financial output/result is the same: o This includes ESF employment programmes delivered under the National Offender Management Service (NOMS), Department for Work and Pensions (DWP), Greater London Authority (GLA), London Councils and Skills Funding Agency.  Are not already mandated on to the Work Programme: o Or are about to be mandated onto the Work Programme or Jobcentre Plus (JCP) approved provision, and the JCP advisor has not approved enrolment onto this programme as an exclusive alternative to the Work Programme. To apply for this Funding, Applicants must be:  constituted: Organisations funded by London Councils must have a constitution or governing document that is signed and dated, and defines how the organisation will operate. A governing document can be a formal constitution, a memorandum or articles of association. o Public or Local authority bodies can apply for grants, however the body bidding must be separate and have appropriate ethical walls from the body awarding the funding3.  able to deliver the work in the borough listed in the project specification:  Financially solvent: Organisations funded by London Councils must not have liabilities that are more than their current assets.  Able to begin delivery of project activity from 5 June 2017: Unless otherwise stated in the application. ## 4. Project Activities, Outputs And Results London Councils ESF Borough Employment Programme 2016-2018 will support objectives under ESF Priority Axis 1– Inclusive Labour Markets delivering outputs and results for the Investment Priority 1.1. As a result the Programme aims to improve access to employment for individuals who are far from the labour market, and need assistance to overcome barriers to work. It will deliver four ESF and Borough jointly funded projects, which aim to:  improve the employability of the economically inactive and long term unemployed individuals so that they can compete effectively in the labour market  provide tailored support for those with particular labour market disadvantage(s) (as detailed in Participant Target Groups section) to improve participants' job readiness and sustainability in employment  encourage inactive people to participate in the labour market and to improve their employability  achieve the basic skills needs of the programme's participants so that they can effectively compete in the labour market. PLEASE NOTE THIS PROSPECTUS IS FOR ONE BOROUGH PROJECT ONLY. Previous borough projects have been advertised in a separate prospectus. Within London, there are a number of programmes already providing support to the unemployed, economically inactive, and long term unemployed. In order to avoid duplication, London Councils and participating borough will fund projects that work with the specific target groups and geographical areas defined within the project specification (Section 2). It is recognised that not all participants will be able to move directly into employment at the end of the project. However, where employment (including self-employment) is a realistic target for individual participants, this is the preferred outcome and this is reflected in the targets agreed with successful applicants. Outputs and Results for payment All payments on the London Councils ESF Borough Programme 2016-18 will be made based on the delivery of pre-specified outputs and results. There are a number of standardised outputs and results for delivery across the specification. These are explained below. Below are all of the specification outputs and result, with associated definitions and evidence requirements. Please note that all of the evidence requirements for output and result payments to be claimed, will also be included in a Project Handbook. Project Handbooks are provided to successful applicants, once the funding agreement with the applicant for delivery of the project is signed with London Councils. ## Standard Outputs Participants receiving six or more hours of one-to-one support There is no payment for enrolments. Instead, after an advance of 15% (of the total agreed budget) the first payment a project receives will be made against participants who receive a minimum of six hours of support (IAG, job search, mentoring and/or training). Providers therefore may enrol as many participants as they wish to or have capacity for, however they will only be paid up to the total amount allocated for each payable output. London Councils' ESF Borough Employment Programme's remit is to assist those furthest from the labour market and this means that for a successful intervention the majority of participants would need a minimum of six hours of support. Please note:  The six hours of support is a milestone which, when passed, allows the project to claim a payment. London Councils requires providers to respond appropriately to participants' needs; those who need a longer intervention in order to secure success should be accommodated and supported effectively throughout.  The six hours of support milestone will not include the time taken to register the participant and complete the enrolment form. Time spent doing the induction, needs assessments, action plans and giving information, advice and guidance may be counted. Class work or other group sessions may not be counted if the milestone has been specified as one-to-one sessions only.  It is recognised that some participants who do not receive six hours of support may still benefit from the programme successfully. Therefore, an employment result may be claimed against any eligible participant, whether or not they have received six hours of support. Any participant for whom a result is claimed must have been enrolled and reported in accordance with London Councils ESF Programme procedures.  London Councils expects all projects to provide childcare for participants as required in order to enable them to access this and other support provided on London Councils' ESF programme. ## Participant Completing Work Placement/Volunteering Initial results of the London Councils ESF Programme 2016-18 indicate that participants who undertake work placements are more likely to secure employment after leaving the programme than those who do not. London Councils wishes to increase the focus on work placements for the 2016-18 programme and has included work placements as an output for payment. Please note:  In order to be claimed as an output for payment, the participant must have completed the work placement.  Work placements are time-limited interventions, giving participants experience of real-life work situations in order to assist them in developing skills, understanding work environments and the expectations of employers. There should be a progression towards paid employment, but the participant should not receive financial compensation for their work (though they may gain financial support with out of pocket expenses e.g. travel, childcare etc.). They should include a structured on-placement training/work plan which takes into account both participant and employer needs and on-placement support to both employer and participant should be provided. Work placements must be for a fixed period of time totalling not less than 30 hours, over a period of time not exceeding twelve weeks. This can include volunteering as long as it meets the criteria outlined above. ## Participant Gaining Basic Skills Basic skills gained upon leaving the operation and as a result of a participant taking part in ESF supported activity. The term `basic skills' refers to one or more of the following: literacy (English); numeracy (maths) or ESOL (where English is not the participant's `mother tongue') ( at entry level or above). Further information about Basic Skills is available in the MI Definitions document (p117): https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/506534/MI_defin itions__Final_V1_20160210.pdf (page 117) ## Participant Achieving Vocational Qualifications Actions to develop skills and promote participation in education/training are central elements of many ESF funded programmes and the monitoring process requires information about the starting position of participants and how this may be influenced through ESF support. Indicators therefore cover the level of educational attainment before support, whether or not any qualifications were gained through ESF support, and subsequent participation in education and training. Please note that we are using the ISCED levels and UK equivalent indicated in the Output and Result Indicator Definitions Guidance for the European Social Fund (pages 131-136). A link to the document is available here:https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/506534/MI_ definitions__Final_V1_20160210.pdf Participants attending skills events (3+ hours) As part of the participants 6+ hours of support, participants should be attending skills events. Events should enable engagement with large groups of clients at the same time to not only help to increase participants for the project but also raise awareness about the project to providers and employers. This should help to deliver IAG in a different way and act as a successful way of engaging participants and stakeholders. This could include holding an event on a particular technical skill/s need, which should be employer-led - so for example if many of the participants on the project are programmers or are interested in becoming programmers, the event could link up with local providers and employers to provide presentations and discuss pathways into the profession. For example, discussing soft skills, amending CVs accordingly, and focussing on future trends in the sector Immediate Results Participants in employment or apprenticeship, including self-employment within four weeks of leaving the Project4 A payment will be made for economically inactive or long term unemployed participants who gain employment within **four** weeks of leaving the project. 'Leaving the project' in this instance marks the date that the participant left the ESF project, after this time no further 'hours of support' can be recorded against a paid outcome. However contact and support to participants is expected to be maintained for as long as the participant feels it is necessary and to ensure that the progression is maintained. To claim this result, the employment must be for 8 or more hours each week, unless otherwise defined in the specification. This may be working for an employer (where their National Insurance is paid directly from their wages) or in self-employment (where people generally pay their National Insurance themselves). Confirmation of self-employment is required. A letter evidencing registration with HMRC, bank statement of a trading business account or registration with Companies House must be provided. For more information on ESF evidence requirements please see: https://www.gov.uk/government/publications/european-structural-and-investment-fundsprogramme-guidance ## Longer-Term Results Participant in sustained employment (including self-employment) for 26 out of 32 weeks A further payment will be made for those participants who sustain their employment for a minimum of six months. All sustained employment results must be achieved by the dates stated within each borough's project specification. Employment does not necessarily need to be with the same employer for the whole period, but all employment must have clear evidence. It is possible that a participant can have breaks in their employment. However for each sustained result a minimum of 26 weeks of 32 weeks is required and must be achieved by the dates stated within each project specification. ## Participant Tracking And On-Going Support Successful projects will be expected to maintain support and track participants on the programme. Projects will need to explain within the grant document their methods and proposal for the support and tracking of participants and details of any in-work support or employer interventions they will deliver. Results can only be claimed once participants leave the project. Submission of a final evaluation You will be responsible for commissioning an independent, external evaluation of the impact of the project, at the end of the project. You will be required to support and contribute to this assessment. Applicants must provide for the cost of the evaluation within the budget submitted as part of the application. The final project payment will be contingent on submission of the evaluation. ## 'Soft' Outcomes Recognising individuals' personal achievements, or soft outcomes, is an important part of helping people towards finding suitable employment. These 'soft outcomes' include for example, helping people to acquire greater self-confidence in their potential or taking steps to overcome barriers to employment. You will be expected to measure the 'distance travelled' (progress/improvements made) by participants while on the project, based on prior assessment and recording of suitable steps- (work carried out by project to achieve participant improvements). This may take the form of progress reports or self-assessment questionnaires. As mentioned you will be expected to compile a final evaluation on your project at project close, which will include an assessment of soft outcomes for participants. You should therefore ensure that you collect information on soft outcomes for each participant throughout the lifetime of the project. ## 5. Added Value London Councils and ESF wish to support projects that could not be delivered without its funding and which bring additional benefits to local provision and individuals. This is called 'added value'. Your project may provide added value because it increases the number of people who receive the support they need to move towards work, or, because it allows you to do more for people than would otherwise be permitted by other funding streams. Alternatively, this funding may allow you to continue existing activity which would otherwise be cut back or it may allow you to develop new activities or to fill a gap in provision. Subject to the eligibility criteria in Section 3, organisations which receive a grant from any London Councils or ESF grants programme are welcome to apply for funding under this programme. However, your application should make very clear what additional activity, outputs or achievements you will deliver through this project. Organisations which have previously received a London Councils grant should note that, unlike other grants, the programme cannot fund general organisational costs, only those which relate solely to the cost of the ESF funded project. ## Esf Employment Support Programmes Where possible applicants are expected to work with other London ESF Programmes' providers, some of which are managed by organisations such as:  Big Lottery  Skills Fund Agency  Department for Work & Pensions  Local Authorities  Greater London Authority Details of their provisions can be found at: https://lep.london/sites/default/files/20160523_Summary_of_ESF_Provision.pdf https://www.biglotteryfund.org.uk/global-content/programmes/england/building-betteropportunities/london ## You Must Ensure There Is No Duplication Of Participants Or Activities With The Above Esf Programmes In London. 6. Partnership Working London Councils wishes to support effective partnership working in project delivery. In particular, we strongly advise delivery organisations to work with partners where complementary expertise is required to deliver a full package of support. For example, where specialist training outside of the provider's core competencies is required, we would prefer that this provision be outsourced to an experienced specialist provider, rather than providers attempting to establish a new training resource. You are also expected to form partnerships with other deliverers in order to recruit people from all target groups. You will be scored accordingly. So please take time to secure agreements with other providers - failure to not detail how all target groups will be recruited and assisted will mean your application may fail. We expect that providers will have established, or be in the final stages of establishing, partnerships prior to submitting their application. All providers intending to work in formal partnership (i.e. where the Applicant, as lead partner, will be paying other partners) must submit partnership agreements with their application which formalise roles and responsibilities within the partnership. As a minimum, a partnership agreement should contain sections on:  who the partners are  roles and responsibilities of each partner  the timescale for delivery  equal opportunities (that the partner must ensure equality of opportunity in line with the lead partner's equal opportunities policy and London Councils and ESF requirements)  the other cross-cutting themes: sustainable development and health  monitoring (including which information the partner is required to keep and how often they are expected to report to the lead partner)  Risks/ mitigation/ contingency plans/ non-delivery/ dispute resolution  Audit (that the project will be subject to audit)  Management of partnership (e.g. steering group, partnership meetings)  Due diligence check of partner organisations (including are they solvent, eligible for London Councils funding)  termination  finance and payments (including how much money will be paid to the partner organisation by the lead organisation, what the money will cover)  deadlines for reporting to the lead partner  It is the lead partner's responsibility to ensure it holds all records relating to any aspect of delivery of the project (including those of partners) until December 2026. This is in line with ESF rules on document retention in ESF Programme Guidance https://www.gov.uk/government/publications/european-structural-and-investment-fundsprogramme-guidance.  Publicity Branding and publicity requirements for the 2014 to 2020 European Regional Development Fund and European Social Fund This type of agreement ensures that project delivery by project partners takes place as discussed and ensures that each partner is clear about what it needs to achieve as part of the project. ## 7. Submitting An Application Gateway Questions All applicants are required to complete a short series of gateway questions in order to determine their eligibility for funding. See Annex A. These will appear as the first stage of the application process once you have created an account. See below for details. If an application does not satisfy these questions, it will be considered ineligible. In such cases, the application and its annexes will not be scored. ## Before You Begin Writing Your Application The funded projects within the London Councils' ESF Borough Employment Programme support the strategic objectives and priorities outlined in the London 2014-2020 ESIF Strategy and the ESF European Operational Programme 2014-2020. As a result, there are certain conditions for this funding which are outlined in the previous and following sections. Please read this guidance carefully before completing the application and consult us *(please see our contact details in Section 19*) if anything is unclear. If your organisation has previously applied for funding from London Councils, you are welcome to reapply in this round. However, please note that some changes have been made to the application form and to the process itself, as well as to the way in which London Councils will fund projects under this Round. If you have any queries relating to the project specification and how to apply, please contact one of the London Councils ESF officers. If you need further guidance or support in putting together your application, you may contact London Voluntary Service Council (LVSC). They are planning to run 1:1 surgeries and workshops. It may be necessary to make an appointment to speak to LVSC and applicants are treated on a first come first served basis. ## Applications For The London Councils Esf Borough Employment Programme 2016-2018 Have To Be Submitted Through An Online Application Process: Applications submitted after the deadline will not be considered for any reason. Leave yourself enough time to complete, review and amend the information you provide, upload the required documents and submit your online form before the deadline. Deadline days are often busy and you may not be able to reach a member of London Councils staff if you have any technical queries with submitting the form. All applications must be submitted through the online form and the Annexes provided on the Programme's website, which, together with the prospectus, can be downloaded from here: http://www.londoncouncils.gov.uk/services/grants/esf The application form includes guidance for each section you need to complete and Annexes you need to upload. Each scored sections will indicate the maximum available score. Please note that your application includes the completion of the Risk Register and Track Record. These are also scored as standalone sections. All other attachments are not scored separately; however, they will support some of the scored sections and will be considered during the assessment process. The person scoring your application can only assess the information stated in your application. You must assume that they know nothing about your organisation, or the needs of your community, so be clear about what activities you are going to do and for whom. There will be no cross references of answers and each answer should be completed fully, as responses for any one question cannot be secured from an answer included for any other question. Please note to be considered for funding, your application must score above 45%. ## Things To Remember About Your Online Form Once you have created a log-in to our form, you can save your on-line application at any point and come back to it later. Once you have saved your on-line application you can open and change the form from any computer. ## Help: If You Need Further Assistance/Information. - Firstly read this guidance section. - Secondly refer to the FAQs (these will be updated regularly) http://www.londoncouncils.gov.uk/services/grants/esf-programme/documents - Thirdly if you still have not been able to find an answer then please email us. Your question and our response will be posted on the FAQs page. Please send your questions before 22nd March 2017 as we may be unable to answer questions after that date. ## Completing Your Online Application Form I. Step One: Create An Account Login And Access The Online Form Click on the following link https://www.grantrequest.com/SID_668/?SA=SNA&FID=35071 to create a login and access a new form, (or copy and paste into your internet address bar). Now you will see this screen, where you create your account and login.  Click on 'New Applicant'  You will be taken to a new page  Enter your email address. The email address must work as we will be using this to contact you about your application and you need it to access a form that you have already started.  Verify your email address (by typing it again)  Create a password. It must be at least five letters long - for example -'Lychee'.  Verify password (by typing it again)  Click on the button marked **'continue'** and you will move straight into the **online form.** You must remember your email address and password as you will need it every time you log into your account. You can save and close your form, by clicking on 'save and finish later' now and at any time and return to the form by accessing your account. To return to your account (where you can access forms already started) click on: http://www.GrantRequest.com/SID_668 ## Ii. Step Two: Complete The Online Form This part of the guidance includes details on how to complete the online application form. ## 1. Technical Help For Using The Online Form The information below will take you through how to use the online form to answer the questions. For most of the form you are asked to simply type your answers into a box under the question. Sometimes you are required to tick a box, select from options or upload a document. The guidance on completing each section is included within the question, upload area or the set template. You will only be able to write in plain text within the answer boxes, therefore you will not be able to use formatting features (e.g. bolding, underlining, resizing and spacing). You can structure your text by adding line breaks and empty rows. Please bear in mind that scorers will have large amounts of information to process, and that it is in your interest to be as clear and concise as possible. ## Mandatory Fields You must answer all questions marked with a purple diamond. If you do not answer these questions you will not be able to submit your application. ## Spell Check Where you see a red tick you can click on it to perform a spell check. ## Word Limit There is a word limit to some questions. Where this is the case the counter will show you how many words are left from the total allowed. Please note that row breaks will not count toward the word count. Attachments You will be required to upload a number of attachments to your application form. ## Before You Can Attach The Documents Online You Need Electronic Versions Of Your Documents Saved Onto Your Computer. Retain The Original Format And File Extension For All The Set Templates. If you don't have electronic copies of other documents to be uploaded (e.g. Constitution) then you can scan the paper copies and save them in a folder on your computer. The maximum size for all attachments combined is 50MB. Files with .exe .com .vbs or .bat will not upload. Uploading a document is similar to attaching a document to an email.  To do this click on the 'browse' button next to the attachment you wish to upload.  This will take you to documents on your pc/network. Search for the correct folder.  Select the correct document and click **'open'.**  Now click on the button **'upload'.**  If you do not click 'upload' your document will not be uploaded to the form.  If you have uploaded the wrong document simply click on **'remove'.** ## 2. How To Save, Print And Return To Your Form Saving Your Work Once you are into the question part of the form you can save what you've done and come back to it at any point by pressing the '**save and finish later'** button. ## We Strongly Advise You To Save Your Form As You Go Along. If You Have Not Saved And Your Computer Crashes You Will Lose All Your Work. Once you have saved your work you will be taken to this screen (below). Simply click on your application and carry on working. ## To Return To Your Form Click on the following link. https://www.GrantRequest.com/SID_668 Log into your account using the email and password you created at the log in stage. You will see the screen above. To go back to your un-submitted application make sure the drop down menu states **'In Progress Applications'** click onto the link to go back to your form. If you have submitted your form you can still view it as a link under the 'Submitted Applications' in the drop down menu. ## To Print Click Save and finish, come back to your form. Click on button **'printer friendly version'** to print. Please note you always need to **click 'save' before printing** your application so that your most up to date version prints out. Do not send us your printed version; simply use it to check your work. London Councils can only accept online applications (unless in exceptional circumstances in which we ask that you please contact us in advance, and within deadline date). Additionally, if you are a disability led organisation and need additional time to complete the application process, London Councils need to be informed of this within deadline date. Where an extension is awarded, London Councils will do this in writing before the standard submittal deadline. ## 3. Completing The Form - Questions The online application form is divided into five main sections: 1. Introduction; 2. Your organisation; 3. Your project summary; 4. Your project delivery; 5. Declaration. ## 1. Introduction The form starts with introductory text covering the assessment of applications. Please read this carefully. The information below will give you guidance on the information required to answer each question. ## Documents You Will Need:  Most attachments are compulsory to complete the application. These are marked with the sign;  Some attachments only apply if your proposed project has delivery partners ## 2. Your Organisation Give details of the lead organisation applying for the funding on this page of the application form. You will also need to upload:  a signed and dated copy of your constitution or memorandum and articles of association and  a copy of your public and employer's liability insurance certificates on this page. ## 3. Your Project Summary Provide general information about your project on this page. This includes the:  project title;  specification you are applying for;  delivery start and end dates;  project summary;  delivery partner details (including attachments if applicable);  contact details for referee. ## 4. Declaration This is the final page of the form. You must **select 'yes'** from the drop down menu if you agree that: o You have read and understood the information contained in the London Councils Application Prospectus; o the proposed activity is within the objects of your organisation's constitution; o London Councils will share the application form and its contents with the participating borough and the City of London Corporation; o this application has the support of your organisation's governing committee/board of trustees/senior management; o all the information you have supplied is accurate; o the information you have supplied about the proposed service is a realistic indication of what your organisation could achieve. ## Important: You Must Select **'Yes'** For Your Application To Be Assessed. ## Requirements We are not permitted to consider any additional information received after the application deadline so please make sure that you have included all the required information and attachments. If you are aware that submitting an application may give rise to a potential conflict of interest please inform the London Councils. A conflict of interest maybe where you are related to a member or staff officer of London Councils or you have privileged information about London Councils that places you at an unfair advantage over other applicants in the application process London Councils is subject to the requirements of the Freedom of Information Act 2000. You should be aware that the information you submit may be subject to a request for information from the public and London Councils may be required to provide information to external parties. ## Data Protection Part or all of the information you give us will be held on computer and used for statistical purposes. It will also be used for the administration of applications and awards. We may provide copies of the information in confidence to individuals or organisations that are helping us assess applications or monitor funding. We may also be required to provide information contained in your application if we receive freedom of information request. ## Finishing The Form  Now you are at the end of the form you may:  You may wish to save and finish later. You may wish to print a copy to proof read it and save it.  When you are ready to submit - click on 'review and submit'  If you have left any mandatory fields blank, or submitted the wrong kind of information (for example text in a box that can only accept numbers) a list of errors will appear in red as below.  The red warning sign and red text will then appear next to any field that you need to amend.  IMPORTANT: Once you have amended the fields, click on the button marked **'update'** or the changes will not be saved.  Once you have amended the fields and clicked 'update' a final version will appear for you to review.  Once you are happy click on the button marked **'submit'**  You will be taken to your account page, where you will see the following message. ## Important Information You **must click 'submit'** to send each application. You will automatically be sent a confirmation email with a copy of your submitted form. If you do not receive a confirmation email, you have not submitted your online form correctly. Please check and submit again. Once submitted you cannot amend your form but you can view it through your account. ## 8. **Horizontal Principles (Formerly Cross Cutting Themes)** London Councils' ESF Programme 2014–2020 will focus on the ESF Investment Priority 1: ## Inclusive Labour Markets To Improving The Employability And Skills Of The Unemployed And Economically Inactive People. There are also two Horizontal Principles that must be addressed in each funded project: Sustainable Development and Equal Opportunities and Non-Discrimination. Sustainable development The Sustainable Development principle of social, economic and environmental organisational responsibilities builds on the approach adopted in the 2007-2013 ESF programme and lessons learned during that programme. These sustainable developments were defined as developments which provided:  skills that businesses demand and require - now and in the future (support for the economy by expanding the labour market);  opportunities to allow everyone to fulfil their potential ( support for social justice); and  environmental protection and enhancement through the delivery of projects (support for the environment). The objectives for ESF Programme 2014-2020 will be pursued in line with the Sustainable Development principle, including the aim of preserving, protecting and improving the quality of the environment as well as the need to prepare for expected changes to the environment and climate. London Council's ESF Borough Employment programme will also support the Social Responsibility aspect of the Principle by achieving progress that recognises the needs of everyone and assists participants towards social inclusion and independent living through employment. Therefore project providers must have sustainable development governance, policies and implementation plans that explain: a) their commitment to promoting sustainable development and complying with relevant EU and domestic environmental legislation; and b) how the commitment will be turned into action at project level. During the life time of each ESF Borough Employment project, London Councils and GLA will be assessing compliance to these policies and plans. Projects will be monitored and this will include basic checks such as ensuring that sustainable development policies and implementation plans are in place and that appropriate action is being taken to implement them. Therefore your application should demonstrate an understanding of the need for good environmental performance and management in keeping with the ethos and achievement of sustainable development in the UK. All projects will be required to consider impact in relation to; energy, water, waste, purchasing and transport. You should also demonstrate how you will integrate relevant aspects of sustainable development into courses you run and/or use the environment as a medium for training delivery. You are required to provide a copy of your sustainable development and/ or environmental policy at the application stage. If your organisation doesn't have a sustainable development policy, please include a statement with your application explaining that the organisation does not yet have a sustainable development policy. Any organisation selected for London Councils ESF Borough Employment Programme funding that does not yet have a sustainable development policy will be required to implement such a policy by the end of the first year of delivery. Equal opportunities and non-discrimination London Councils' ESF Borough Employment Programme will also promote equal opportunities and non-discrimination. All delivery partners will be required to adhere to the principles and processes set out in EU and UK equality legislation. The principles promote equality into the preparation, implementation, monitoring and evaluation of ESF funded activity:  no exclusion on the grounds of protected characteristics;  projects are designed to meet the needs of all potential participants;  services are responsive to the needs of all communities and under-represented groups;  support is targeted towards under-represented communities where relevant;  responsiveness to, and inclusiveness of, under-represented groups in delivery and management. ESF's 2014-20 programme builds on the lessons learned from the ESF 2007-13 programmes, including the findings of an evaluation of the mainstreaming of gender equality and equal opportunities within the ESF in England in 20105. The lessons learnt can be found in research published in 2011 that focussed on the engagement of women in ESF provision6 and an evidence report published in August 2013 on helping disabled people. As a result there is good practice guidance in promoting gender equality. It includes a checklist that will be used to help inform core criteria for project selection along with other equality-related criteria. The principles of equal opportunities is embedded in London Councils' project selection arrangements, grant performance management and monitoring. In support of the principles, the ESF Borough Employment programme will target groups such as the long term unemployed people, inactive people, lone parents, disabled people, people from ethnic minorities, and older people, and we have set output targets to ensure that we help appropriate numbers of these people. The strategy section makes clear that as the economy improves our focus will increasingly be on those who face multiple disadvantages. All ESF activities should be accessible to disabled people and responsive to their needs. The investment priorities on access to employment and active inclusion can support activities focused on improving the employability of disabled people and those with health conditions. Active inclusion will help those furthest from employment and who often experience other disadvantages. People from ethnic minorities should be able to access ESF provision in all investment priorities. Interventions must be tailored to the needs of people from different ethnic minority groups in each locality, and where appropriate targeted on specific groups. There is a strong case for interventions targeted at groups with low employment and high inactivity rates in the access to employment and active inclusion investment priorities, e.g. women of Pakistani and Bangladeshi origin, especially in areas with high concentrations of people from ethnic minorities. Activities in the access to employment, active inclusion and access to lifelong learning investment priorities will respond to the needs of older people. Specific activities will be delivered to help improve the participation of older women, depending on local needs. Equality between men and women Although female participation in the English labour market has increased, there is still a gender gap in employment of 11.7% with a male employment rate of 81.6 % and a female rate of 69.9% (for those aged 20-64). Part of the gap can be attributed to different levels of inactivity in the labour market (26.1% for women and 13.5% for men, aged 20-64 in England). Labour Force Survey (LFS) data show that, at a UK level, 25% of economically inactive women would be interested in working. The Officer for National Statistics (ONS) report 'Women in the Labour Market' (2013) explained that the low ranking for female employment rates in London and Birmingham was linked to the diverse ethnic population with some women not in work due to looking after families. Looking at the most recent city data, Birmingham has the lowest employment rate for women (55.9% for women aged 16-64). Help should be aimed at inactive women from ethnic minorities in England's cities, including those with caring responsibilities (child or elder care) and who are multiply disadvantaged. The extension of the state pension age for women has increased the number of older women in the scope of unemployment. Since 2010 there are more older (over 50) women in work and more looking for work - employment is up 655,000 and unemployment up 14,000 (UK figures). Disadvantaged older women should be targeted for support if they wish to find work (or stay in work). Some women want to work longer hours. There are 4.8 million females in England who work part-time and 1.5 million males. The majority work part-time because they want to - figures are not available for England but at a UK level, only 743,000 out of 6.07 million women (12.2%) work part-time because they couldn't find a full-time job. London Council and ESF funding within this Borough Employment programme will be used to help address these issues. Activities for ESF support should include innovative outreach and holistic support with a vocational focus. Providers must consider activities and support for at least one of these groups:  Inactive women from ethnic minorities, including those with child or elder care responsibilities, and who are often multiply disadvantaged. Barriers include: childcare; lack of skills or work experience due to starting family at a young age; no opportunity to acquire skills before starting a family.  Lone parents. Barriers include: inflexible jobs/employers (poor work/life balance), concerns about possible financial instability and lack of skills/recent skills. Examples of activities to be supported include job search skills, vocational training, remedial training and basic skills support.  Disadvantaged older unemployed women. Barriers include age discrimination, low confidence and elder care responsibilities. Activities to be supported include job search training, skills refresher training and mentoring/ confidence building.  Women who are inactive but who would be interested in working. Barriers include lack of motivation and confidence, lack of skills, outdated skills and difficulties in travelling to work. Activities to be supported include confidence building support, job-search training, jobspecific training, work experience and mentoring support.  Women seeking career advancement and/or progressing from part-time to full-time work, or at least increasing their hours at work. Barriers include seasonal work, sectors with a high concentration of part-time work and age (younger people are more likely to be underemployed). Activities to be supported include upskilling/vocational qualifications and identifying progression routes. (Investment Priority 2.1) Project applicants submitting applications will be required to explain how they will actively promote gender equality through the design and delivery of their projects. For example, a grant application for in-work training should require the applicant organisation to explain how it will ensure that female employees will have access to support, including those who may be working part-time and/or have childcare needs. Providers targeting disadvantaged people and other groups are also required under the Equality Act 2010 to do so with a corresponding gender focus. This will include actively encouraging more women to take part in the programme, as well as making sure that the type and nature of support offered is appropriate and helps meet the needs of women, including disadvantaged women. Programme providers will be expected to consider the needs of women in a number of key areas of design and delivery of their services, for example by:  promoting gender equality throughout their recruitment process;  offering information, advice and guidance;  providing or procuring childcare support where this might be a barrier to participation;  ensuring that the structure and content of the activities delivered are suitable and appropriate for women and men;  ensuring that provision is accessible, flexible and gender-sensitive where necessary. London Councils will ensure that there is regular monitoring of the participation rates for women and men. Results data will also be monitored and reported to GLA's European Performance Management Unit (EPMU). ## 9. Monitoring And Reporting On Your Project London Councils has to report to the Managing Authority for ESF on the progress of the ESF programme each quarter as part of the procedure for claiming funds. These reports will include data on participants, on project activities and on total expenditure. Successful applicants will therefore be required to submit reports at the end of each quarter. These reports will enable London Councils to meet the ESF and its own reporting requirements but will also form the basis for monitoring your project progress and achievements. Organisations will be given full advice in the pre-agreement phase on the information that must be recorded and reported and the implications for project procedures and systems. Employability Performance Rating ESF funded projects in London are also required to implement the Employability Performance Rating system. The Performance Rating is a comprehensive tool to benchmark the achievements of employability delivered by service providers in London. The rating system awards a rating of between four and zero stars against three key areas: Grant Performance, Quality and Grant Compliance. Key Performance Area (KPA) Weighting of the KPA Indicators Weighting of Indicator Grant Performance 60%  Delivery against grant targets 48% 12%  Delivery against grant diversity targets 12% Quality 30%  Conversion Factor  Self-assessment of quality 9% 9%  Participant Satisfaction 10% Grant Compliance 10%  Grant compliance and provider proactivity The Performance Rating is collected from funded projects quarterly with results made public and published biannually on the London Datastore (http://data.london.gov.uk/dataset/lepr-esf- 2014-20). More information regarding the Employability Performance Rating requirements will be provided during the grant agreement process and the reporting systems will be provided to you. However an overview of the requirements can be found here: http://data.london.gov.uk/dataset/lepr-esf-2014-20 ## 10. Financial Information London Councils ESF programmes pay providers on the basis of unit prices per output and result. In other words, your project will be paid for the delivery of certain pre-specified outputs and results. The budget available for each output and results is fixed and stated in the project specification along with the specification descriptions. Please note that London Councils expects that your intended project delivery activities are not dependent on other sources of funding. By planning your delivery on the basis of actual costs, your organisation should be able to compare the anticipated budget for delivering the specification with the funding available. Please note that unless otherwise stated in the specification, the funding and, where appropriate, the number of outputs/results represent the maximum funding available. Please also note that London Councils reserves the right, in agreement with the participating borough, to reduce or increase the value of the grant by up to 100% in line with performance. You will be required to submit a project budget as part of your application. Whilst you will be paid on the basis of grant agreement costs, London Councils' assessors will be looking at your project budget to check that your application represents value for money, and that all costs included are ESF eligible. Assessors will also be checking to see that you have included enough staff in your budget to deliver the project. In addition, assessors will be checking that you have included adequate provision for participant support measures such as childcare and also for publicity. Your budget is part of your application for funding and will be scored as such. Staff costs In this section of the application form you should provide details of all the costs that relate to staffing your project. List the job title of the staff member involved and a short explanation of how the cost was calculated. If there are any other costs relating to staff (e.g. travel, subsistence etc.) you should include them in this section. You should give a brief explanation of how you calculated your costs, to enable assessors to clearly understand what is being applied for. For example - Item Calculation Amount Trainer 5hrs per month x 9 months x £16 per hr £720 Travel to outreach centre 1 person x £3 x 2 per wk x 34 weeks £204 Participant costs In this section of the application form you should provide details of all the costs relating to items that you will provide to participants. For example, childcare, out of pocket travel costs, allowances, refreshments, equipment that participants may need for training (e.g. protective clothing), and so on. All entries should be itemised and calculations shown to explain the costs. For example: | Item | Calculation | Amount | |---------------------------|--------------------------------------|-----------| | Childcare/carer allowance | £50 per wk x 7 people x 34 weeks | £11,900 | | Travel | 10 people x £3 x 3 per wk x 34 weeks | £3,060 | London Councils expects all projects to provide child or dependent care for participants as required in order to enable them to access the programme. Other costs In this section of the application form you should provide details of any other costs of your project, which do not relate to staff or participants. This will include other direct and indirect costs of the project, for example, small items of equipment, exam fees, publicity materials, postage, photocopying etc. Indirect costs, which are shared organisational costs e.g. rent, utilities, that cannot be connected directly to project activity and which are difficult to attribute to the project may be claimed but must be apportioned appropriately. Indirect project costs cannot represent more than 15% of the proposed budget. Eligible items of expenditure Funding can cover all the running costs of your project as long as they are ESF eligible (please see ESF National Eligibility rules https://www.gov.uk/government/publications/europeanstructural-and-investment-funds-programme-guidance) and you list them in your application. When budgeting, if some items are used for both this project and your other activities, you should apportion the cost as appropriate. This funding does not cover capital expenditure; it only covers the costs associated with setting up and running your project. However you are permitted to include the purchase of small items of equipment under the value of £1000 per item which are necessary for the delivery of your project.7 ## 11. Publicity Arrangements ESF funding carries requirements to adhere to the ESF 2014-20 publicity guidance:  ensure that potential and actual participants, project partners, and employers, are aware of the source of support;  publicise project successes; and  participate as far as is practicable in London and national ESF publicity initiatives, including providing information for public directories of projects. For example, London Councils and ESF logos should be present on all information and forms given to participants and included in all project publicity produced. Further guidance on publicity will be given to successful applicants. All publicity materials developed to advertise or promote the project will need to be made available for inspection and approved prior to use. For more detail on ESF publicity requirements, please visit https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/470206/ESIF_Pu blicity_Requirements_v2_221015.pdf. ## 12. Assessment Process Assessment against criteria The selection process for making an appeal will be as open, objective and fair as possible but because the amount of funding available through London Councils ESF Programme is limited, only a small number of projects can be supported. All applications will be carefully assessed against the criteria set out in the ESF Borough Employment Prospectus and their fit with the stated objectives will be judged. The Project's proposed outputs and value for money will also be assessed e.g. assessors will check your budget to see that you have given due consideration to staff numbers and participant costs and the track record of your organisation will be considered. Funds are limited and not all projects that apply will receive funding. It is therefore important that you demonstrate in your project application how your project meets the criteria laid out in this guidance. Your project must fit the specification outlined in Section 2. Once the assessor is satisfied that your project and organisation is eligible for support, the rest of your application will be scored by awarding points against each of the assessment questions in the Application form. Instructions on completing the application form are included with each question in the application, and should be read carefully before you complete your answer. Each application will be scored separately by two independent assessors, generally a representative from the Borough Officer and London Councils. The application form sets out the points available for each part of each question. These assessors will then come together to discuss the application and definitive score for your project proposal. Applications will also be assessed against your project's ability to promote equality and social inclusion as well as sustainable development (Questions C7 a) and b) - Horizontal Principles in the Application form). Applicants will therefore be required to score at least 3 marks (out of a possible 6 marks) for Question C7a)-Equal Opportunities and non-discrimination. And score at least 1 mark (out of a possible 6 marks) for Question C7b)-Sustainable development. If you do not achieve at least the minimum marks above for the above questions your application will not proceed. Your application can only be assessed on the information stated in your application. You must assume that the scorers know nothing about your organisation, or the needs of your community, so be clear about what activities you are going to do and for whom. There will be no cross references of answers and each answer should be completed fully, as responses for any one question cannot be secured from an answer included for any other question. Please note to be considered for funding, your application must score above 45%. References London Councils intends to reference delivery organisations through its network of Borough grants officers, to verify whether the organisation has experience of working within the Borough and with the particular participant group relevant to this application. If you do not consider that the relevant officer has sufficient knowledge of your organisation to provide this reference, please supply details of an alternative referee in the application form. The internal appraisal panel Following scoring, an internal appraisal panel will convene to review the each project application and the proposed joint scores. The Panel is comprised of senior representatives from London Councils' ESF Team. Other participants may be invited to join the appraisal panel should the number of applications warrant this. The Panel will be recommending the successful applicants to the External Panel. In addition to the joint scores, the Panel will take into account further factors such as previous experience, value for money and the project's fit within London Councils' ESF Programme. This will ensure that projects funded under the ESF Programme collectively meet the whole range of target groups and that there is a good mix of projects and that there is a fair spread of projects geographically across London related to need. The panel will consider the geographic coverage of the provision, and coverage could be a deciding factor when funding is awarded. The recommendations of the Panel will be reported to the external panel for final sign-off. All applicants will be informed of their scores and provided feedback on their application. Applicants will then have the opportunity to make an appeal against the score and/or feedback. Appeals Applicants will be given 10 working days to submit an appeal against the funding decisions made by the Internal Appraisal Panel. Please note we will only accept one appeal per application submitted. **No new information relating to the application can be considered**. Due to the limited funding available, it is likely that a number of good proposals will not be successful. Most disappointed applicants think that their application deserved a higher score. The appeals process will provide the applicant with clarification or a further explanation of a score. An appeal based on the fact that the project has been successful in the past will not be investigated further. ESF Officers will consider the appeal received and update the Internal Appraisal Panel recommendations for review by the External Panel. ## External Panel The External Panel Will Provide The Final Judgement On Applications. This panel is comprised of:  a representative(s) from a suitable general voluntary sector umbrella organisation;  borough representative(s); and  representative(s) of the Intermediate Body for ESF in London (the GLA's European Programmes Management Unit). The Panel's judgement will be based on the information provided the Internal Panel. This is to ensure that the projects chosen meet ESF and London Councils' corporate aims and objectives. It will also help to ensure that there is no duplication of activities. We can provide feedback to unsuccessful applicants. The Pre-agreement meeting The Pre-agreement meeting will take place between the provider, London Councils appointed ESF performance manager and possibly a representative from the borough providing match funding. The meeting aims to outline the London Councils' project delivery process including:  Roles and responsibilities between London Councils and your project  Review working relationships with project partners (include SLAs)  Confirmation of the outputs and results your project will deliver  Agreement of the Project's Delivery Schedule  Review Risk Register and intended actions to manage risks  Explain London Councils' ESF monitoring and payment arrangements  Confirm evidence requirements for expenditure, outputs and results  Confirm evaluation requirements  Confirm publicity requirements  Confirm General Data Protection Regulation requirements At the meeting, a list of actions will be drawn up which must be completed before your organisation can be awarded its funding agreement. These will include but are not limited to:  Your signed project delivery schedule profile  Your bank details template completed and stamped  Your Borough Cashflow forecast  Clarification of any outstanding due diligence issues or issues identified in your application  A signed copy of the Service Level Agreement's between you and your partners. ## 13. Payment Arrangements London Councils provides an advance payment to all funded organisations. Up to 15% of the agreed grant will be paid in advance to providers upon satisfactory completion of funding agreements with London Councils. Payments in the final quarters of delivery will be reduced to take into account the initial first advance payment. London Councils will then pay providers quarterly in arrears on the basis of project costs. Projects will be paid for the delivery of pre-specified outputs and results. These are described in Section 2 Project Specification. Please note: London Councils is generally unable to recover any Value Added Tax charged. Therefore, the maximum sum stated in the project specification listed above includes any VAT or other taxes charged. Under the provision of item 5A to group 6 of schedule 9 of the VAT Act 1994, the supply of education or vocational training funded by London Councils, and the supply by the person providing that education or training, of any goods or services essential to that provision, is an exempt supply for VAT purposes. In addition, the maximum sum stated in the project specification should include provision for direct costs to participants such as childcare, travel, subsistence, or participant incentives. ## 14. Contacts For queries regarding the application process please contact: Maxine Quintyne-Kolaru London Councils ESF Priority Manager maxine.quintyne-kolaru@londoncouncils.gov.uk 020 7934 9835 Karen Ferguson, London Councils ESF Borough Employment Programme Manager karen.ferguson@londoncouncils.gov.uk 020 7934 9954 Simon Courage, London Councils Head of Community Services and Grants. simon.courage@londoncouncils.gov.uk 020 7934 9901 Ann Britton, London Councils ESF Performance Manager ann.britton@londoncouncils.gov.uk 020 7934 9952 http://www.londoncouncils.gov.uk/services/grants/esf-programme For other support, including a discussion of your project, please contact: ## Support For Bidders VCS Assist 2.0 is an EU part-funded project supporting voluntary and community sector organisations in London to successfully access the European Social Fund and deliver ESF projects. It succeeds the VCS Assist project which operated during the 2007-2013 ESF Round. VCS Assist 2.0 project partners, London Voluntary Service Council and the Evelyn Oldfield Unit, will deliver:  One to one surgeries for organisations intending to apply for or holding ESF funding, providing a range of support from application guidance, complying with ESF requirements and ESF project management  Workshops focusing on particular skills required for ESF and opportunities  Forum events, bringing together organisations interested in ESF from across London to share information and provide networking opportunities  Regular updates on ESF opportunities and progress, including through the vcsassist.org.uk website and monthly e-bulletins. Further queries about the VCS Assist 2.0 programme should be directed to: Steve White, Policy Officer - Employment and Skills Stevegwhite.eu@gmail.com info@lvsc,org,uk 020 7832 5811 London Voluntary Service Council (LVSC) 2nd floor, 200a Pentonville Road London N1 9JP http://www.lvsc.org.uk/ ## 15. Esf Programme Guidance Documents This section provides the latest information and guidance documents to help you understand how to develop and deliver ESF compliant projects. All providers should acquaint themselves with these guidance documents. The latest version of the documents below can be found at the following site: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/470206/ESIF_Pu blicity_Requirements_v2_221015.pdf ## Background Information On European Social Funds Esf Operational Programme For England 2014 To 2020 The European Social Fund Operational Programme sets out the strategy and priorities for use of the Fund to support the Europe 2020 strategy for smart, sustainable and inclusive growth. ## Esif Strategy This document outlines; London's key areas for ESF (and ERDF) investment against its Jobs and Growth Plan priorities. ## Project Delivery Information Eligibility rules for the 2014 to 2020 European Social Fund European Social Fund programme guidance ## European Social Fund Data Evidence Requirements - Eligibility And Results Guidance Branding And Publicity Requirements For The 2014 To 2020 European Regional Development Fund And European Social Fund European Social Fund Guidance On Document Retention Output And Result Indicator Definitions Guidance For The European Social Fund This prospectus invites applications for ESF grants. It is not a procurement tender, however, providers under the prospectus may procure services and will therefore have to follow ESF procurement guidance: Procurement law compliance guidance note Procurement aide memoire for applicants and grant recipients ## Gateway Questions: 1. Does your organisation have a Constitution, Memorandum of Association or Articles of Association? 2. Are you organisationally a going concern? 3. Does your organisation have a copy of its most recent signed accounts (audited accounts where required)? 4. Does your organisation have an Equal Opportunities Policy? 5. Does your organisation have a Sustainable Development Policy? 6. Does your organisation have a Health & Safety Policy? 7. Do you commit to taking out the appropriate levels of insurance required to deliver the project? 8. Will you provide the specified services of the project to residents of the borough where you are applying to deliver a project in and detailed in the relevant specification? (Hounslow)? 9. Can you provide evidence that your organisation has policies in place that adhere to the data protection act? Failure to provide any of the documents or other evidence specified may result in your application being not pursued. Should your application be successful, the provision of and our approval of, your organisation's child and adult safeguarding policies will also be a condition of grant funding.
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Department family Entity Date Expense Type Expense area Supplier Transaction number AP Amount (£) VAT registration number Purchase invoice number Department of Health NHS Oxfordshire CCG 31/08/2016 Charges from CSU PROGRAMME PROJECTS NHS SOUTH CENTRAL AND WEST COMMISSIONING SUPPORT UNIT 13646734 316,510.00 7312700122 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec NHS Trust-Contract Baseline ACUTE COMMISSIONING BUCKINGHAMSHIRE HEALTHCARE NHS TRUST 13646900 239,194.22 654 4313 46 BB005230 Department of Health NHS Oxfordshire CCG 31/08/2016 Services From Local Authorities QUALITY ASSURANCE OXFORDSHIRE COUNTY COUNCIL 13650033 60,000.00 3920083031 Department of Health NHS Oxfordshire CCG 31/08/2016 Other Gen Supplies & Srv PRESCRIBING NORTH WEST OSTOMY SUPPLIES 13673120 105,366.60 391-5320-58 0000000070 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS SOUTH WARWICKSHIRE NHS FOUNDATION TRUST 13673124 96,980.00 W0093076 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-APMS Contract Value PRC DELEGATED CO-COMMISSIONING NHS ENGLAND 13673128 116,254.24 654 442 045 7000019998 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING PRINCIPAL MEDICAL 13673130 55,833.33 2001637 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Clinical Other PRESCRIBING NORTH WEST OSTOMY SUPPLIES 13673132 111,447.93 391-5320-58 0000000075 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING PRINCIPAL MEDICAL 13673137 55,833.33 2001641 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE CHILDRENS SERVICES SEESAW 13673152 35,000.00 265 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING PRINCIPAL MEDICAL 13673178 (55,833.33) 1000148 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING PRINCIPAL MEDICAL 13673180 (55,833.33) 1000147 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector PLANNED CARE SCRIVENS LTD 13673189 29,014.32 10Q0285 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector PLANNED CARE SPECSAVERS HEARCARE LTD 13673212 39,515.80 159320215 20740119 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline NHS 111 SOUTH CENTRAL AMBULANCE SERVICE NHS FOUNDATION TRUST 13673270 179,835.05 INV00000000043209 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING CIRCLEREADING T/A CIRCLE HOSPITAL (READING) LTD 13690533 27,612.08 10Q042016OP2 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector PLANNED CARE INHEALTH ENDOSCOPY LTD 13690539 79,576.50 001221 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector PLANNED CARE BPAS 13690551 35,168.08 855924881 31447 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector LONG TERM CONDITIONS PRINCIPAL MEDICAL 13706413 44,333.33 2001671 Department of Health NHS Oxfordshire CCG 31/08/2016 NHS Payables <1Yr-Non PO Accruals BALANCE SHEET OXFORD HEALTH NHS FOUNDATION TRUST 13706427 30,844.50 GB654935896 A0099237 Department of Health NHS Oxfordshire CCG 31/08/2016 NHS Payables <1Yr-Non PO Accruals BALANCE SHEET OXFORD HEALTH NHS FOUNDATION TRUST 13706432 (30,844.50) GB654935896 A0099593 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13739298 107,381.00 INT5 K84009 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13739306 91,072.00 INT5 K84044 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING HART SURGERY 13739312 69,929.00 INT5 K84001 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13739320 76,285.00 INT5 K84014 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13739327 27,040.00 INT5 K84015 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13739334 77,611.00 INT5 K84019 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13739339 111,764.00 INT5 K84002 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13739347 123,130.00 INT5 K84027 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13739357 86,809.00 INT5 K84033 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 13751540 2,661,016.50 GB654935896 A0099508 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING ROYAL BERKSHIRE NHS FOUNDATION TRUST 13751621 1,736,120.00 654938593 480194 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757292 (39,250.00) OX000016087 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - PMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757292 (1,582.12) OX000016087 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-PMS GP Pension EEs-PMS PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757292 (5,535.07) OX000016087 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-PMS GP Pension ERs Adjs - PMS PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757292 (5,717.22) OX000016087 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Baseline Adjustment PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757294 378.06 OX000016088 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Contract Value PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757294 74,319.94 OX000016088 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757294 2,007.67 OX000016088 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS NES Premium PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757294 15,990.23 OX000016088 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS PCO Seniority PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757294 2,574.31 OX000016088 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Prof fees Dispensing PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757294 10,885.92 OX000016088 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13757294 8,468.85 OX000016088 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13757840 76,285.00 K84014 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-APMS Contract Value PRC DELEGATED CO-COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 13797845 57,185.97 GB654935896 A0099511 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-APMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 13797845 941.15 GB654935896 A0099511 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-APMS Contract Value PRC DELEGATED CO-COMMISSIONING VIRGIN CARE COVENTRY LLP 13797851 34,141.00 304002720 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-APMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING VIRGIN CARE COVENTRY LLP 13797851 6,935.00 304002720 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-APMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING VIRGIN CARE COVENTRY LLP 13797851 5,290.00 304002720 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector PLANNED CARE OXFORD FERTILITY UNIT 13812195 40,992.00 OXF0881 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline COMMUNITY SERVICES OXFORD UNIVERSITY HOSPITALS NHS TRUST 13825997 403,666.67 8226969 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector END OF LIFE MARIE CURIE CANCER CARE 13826056 52,000.00 003170 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Over/ Under Performance ACUTE COMMISSIONING GREAT WESTERN HOSPITALS NHS FOUNDATION TRUST 13826093 74,796.00 16964691 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING OXFORD UNIVERSITY HOSPITALS NHS TRUST 13826139 25,752,618.00 8234808 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline AMBULANCE SERVICES SOUTH CENTRAL AMBULANCE SERVICE NHS FOUNDATION TRUST 13826164 373,612.36 INV00000000043230 31/08/2016 Hcare Srv Rec Fdtn Trust-Over/ Under Performance PLANNED CARE OXFORD HEALTH NHS FOUNDATION TRUST 13826178 82,012.79 GB654935896 A0099496 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline PLANNED CARE OXFORD HEALTH NHS FOUNDATION TRUST 13826180 244,000.00 GB654935896 A0099512 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline COMMUNITY SERVICES OXFORD HEALTH NHS FOUNDATION TRUST 13826189 5,404,166.67 GB654935896 A0099509 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline OUT OF HOURS OXFORD HEALTH NHS FOUNDATION TRUST 13826189 484,333.33 GB654935896 A0099509 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Cost per Case MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 13826189 815,173.33 GB654935896 A0099509 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Cost per Case MENTAL HEALTH SERVICES - OTHER OXFORD HEALTH NHS FOUNDATION TRUST 13826189 862,160.00 GB654935896 A0099509 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Othe Public Sector CHC ADULT JOINT FUNDED OXFORDSHIRE COUNTY COUNCIL 13826200 4,144,385.67 3920087868 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Othe Public Sector LEARNING DIFFICULTIES OXFORDSHIRE COUNTY COUNCIL 13826200 1,109,812.25 3920087868 Department of Health NHS Oxfordshire CCG 31/08/2016 Cont Care-Physical Disab (65+) CHC ADULT JOINT FUNDED OXFORDSHIRE COUNTY COUNCIL 13826200 655,533.00 3920087868 Department of Health NHS Oxfordshire CCG 31/08/2016 Continuing Care- Equipment CHC ADULT JOINT FUNDED OXFORDSHIRE COUNTY COUNCIL 13826200 88,416.67 3920087868 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline AMBULANCE SERVICES SOUTH CENTRAL AMBULANCE SERVICE NHS FOUNDATION TRUST 13826204 1,726,669.00 INV00000000043165 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING GREAT WESTERN HOSPITALS NHS FOUNDATION TRUST 13826276 268,766.00 16965271 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING SOUTH WARWICKSHIRE NHS FOUNDATION TRUST 13826285 51,565.00 W0095209 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING GLOUCESTERSHIRE HOSPITALS NHS FOUNDATION TRUST 13826286 42,510.00 1014827 Department of Health NHS Oxfordshire CCG 31/08/2016 Charges from CSU FINANCE NHS SOUTH CENTRAL AND WEST COMMISSIONING SUPPORT UNIT 13826287 396,634.00 7312700743 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING NUFFIELD HEALTH 13826288 154,162.00 564291137 AUGUST2016001 Department of Health NHS Oxfordshire CCG 31/08/2016 Income tax <1Yr BALANCE SHEET HMRC 13848483 69,564.83 120PS005674981704 Department of Health NHS Oxfordshire CCG 31/08/2016 Income tax <1Yr-Student Loans BALANCE SHEET HMRC 13848483 1,194.00 120PS005674981704 Department of Health NHS Oxfordshire CCG 31/08/2016 National Insurance < 1 yr-NI- ERS BALANCE SHEET HMRC 13848483 45,819.63 120PS005674981704 Department of Health NHS Oxfordshire CCG 31/08/2016 National Insurance < 1 yr-NI-EES BALANCE SHEET HMRC 13848483 31,090.31 120PS005674981704 Department of Health NHS Oxfordshire CCG 31/08/2016 Statutory Mat Pay < 1 yr BALANCE SHEET HMRC 13848483 (3,967.60) 120PS005674981704 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING CIRCLEREADING T/A CIRCLE HOSPITAL (READING) LTD 13857542 107,478.08 10Q072016 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING BERKSHIRE INDEPENDENT HOSPITAL 13857577 36,475.00 OXOND0716 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING CIRCLEREADING T/A CIRCLE HOSPITAL (READING) LTD 13857693 107,478.08 10Q082016 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING FOSCOTE PRIVATE HOSPITAL (BMI) 13857766 57,264.58 10QFOSM05AUG16INVOICE Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING RYCOTE PRACTICE 13862376 232.00 BU000015155 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING RYCOTE PRACTICE 13862376 70,100.50 BU000015155 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING RYCOTE PRACTICE 13862376 3,606.08 BU000015155 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING RYCOTE PRACTICE 13862376 6,038.42 BU000015155 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING RYCOTE PRACTICE 13862376 715.00 BU000015155 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING RYCOTE PRACTICE 13862376 7,772.51 BU000015155 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING FOSCOTE PRIVATE HOSPITAL (BMI) 13876358 48,614.45 10QFOSM12MARCH16ADDITIONALI Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS ROYAL DEVON AND EXETER NHS FOUNDATION TRUST 13876371 25,692.49 26338023 Department of Health NHS Oxfordshire CCG 31/08/2016 Other professional fees MEDICAL DIRECTORATE PRINCIPAL MEDICAL 13876376 34,231.50 2001677 Department of Health NHS Oxfordshire CCG 31/08/2016 Charges from CSU PROGRAMME PROJECTS NHS SOUTH CENTRAL AND WEST COMMISSIONING SUPPORT UNIT 13876385 70,530.20 7312700513 Department of Health NHS Oxfordshire CCG 31/08/2016 Charges from CSU PROGRAMME PROJECTS NHS SOUTH CENTRAL AND WEST COMMISSIONING SUPPORT UNIT 13876389 45,785.27 7312700527 Department of Health NHS Oxfordshire CCG 31/08/2016 Charges from CSU PROGRAMME PROJECTS NHS SOUTH CENTRAL AND WEST COMMISSIONING SUPPORT UNIT 13876390 35,173.37 7312700534 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract AMBULANCE SERVICES SOUTH CENTRAL AMBULANCE SERVICE NHS FOUNDATION TRUST 13883332 73,843.84 INV00000000042368 Department of Health NHS Oxfordshire CCG 31/08/2016 Other professional fees MEDICAL DIRECTORATE PRINCIPAL MEDICAL 13883464 34,231.50 2001737 Department of Health NHS Oxfordshire CCG 31/08/2016 Other professional fees MEDICAL DIRECTORATE PRINCIPAL MEDICAL 13883496 (34,231.50) 1000149 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING OXFORD UNIVERSITY HOSPITALS NHS TRUST 13908926 5,100,000.00 8235260 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING HORTON NHS TREATMENT CENTRE 13908943 603,687.00 426505170 HOROXF201605 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING ROYAL BERKSHIRE NHS FOUNDATION TRUST 13909034 615,252.00 654938593 480264 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING OXFORD UNIVERSITY HOSPITALS NHS TRUST 13909041 (5,100,000.00) CN8235260 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec NHS CCG-Contract Baseline ACUTE COMMISSIONING NHS SLOUGH CCG 13909050 272,257.00 7028101528 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 13909058 450,511.25 GB654935896 A0099857 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING BEAUMONT STREET SURGERY 13916880 745.75 OX000016094 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BEAUMONT STREET SURGERY 13916880 25,699.71 OX000016094 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING BEAUMONT STREET SURGERY 13916880 3,314.74 OX000016094 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BEAUMONT STREET SURGERY 13916880 2,450.04 OX000016094 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING BELL SURGERY 13916882 1,373.23 OX000016096 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BELL SURGERY 13916882 56,331.32 OX000016096 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING BELL SURGERY 13916882 1,858.23 OX000016096 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BELL SURGERY 13916882 6,477.41 OX000016096 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING ABINGDON SURGERY 13916884 2,150.96 OX000016098 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING ABINGDON SURGERY 13916884 464.00 OX000016098 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING ABINGDON SURGERY 13916884 79,356.39 OX000016098 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING ABINGDON SURGERY 13916884 3,538.23 OX000016098 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING ABINGDON SURGERY 13916884 4,025.00 OX000016098 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING ABINGDON SURGERY 13916884 9,426.86 OX000016098 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING BAMPTON MEDICAL PRACTICE 13916886 1,299.60 OX000016100 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING BAMPTON MEDICAL PRACTICE 13916886 10,919.30 OX000016100 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BAMPTON MEDICAL PRACTICE 13916886 55,083.73 OX000016100 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING BAMPTON MEDICAL PRACTICE 13916886 963.51 OX000016100 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING BAMPTON MEDICAL PRACTICE 13916886 6,201.83 OX000016100 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BAMPTON MEDICAL PRACTICE 13916886 6,222.23 OX000016100 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING BANBURY ROAD MEDICAL CENTRE 13916888 1,244.50 OX000016102 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING BANBURY ROAD MEDICAL CENTRE 13916888 10,449.81 OX000016102 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BANBURY ROAD MEDICAL CENTRE 13916888 42,450.22 OX000016102 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING BANBURY ROAD MEDICAL CENTRE 13916888 1,968.12 OX000016102 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING BANBURY ROAD MEDICAL CENTRE 13916888 1,275.00 OX000016102 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BANBURY ROAD MEDICAL CENTRE 13916888 3,235.88 OX000016102 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING BARTLEMAS SURGERY 13916890 1,445.90 OX000016104 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING BARTLEMAS SURGERY 13916890 348.00 OX000016104 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING BARTLEMAS SURGERY 13916890 12,149.55 OX000016104 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BARTLEMAS SURGERY 13916890 51,399.78 OX000016104 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING BARTLEMAS SURGERY 13916890 2,577.22 OX000016104 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BARTLEMAS SURGERY 13916890 4,963.67 OX000016104 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BLETCHINGTON ROAD SURGERY 13916892 39,361.13 OX000016106 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING BLETCHINGTON ROAD SURGERY 13916892 3,597.29 OX000016106 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING BLETCHINGTON ROAD SURGERY 13916892 10,250.00 OX000016106 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BLETCHINGTON ROAD SURGERY 13916892 4,322.46 OX000016106 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING BOTLEY MEDICAL CENTRE 13916894 1,472.18 OX000016108 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING BOTLEY MEDICAL CENTRE 13916894 696.00 OX000016108 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING BOTLEY MEDICAL CENTRE 13916894 12,362.35 OX000016108 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BOTLEY MEDICAL CENTRE 13916894 57,731.30 OX000016108 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING BOTLEY MEDICAL CENTRE 13916894 4,900.00 OX000016108 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BOTLEY MEDICAL CENTRE 13916894 5,732.38 OX000016108 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916895 (107,381.00) OX000016109 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916895 (11,233.33) OX000016109 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916895 (207.29) OX000016109 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916895 (8,105.25) OX000016109 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916895 (9,601.23) OX000016109 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916896 2,270.18 OX000016110 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916896 928.00 OX000016110 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916896 90,513.34 OX000016110 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916896 24,328.03 OX000016110 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916896 485.70 OX000016110 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916896 11,233.33 OX000016110 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BURY KNOWLE HEALTH CENTRE 13916896 8,353.62 OX000016110 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING BROADSHIRES HEALTH CENTRE 13916898 1,574.31 OX000016112 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING BROADSHIRES HEALTH CENTRE 13916898 13,220.20 OX000016112 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BROADSHIRES HEALTH CENTRE 13916898 53,955.60 OX000016112 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING BROADSHIRES HEALTH CENTRE 13916898 5,506.68 OX000016112 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BROADSHIRES HEALTH CENTRE 13916898 6,207.42 OX000016112 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING CHARLBURY MEDCIAL CENTRE 13916900 833.31 OX000016114 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING CHARLBURY MEDCIAL CENTRE 13916900 33,141.27 OX000016114 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING CHARLBURY MEDCIAL CENTRE 13916900 782.44 OX000016114 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING CHARLBURY MEDCIAL CENTRE 13916900 4,458.33 OX000016114 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING CHARLBURY MEDCIAL CENTRE 13916900 3,137.61 OX000016114 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING CHILTERN SURGERY 13916902 1,180.85 OX000016116 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING CHILTERN SURGERY 13916902 52,223.33 OX000016116 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING CHILTERN SURGERY 13916902 2,009.08 OX000016116 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING CHILTERN SURGERY 13916902 6,950.00 OX000016116 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING CHILTERN SURGERY 13916902 4,957.57 OX000016116 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13916903 (86,809.00) OX000016117 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13916903 (84.53) OX000016117 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13916903 (5,764.46) OX000016117 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13916903 (6,262.21) OX000016117 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING COGGES SURGERY 13916905 1,086.64 OX000016120 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING COGGES SURGERY 13916905 9,127.79 OX000016120 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING COGGES SURGERY 13916905 35,989.62 OX000016120 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING COGGES SURGERY 13916905 2,520.91 OX000016120 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING COGGES SURGERY 13916905 3,965.33 OX000016120 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING COGGES SURGERY 13916905 4,021.89 OX000016120 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING CROPREDY SURGERY 13916907 556.70 OX000016122 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING CROPREDY SURGERY 13916907 24,958.71 OX000016122 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING CROPREDY SURGERY 13916907 661.37 OX000016122 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING CROPREDY SURGERY 13916907 2,228.48 OX000016122 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING DR A MURPHY & PARTNERS 13916909 2,016.38 OX000016124 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING DR A MURPHY & PARTNERS 13916909 1,160.00 OX000016124 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING DR A MURPHY & PARTNERS 13916909 77,852.82 OX000016124 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING DR A MURPHY & PARTNERS 13916909 8,019.34 OX000016124 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING DR A MURPHY & PARTNERS 13916909 9,987.60 OX000016124 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13916910 (111,764.00) OX000016125 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Actual Rent PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13916910 (21,245.92) OX000016125 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13916910 (1,461.93) OX000016125 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13916910 (5,810.84) OX000016125 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13916910 (6,578.00) OX000016125 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING DR HAMMERSLEY & PARTNERS OXFORD 13916912 1,043.58 OX000016128 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING DR HAMMERSLEY & PARTNERS OXFORD 13916912 116.00 OX000016128 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING DR HAMMERSLEY & PARTNERS OXFORD 13916912 35,533.79 OX000016128 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING DR HAMMERSLEY & PARTNERS OXFORD 13916912 4,455.82 OX000016128 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING DR HAMMERSLEY & PARTNERS OXFORD 13916912 2,532.66 OX000016128 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING DR KENYON & PARTNERS 13916914 2,263.85 OX000016130 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING DR KENYON & PARTNERS 13916914 70,603.10 OX000016130 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING DR KENYON & PARTNERS 13916914 5,762.90 OX000016130 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING DR KENYON & PARTNERS 13916914 5,938.51 OX000016130 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING DR T W ANDERSON & PARTNERS 13916916 1,533.30 OX000016132 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING DR T W ANDERSON & PARTNERS 13916916 116.00 OX000016132 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING DR T W ANDERSON & PARTNERS 13916916 12,878.39 OX000016132 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING DR T W ANDERSON & PARTNERS 13916916 47,056.18 OX000016132 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING DR T W ANDERSON & PARTNERS 13916916 10,768.48 OX000016132 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING DR T W ANDERSON & PARTNERS 13916916 3,784.42 OX000016132 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING DR T W ANDERSON & PARTNERS 13916916 983.33 OX000016132 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING DR T W ANDERSON & PARTNERS 13916916 4,682.02 OX000016132 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING EARLS LANE HEALTH CENTRE 13916918 116.00 OX000016134 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING EARLS LANE HEALTH CENTRE 13916918 13,060.60 OX000016134 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING EARLS LANE HEALTH CENTRE 13916918 67,605.33 OX000016134 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING EARLS LANE HEALTH CENTRE 13916918 6,054.17 OX000016134 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING EARLS LANE HEALTH CENTRE 13916918 6,610.54 OX000016134 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING EAST OXFORD HEALTH CENTRE STEVENS 13916920 16,656.50 OX000016136 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING EAST OXFORD HEALTH CENTRE STEVENS 13916920 44,694.39 OX000016136 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING EAST OXFORD HEALTH CENTRE STEVENS 13916920 1,668.13 OX000016136 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING EAST OXFORD HEALTH CENTRE STEVENS 13916920 3,618.61 OX000016136 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13916921 (9,366.67) OX000016137 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13916921 (9,326.19) OX000016137 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13916921 (9,596.50) OX000016137 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13916922 2,177.08 OX000016138 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13916922 89,457.78 OX000016138 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13916922 4,373.62 OX000016138 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13916922 9,366.67 OX000016138 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13916922 11,436.42 OX000016138 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING FANE DRIVE HEALTH CENTRE 13916924 763.48 OX000016140 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING FANE DRIVE HEALTH CENTRE 13916924 33,738.46 OX000016140 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING FANE DRIVE HEALTH CENTRE 13916924 1,851.97 OX000016140 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING FANE DRIVE HEALTH CENTRE 13916924 4,465.30 OX000016140 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING GOSFORD HILL MEDICAL CENTRE 13916926 1,104.38 OX000016142 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING GOSFORD HILL MEDICAL CENTRE 13916926 9,280.74 OX000016142 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING GOSFORD HILL MEDICAL CENTRE 13916926 42,156.83 OX000016142 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING GOSFORD HILL MEDICAL CENTRE 13916926 3,320.70 OX000016142 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING GOSFORD HILL MEDICAL CENTRE 13916926 5,229.54 OX000016142 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING GORING & WOODCOTE MEDICAL PRACTICE 13916928 1,515.88 879063483 OX000016146 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING GORING & WOODCOTE MEDICAL PRACTICE 13916928 65,870.45 879063483 OX000016146 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING GORING & WOODCOTE MEDICAL PRACTICE 13916928 2,408.62 879063483 OX000016146 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING GORING & WOODCOTE MEDICAL PRACTICE 13916928 9,725.00 879063483 OX000016146 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING GORING & WOODCOTE MEDICAL PRACTICE 13916928 7,534.62 879063483 OX000016146 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING HART SURGERY 13916929 (69,929.00) OX000016147 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING HART SURGERY 13916929 (5,345.13) OX000016147 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING HART SURGERY 13916929 (5,516.23) OX000016147 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING HOLLOW WAY MEDICAL CENTRE 13916933 1,327.78 OX000016152 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING HOLLOW WAY MEDICAL CENTRE 13916933 50,029.09 OX000016152 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING HOLLOW WAY MEDICAL CENTRE 13916933 1,411.21 OX000016152 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING HOLLOW WAY MEDICAL CENTRE 13916933 10,595.00 OX000016152 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING HOLLOW WAY MEDICAL CENTRE 13916933 6,040.19 OX000016152 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING HIGHTOWN SURGERY 13916935 1,686.25 OX000016154 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING HIGHTOWN SURGERY 13916935 232.00 OX000016154 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING HIGHTOWN SURGERY 13916935 14,168.49 OX000016154 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING HIGHTOWN SURGERY 13916935 64,856.06 OX000016154 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING HIGHTOWN SURGERY 13916935 2,643.63 OX000016154 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING HIGHTOWN SURGERY 13916935 4,500.00 OX000016154 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING HIGHTOWN SURGERY 13916935 7,735.04 OX000016154 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING HORSEFAIR SURGERY 13916937 2,770.52 OX000016156 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING HORSEFAIR SURGERY 13916937 23,256.38 OX000016156 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING HORSEFAIR SURGERY 13916937 108,561.77 OX000016156 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING HORSEFAIR SURGERY 13916937 675.00 OX000016156 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING HORSEFAIR SURGERY 13916937 13,732.31 OX000016156 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING KENNINGTON HEALTH CENTRE 13916939 1,029.01 OX000016158 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING KENNINGTON HEALTH CENTRE 13916939 116.00 OX000016158 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING KENNINGTON HEALTH CENTRE 13916939 41,240.43 OX000016158 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING KENNINGTON HEALTH CENTRE 13916939 901.05 OX000016158 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING KENNINGTON HEALTH CENTRE 13916939 5,356.80 OX000016158 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING JERICHO HEALTH CENTRE KEARLEY 13916941 1,744.83 OX000016160 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING JERICHO HEALTH CENTRE KEARLEY 13916941 60,066.86 OX000016160 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING JERICHO HEALTH CENTRE KEARLEY 13916941 7,948.24 OX000016160 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING JERICHO HEALTH CENTRE KEARLEY 13916941 12,148.67 OX000016160 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING JERICHO HEALTH CENTRE KEARLEY 13916941 5,768.23 OX000016160 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING JERICO HEALTH CENTRE BOGDANOR 13916943 1,066.38 OX000016162 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING JERICO HEALTH CENTRE BOGDANOR 13916943 8,960.21 OX000016162 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING JERICO HEALTH CENTRE BOGDANOR 13916943 34,214.55 OX000016162 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING JERICO HEALTH CENTRE BOGDANOR 13916943 4,941.27 OX000016162 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING JERICO HEALTH CENTRE BOGDANOR 13916943 8,146.58 OX000016162 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING JERICO HEALTH CENTRE BOGDANOR 13916943 1,961.48 OX000016162 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING KING EDWARD STREET SURGERY 13916945 727.86 OX000016164 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING KING EDWARD STREET SURGERY 13916945 22,624.78 OX000016164 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING KING EDWARD STREET SURGERY 13916945 1,035.82 OX000016164 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING KING EDWARD STREET SURGERY 13916945 1,204.45 OX000016164 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING LONG FURLONG MEDICAL CENTRE 13916947 1,436.72 OX000016166 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING LONG FURLONG MEDICAL CENTRE 13916947 44,995.27 OX000016166 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING LONG FURLONG MEDICAL CENTRE 13916947 6,068.31 OX000016166 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING LONG FURLONG MEDICAL CENTRE 13916947 5,616.83 OX000016166 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING LONG FURLONG MEDICAL CENTRE 13916947 1,403.33 OX000016166 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING LONG FURLONG MEDICAL CENTRE 13916947 4,482.23 OX000016166 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Actual Rent PRC DELEGATED CO-COMMISSIONING LEYS HEALTH CENTRE 13916948 (51,117.26) OX000016167 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING LEYS HEALTH CENTRE 13916948 (616.00) OX000016167 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING LEYS HEALTH CENTRE 13916948 (4,936.05) OX000016167 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING LEYS HEALTH CENTRE 13916948 (4,867.96) OX000016167 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING LEYS HEALTH CENTRE 13916949 1,716.18 OX000016168 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING LEYS HEALTH CENTRE 13916949 66,808.30 OX000016168 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING LEYS HEALTH CENTRE 13916949 2,784.97 OX000016168 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING LEYS HEALTH CENTRE 13916949 7,496.42 OX000016168 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING MARSTON MEDICAL CENTRE 13916951 777.73 OX000016170 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MARSTON MEDICAL CENTRE 13916951 28,644.49 OX000016170 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING MARSTON MEDICAL CENTRE 13916951 1,290.40 OX000016170 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING MARSTON MEDICAL CENTRE 13916951 2,966.67 OX000016170 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING MARSTON MEDICAL CENTRE 13916951 2,503.38 OX000016170 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916952 (123,130.00) OX000016171 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Actual Rent PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916952 (11,344.33) OX000016171 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916952 (899.44) OX000016171 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916952 (9,386.84) OX000016171 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916952 (9,947.45) OX000016171 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916953 2,918.56 OX000016172 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916953 24,509.24 OX000016172 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916953 111,203.52 OX000016172 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916953 13,185.10 OX000016172 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916953 802.66 OX000016172 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Actual Rent PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916953 11,344.33 OX000016172 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING MALTHOUSE SURGERY 13916953 15,238.59 OX000016172 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916954 (91,072.00) OX000016173 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916954 (6,541.67) OX000016173 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916954 (793.02) OX000016173 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916954 (4,484.31) OX000016173 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916954 (5,494.69) OX000016173 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916955 2,339.85 OX000016174 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916955 19,654.74 OX000016174 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916955 90,441.59 OX000016174 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916955 7,253.28 OX000016174 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916955 469.02 OX000016174 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916955 6,541.67 OX000016174 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING MANOR SURGERY 13916955 9,165.22 OX000016174 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916956 (11,483.33) OX000016175 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916956 (1,705.58) OX000016175 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916956 (6,760.43) OX000016175 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916956 (7,018.91) OX000016175 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916957 1,624.00 OX000016176 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916957 16,184.77 OX000016176 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916957 74,209.39 OX000016176 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916957 1,894.93 OX000016176 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916957 11,483.33 OX000016176 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916957 7,667.03 OX000016176 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Prior Year EEs PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13916957 1,151.31 OX000016176 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING MILL STREAM SURGERY 13916958 750.66 OX000016178 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MILL STREAM SURGERY 13916958 32,190.55 OX000016178 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING MILL STREAM SURGERY 13916958 1,573.95 OX000016178 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING MILL STREAM SURGERY 13916958 4,773.33 OX000016178 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING MILL STREAM SURGERY 13916958 3,290.68 OX000016178 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916959 (76,285.00) OX000016179 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916959 (8,262.92) OX000016179 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916959 (142.53) OX000016179 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916959 (6,001.24) OX000016179 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916959 (6,747.22) OX000016179 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916960 1,683.24 OX000016180 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916960 69,884.98 OX000016180 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916960 10,459.01 OX000016180 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916960 496.91 OX000016180 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916960 8,262.92 OX000016180 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13916960 7,363.65 OX000016180 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING NORTH BICESTER SURGERY 13916962 673.71 OX000016182 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING NORTH BICESTER SURGERY 13916962 20,603.03 OX000016182 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING NORTH BICESTER SURGERY 13916962 5,086.69 OX000016182 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING NORTH BICESTER SURGERY 13916962 2,202.55 OX000016182 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916963 (27,040.00) OX000016183 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916963 (8,750.00) OX000016183 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916963 (220.28) OX000016183 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916963 (305.95) OX000016183 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916963 (350.01) OX000016183 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916964 26,302.24 OX000016184 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916964 3,749.47 OX000016184 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916964 280.13 OX000016184 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916964 8,750.00 OX000016184 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13916964 2,973.50 OX000016184 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13916965 (77,611.00) OX000016185 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13916965 (6,262.08) OX000016185 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13916965 (6,494.59) OX000016185 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING NUFFIELD HEALTH CENTRE 13916967 70,798.07 OX000016188 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING NUFFIELD HEALTH CENTRE 13916967 1,910.06 OX000016188 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING NUFFIELD HEALTH CENTRE 13916967 10,460.00 OX000016188 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING NUFFIELD HEALTH CENTRE 13916967 10,250.93 OX000016188 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING OAK TREE HEALTH CENTRE 13916969 12,934.25 OX000016190 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING OAK TREE HEALTH CENTRE 13916969 48,372.58 OX000016190 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING OAK TREE HEALTH CENTRE 13916969 13,399.45 OX000016190 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING OAK TREE HEALTH CENTRE 13916969 302.58 OX000016190 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING OAK TREE HEALTH CENTRE 13916969 4,437.74 OX000016190 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING SOUTH OXFORD HEALTH CENTRE 13916972 614.97 OX000016194 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING SOUTH OXFORD HEALTH CENTRE 13916972 21,327.26 OX000016194 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING SOUTH OXFORD HEALTH CENTRE 13916972 1,754.82 OX000016194 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING SOUTH OXFORD HEALTH CENTRE 13916972 2,151.57 OX000016194 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING SHEEP STREET SURGERY BURFORD 13916974 1,021.09 OX000016196 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING SHEEP STREET SURGERY BURFORD 13916974 43,061.48 OX000016196 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING SHEEP STREET SURGERY BURFORD 13916974 1,290.70 OX000016196 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING SHEEP STREET SURGERY BURFORD 13916974 7,350.00 OX000016196 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING SHEEP STREET SURGERY BURFORD 13916974 5,136.36 OX000016196 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING ST BARTHOLOMEWS MEDICAL CENTRE 13916978 3,068.66 OX000016200 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING ST BARTHOLOMEWS MEDICAL CENTRE 13916978 90,837.28 OX000016200 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING ST BARTHOLOMEWS MEDICAL CENTRE 13916978 9,475.88 OX000016200 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING ST BARTHOLOMEWS MEDICAL CENTRE 13916978 8,915.83 OX000016200 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING ST BARTHOLOMEWS MEDICAL CENTRE 13916978 5,393.50 OX000016200 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING SUMMERTOWN HEALTH CENTRE 13916980 2,428.99 OX000016202 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING SUMMERTOWN HEALTH CENTRE 13916980 84,696.03 OX000016202 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING SUMMERTOWN HEALTH CENTRE 13916980 6,033.67 OX000016202 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING SUMMERTOWN HEALTH CENTRE 13916980 7,856.66 OX000016202 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING ST CLEMENTS SURGERY OXFORD 13916982 721.68 OX000016204 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING ST CLEMENTS SURGERY OXFORD 13916982 26,123.00 OX000016204 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING ST CLEMENTS SURGERY OXFORD 13916982 2,808.29 OX000016204 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING ST CLEMENTS SURGERY OXFORD 13916982 2,020.25 OX000016204 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING ST CLEMENTS SURGERY OXFORD 13916982 2,771.04 OX000016204 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING TEMPLE COWLEY HEALTH CENTRE 13916984 51,317.95 OX000016206 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING TEMPLE COWLEY HEALTH CENTRE 13916984 1,139.34 OX000016206 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING TEMPLE COWLEY HEALTH CENTRE 13916984 5,937.73 OX000016206 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING VICTORIA HOUSE SURGERY 13916986 1,212.36 OX000016208 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING VICTORIA HOUSE SURGERY 13916986 10,179.82 OX000016208 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING VICTORIA HOUSE SURGERY 13916986 41,540.11 OX000016208 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING VICTORIA HOUSE SURGERY 13916986 3,529.21 OX000016208 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING VICTORIA HOUSE SURGERY 13916986 4,357.84 OX000016208 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Actual Rent PRC DELEGATED CO-COMMISSIONING WEST BAR SURGERY 13916987 (83,250.00) OX000016209 Department of Health NHS Oxfordshire CCG 31/08/2016 ME - GMS TPS Added Years Adj EEs PRC DELEGATED CO-COMMISSIONING WEST BAR SURGERY 13916987 (242.40) OX000016209 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING WEST BAR SURGERY 13916987 (5,431.23) OX000016209 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING WEST BAR SURGERY 13916987 (6,236.23) OX000016209 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING WEST BAR SURGERY 13916988 2,666.02 OX000016210 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WEST BAR SURGERY 13916988 104,080.61 OX000016210 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WEST BAR SURGERY 13916988 11,498.51 OX000016210 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING WHITE HORSE MEDICAL CENTRE 13920990 2,379.91 OX000016212 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING WHITE HORSE MEDICAL CENTRE 13920990 232.00 OX000016212 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WHITE HORSE MEDICAL CENTRE 13920990 103,839.07 OX000016212 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING WHITE HORSE MEDICAL CENTRE 13920990 3,285.68 OX000016212 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING WHITE HORSE MEDICAL CENTRE 13920990 147.75 OX000016212 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WHITE HORSE MEDICAL CENTRE 13920990 11,191.75 OX000016212 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING WALLINGFORD MEDICAL PRACTICE 13920992 2,632.61 OX000016214 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WALLINGFORD MEDICAL PRACTICE 13920992 110,057.28 OX000016214 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING WALLINGFORD MEDICAL PRACTICE 13920992 7,295.90 OX000016214 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING WALLINGFORD MEDICAL PRACTICE 13920992 758.86 OX000016214 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING WALLINGFORD MEDICAL PRACTICE 13920992 4,800.00 OX000016214 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING WALLINGFORD MEDICAL PRACTICE 13920992 4,166.67 OX000016214 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WALLINGFORD MEDICAL PRACTICE 13920992 12,719.94 OX000016214 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WATERY LANE SURGERY 13920994 21,687.88 OX000016216 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING WATERY LANE SURGERY 13920994 1,764.15 OX000016216 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING WATERY LANE SURGERY 13920994 1,950.00 OX000016216 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WATERY LANE SURGERY 13920994 2,007.36 OX000016216 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING WOODLAND SURGERY BANBURY 13920997 1,104.38 OX000016219 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING WOODLAND SURGERY BANBURY 13920997 116.00 OX000016219 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WOODLAND SURGERY BANBURY 13920997 40,360.94 OX000016219 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING WOODLAND SURGERY BANBURY 13920997 4,124.24 OX000016219 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING WOODLAND SURGERY BANBURY 13920997 2,757.25 OX000016219 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WOODLAND SURGERY BANBURY 13920997 4,341.92 OX000016219 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING WOODLANDS MEDICAL CENTRE 13920999 1,712.38 OX000016221 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WOODLANDS MEDICAL CENTRE 13920999 69,758.24 OX000016221 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING WOODLANDS MEDICAL CENTRE 13920999 2,248.88 OX000016221 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING WOODLANDS MEDICAL CENTRE 13920999 9,500.00 OX000016221 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WOODLANDS MEDICAL CENTRE 13920999 7,570.23 OX000016221 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING WOODSTOCK SURGERY 13921001 1,446.06 OX000016223 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WOODSTOCK SURGERY 13921001 64,036.14 OX000016223 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING WOODSTOCK SURGERY 13921001 2,458.33 OX000016223 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WOODSTOCK SURGERY 13921001 7,215.52 OX000016223 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING WYCHWOOD SURGERY 13921003 927.52 OX000016225 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WYCHWOOD SURGERY 13921003 41,287.61 OX000016225 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING WYCHWOOD SURGERY 13921003 1,162.12 OX000016225 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING WYCHWOOD SURGERY 13921003 8,708.33 OX000016225 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WYCHWOOD SURGERY 13921003 4,148.66 OX000016225 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING WINDRUSH MEDICAL PRACTICE WITNEY 13921005 2,304.54 OX000016227 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING WINDRUSH MEDICAL PRACTICE WITNEY 13921005 2,204.00 OX000016227 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING WINDRUSH MEDICAL PRACTICE WITNEY 13921005 19,367.46 OX000016227 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WINDRUSH MEDICAL PRACTICE WITNEY 13921005 88,776.48 OX000016227 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING WINDRUSH MEDICAL PRACTICE WITNEY 13921005 2,866.81 OX000016227 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WINDRUSH MEDICAL PRACTICE WITNEY 13921005 10,109.23 OX000016227 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING WINDRUSH SURGERY BANBURY 13921007 1,218.85 OX000016229 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING WINDRUSH SURGERY BANBURY 13921007 812.00 OX000016229 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING WINDRUSH SURGERY BANBURY 13921007 48,772.73 OX000016229 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING WINDRUSH SURGERY BANBURY 13921007 1,326.95 OX000016229 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING WINDRUSH SURGERY BANBURY 13921007 3,083.33 OX000016229 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING WINDRUSH SURGERY BANBURY 13921007 4,874.18 OX000016229 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING DONNINGTON MEDICAL PARTNERSHIP (THE) 13921009 2,374.05 OX000016231 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING DONNINGTON MEDICAL PARTNERSHIP (THE) 13921009 92,456.57 OX000016231 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Cost Rent PRC DELEGATED CO-COMMISSIONING DONNINGTON MEDICAL PARTNERSHIP (THE) 13921009 1,454.42 OX000016231 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING DONNINGTON MEDICAL PARTNERSHIP (THE) 13921009 9,175.00 OX000016231 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING DONNINGTON MEDICAL PARTNERSHIP (THE) 13921009 10,637.56 OX000016231 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13921010 (27,262.92) GB186693943 OX000016232 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension EEs PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13921010 (10,569.89) GB186693943 OX000016232 Department of Health NHS Oxfordshire CCG 31/08/2016 ME-GMS GP Pension ERs Adjustments PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13921010 (10,424.11) GB186693943 OX000016232 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13921011 2,333.20 GB186693943 OX000016233 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13921011 19,596.22 GB186693943 OX000016233 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13921011 101,697.15 GB186693943 OX000016233 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13921011 1,711.01 GB186693943 OX000016233 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13921011 27,262.92 GB186693943 OX000016233 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13921011 11,855.73 GB186693943 OX000016233 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING BLOXHAM & HOOK NORTON SURGERIES 13922285 1,131.93 GB 879120308 OX000016144 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING BLOXHAM & HOOK NORTON SURGERIES 13922285 580.00 GB 879120308 OX000016144 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING BLOXHAM & HOOK NORTON SURGERIES 13922285 9,506.84 GB 879120308 OX000016144 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING BLOXHAM & HOOK NORTON SURGERIES 13922285 47,755.90 GB 879120308 OX000016144 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING BLOXHAM & HOOK NORTON SURGERIES 13922285 464.77 GB 879120308 OX000016144 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING BLOXHAM & HOOK NORTON SURGERIES 13922285 7,275.00 GB 879120308 OX000016144 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING BLOXHAM & HOOK NORTON SURGERIES 13922285 4,398.99 GB 879120308 OX000016144 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING KEY MEDICAL PRACTICE 13922287 1,994.21 OX000016235 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING KEY MEDICAL PRACTICE 13922287 2,204.00 OX000016235 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING KEY MEDICAL PRACTICE 13922287 16,759.33 OX000016235 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING KEY MEDICAL PRACTICE 13922287 72,145.69 OX000016235 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING KEY MEDICAL PRACTICE 13922287 13,140.00 OX000016235 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING KEY MEDICAL PRACTICE 13922287 480.79 OX000016235 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING KEY MEDICAL PRACTICE 13922287 5,858.33 OX000016235 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING KEY MEDICAL PRACTICE 13922287 9,549.56 OX000016235 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline PATIENT TRANSPORT SOUTH CENTRAL AMBULANCE SERVICE NHS FOUNDATION TRUST 13923788 336,146.04 INV00000000043171 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13933367 2,102.83 OX000016118 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13933367 27,627.25 OX000016118 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13933367 85,352.77 OX000016118 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13933367 5,143.26 OX000016118 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13933367 748.57 OX000016118 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING CHURCH STREET PRACTICE 13933367 10,066.28 OX000016118 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13933368 2,804.88 OX000016126 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13933368 696.00 OX000016126 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13933368 100,619.45 OX000016126 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS LES Medical Fees LOCAL ENHANCED SERVICES DIDCOT HEALTH CENTRE 13933368 154.00 OX000016126 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13933368 17,402.99 OX000016126 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13933368 555.56 OX000016126 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Actual Rent PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13933368 21,245.92 OX000016126 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING DIDCOT HEALTH CENTRE 13933368 11,560.35 OX000016126 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING HART SURGERY 13933369 1,640.18 OX000016148 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING HART SURGERY 13933369 232.00 OX000016148 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING HART SURGERY 13933369 64,679.25 OX000016148 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING HART SURGERY 13933369 7,315.31 OX000016148 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING HART SURGERY 13933369 782.07 OX000016148 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING HART SURGERY 13933369 7,525.00 OX000016148 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING HART SURGERY 13933369 5,730.30 OX000016148 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13933371 2,453.85 OX000016186 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Learn Dsblty Hlth Chk PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13933371 116.00 OX000016186 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13933371 98,201.77 OX000016186 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13933371 6,753.31 OX000016186 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13933371 655.58 OX000016186 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING NEWBURY STREET PRACTICE 13933371 7,954.56 OX000016186 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES Extended Hours Access PRC DELEGATED CO-COMMISSIONING SONNING COMMON HEALTH CENTRE 13933372 1,370.38 OX000016192 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS DES UNPLANNED ADMISSIONS PRC DELEGATED CO-COMMISSIONING SONNING COMMON HEALTH CENTRE 13933372 11,521.79 OX000016192 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Global Sum PRC DELEGATED CO-COMMISSIONING SONNING COMMON HEALTH CENTRE 13933372 56,219.57 OX000016192 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS MPIG Correction Factor PRC DELEGATED CO-COMMISSIONING SONNING COMMON HEALTH CENTRE 13933372 6,408.14 OX000016192 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Other Baseline Adjustment PRC DELEGATED CO-COMMISSIONING SONNING COMMON HEALTH CENTRE 13933372 908.67 OX000016192 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING SONNING COMMON HEALTH CENTRE 13933372 8,000.00 OX000016192 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS QOF Aspiration PRC DELEGATED CO-COMMISSIONING SONNING COMMON HEALTH CENTRE 13933372 6,814.76 OX000016192 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector PLANNED CARE SPECSAVERS HEARCARE LTD 13945276 38,934.10 159320215 20740118 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector LONG TERM CONDITIONS PRINCIPAL MEDICAL 13945303 44,333.33 2001764 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector PALLIATIVE CARE SUE RYDER CARE 13963995 125,000.00 071606 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Othe Public Sector CHC ADULT JOINT FUNDED OXFORDSHIRE COUNTY COUNCIL 13964198 4,128,069.71 3920088495 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Othe Public Sector LEARNING DIFFICULTIES OXFORDSHIRE COUNTY COUNCIL 13964198 1,109,812.25 3920088495 Department of Health NHS Oxfordshire CCG 31/08/2016 Cont Care-Physical Disab (65+) CHC ADULT JOINT FUNDED OXFORDSHIRE COUNTY COUNCIL 13964198 655,533.00 3920088495 Department of Health NHS Oxfordshire CCG 31/08/2016 Continuing Care- Equipment CHC ADULT JOINT FUNDED OXFORDSHIRE COUNTY COUNCIL 13964198 88,416.67 3920088495 Department of Health NHS Oxfordshire CCG 31/08/2016 External Consultancy Fees MEDICAL DIRECTORATE OXFED HEALTH & CARE LTD 13964287 26,250.00 OXFED0023 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector PLANNED CARE SPECSAVERS HEARCARE LTD 13964550 33,561.70 159320215 20740122 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BAMPTON MEDICAL PRACTICE 13975393 28,680.92 OX000016344 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING BAMPTON MEDICAL PRACTICE 13975393 6,055.77 OX000016344 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES BAMPTON MEDICAL PRACTICE 13975393 1,436.40 OX000016344 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BLETCHINGTON ROAD SURGERY 13975397 (47,029.80) OX000016348 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING BLETCHINGTON ROAD SURGERY 13975397 (3,502.20) OX000016348 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BLETCHINGTON ROAD SURGERY 13975398 89,413.49 OX000016349 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING BLETCHINGTON ROAD SURGERY 13975398 16,822.69 OX000016349 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES BLETCHINGTON ROAD SURGERY 13975398 3,502.20 OX000016349 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES CHARLBURY MEDCIAL CENTRE 13975404 21,570.01 OX000016355 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING CHARLBURY MEDCIAL CENTRE 13975404 3,558.37 OX000016355 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES CHARLBURY MEDCIAL CENTRE 13975404 814.80 OX000016355 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES COKER CLOSE HEALTH CENTRE 13975408 (26,677.65) OX000016359 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Prsc Chrgs Cll&Rmttd by GPs PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13975408 (1,923.60) OX000016359 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES COKER CLOSE HEALTH CENTRE 13975409 53,075.31 OX000016360 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Prsc Chrgs Cll&Rmttd by GPs LOCAL ENHANCED SERVICES COKER CLOSE HEALTH CENTRE 13975409 1,923.60 OX000016360 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES CROPREDY SURGERY 13975411 (32,641.26) OX000016363 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING CROPREDY SURGERY 13975411 (2,578.80) OX000016363 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES CROPREDY SURGERY 13975412 63,726.14 OX000016364 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING CROPREDY SURGERY 13975412 11,754.29 OX000016364 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES CROPREDY SURGERY 13975412 2,578.80 OX000016364 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES DR A MURPHY & PARTNERS 13975413 (32,607.10) OX000016365 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING DR A MURPHY & PARTNERS 13975413 (2,578.80) OX000016365 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES DR A MURPHY & PARTNERS 13975414 63,113.18 OX000016366 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING DR A MURPHY & PARTNERS 13975414 11,815.66 OX000016366 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES DR A MURPHY & PARTNERS 13975414 2,578.80 OX000016366 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES DR T W ANDERSON & PARTNERS 13975419 23,109.99 OX000016371 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING DR T W ANDERSON & PARTNERS 13975419 5,328.16 OX000016371 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES DR T W ANDERSON & PARTNERS 13975419 1,083.60 OX000016371 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES EARLS LANE HEALTH CENTRE 13975420 (94,295.94) OX000016372 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING EARLS LANE HEALTH CENTRE 13975420 (8,845.00) OX000016372 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES EARLS LANE HEALTH CENTRE 13975421 145,238.09 OX000016373 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING EARLS LANE HEALTH CENTRE 13975421 35,612.78 OX000016373 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES EARLS LANE HEALTH CENTRE 13975421 8,845.00 OX000016373 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES EYNSHAM MEDICAL CENTRE 13975423 (47,252.24) OX000016375 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13975423 (2,679.60) OX000016375 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES EYNSHAM MEDICAL CENTRE 13975424 82,659.53 OX000016376 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING EYNSHAM MEDICAL CENTRE 13975424 18,166.58 OX000016376 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES EYNSHAM MEDICAL CENTRE 13975424 2,679.60 OX000016376 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES GORING & WOODCOTE MEDICAL PRACTICE 13975427 (47,654.25) 879063483 OX000016381 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING GORING & WOODCOTE MEDICAL PRACTICE 13975427 (4,267.20) 879063483 OX000016381 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES GORING & WOODCOTE MEDICAL PRACTICE 13975428 89,204.19 879063483 OX000016382 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING GORING & WOODCOTE MEDICAL PRACTICE 13975428 17,780.17 879063483 OX000016382 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES GORING & WOODCOTE MEDICAL PRACTICE 13975428 4,267.20 879063483 OX000016382 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Prescribing LOCAL ENHANCED SERVICES HORSEFAIR SURGERY 13975432 25,242.92 OX000016386 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Prescribing PRC DELEGATED CO-COMMISSIONING HORSEFAIR SURGERY 13975432 387.52 OX000016386 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES MARCHAM ROAD HEALTH CENTRE 13975440 (36,364.56) OX000016394 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13975440 (3,444.00) OX000016394 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES MARCHAM ROAD HEALTH CENTRE 13975441 67,803.75 OX000016395 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING MARCHAM ROAD HEALTH CENTRE 13975441 13,429.68 OX000016395 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES MARCHAM ROAD HEALTH CENTRE 13975441 3,444.00 OX000016395 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES MORLAND HOUSE SURGERY 13975443 (58,693.32) OX000016397 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13975443 (3,922.80) OX000016397 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES MORLAND HOUSE SURGERY 13975444 101,287.76 OX000016398 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING MORLAND HOUSE SURGERY 13975444 18,308.12 OX000016398 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES MORLAND HOUSE SURGERY 13975444 3,922.80 OX000016398 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES NETTLEBED SURGERY 13975447 (26,055.24) OX000016401 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13975447 (2,024.40) OX000016401 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES NETTLEBED SURGERY 13975448 49,893.67 OX000016402 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING NETTLEBED SURGERY 13975448 10,295.58 OX000016402 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES NETTLEBED SURGERY 13975448 2,024.40 OX000016402 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES SONNING COMMON HEALTH CENTRE 13975453 32,117.21 OX000016407 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING SONNING COMMON HEALTH CENTRE 13975453 5,265.35 OX000016407 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES SONNING COMMON HEALTH CENTRE 13975453 1,948.80 OX000016407 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES SHEEP STREET SURGERY BURFORD 13975456 41,613.88 OX000016410 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING SHEEP STREET SURGERY BURFORD 13975456 7,336.79 OX000016410 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES SHEEP STREET SURGERY BURFORD 13975456 1,638.00 OX000016410 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES SIBFORD SURGERY 13975458 27,738.66 GB879117988 OX000016412 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING SIBFORD SURGERY 13975458 5,795.54 GB879117988 OX000016412 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES SIBFORD SURGERY 13975458 1,596.00 GB879117988 OX000016412 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES VICTORIA HOUSE SURGERY 13975463 20,772.40 OX000016417 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING VICTORIA HOUSE SURGERY 13975463 3,450.82 OX000016417 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES VICTORIA HOUSE SURGERY 13975463 1,066.20 OX000016417 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WHITE HORSE MEDICAL CENTRE 13975465 (74,851.08) OX000016419 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING WHITE HORSE MEDICAL CENTRE 13975465 (4,410.00) OX000016419 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WHITE HORSE MEDICAL CENTRE 13975466 113,603.31 OX000016420 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING WHITE HORSE MEDICAL CENTRE 13975466 25,699.73 OX000016420 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES WHITE HORSE MEDICAL CENTRE 13975466 4,410.00 OX000016420 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WALLINGFORD MEDICAL PRACTICE 13975467 (22,847.34) OX000016421 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING WALLINGFORD MEDICAL PRACTICE 13975467 (2,931.60) OX000016421 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WALLINGFORD MEDICAL PRACTICE 13975468 42,877.33 OX000016422 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING WALLINGFORD MEDICAL PRACTICE 13975468 8,027.01 OX000016422 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES WALLINGFORD MEDICAL PRACTICE 13975468 2,931.60 OX000016422 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WATERY LANE SURGERY 13975469 (23,477.05) OX000016423 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING WATERY LANE SURGERY 13975469 (1,881.60) OX000016423 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WATERY LANE SURGERY 13975470 39,794.45 OX000016424 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING WATERY LANE SURGERY 13975470 8,369.67 OX000016424 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES WATERY LANE SURGERY 13975470 1,881.60 OX000016424 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WYCHWOOD SURGERY 13975475 33,871.36 OX000016429 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING WYCHWOOD SURGERY 13975475 6,494.47 OX000016429 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES WYCHWOOD SURGERY 13975475 1,789.20 OX000016429 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WINDRUSH MEDICAL PRACTICE WITNEY 13975476 (33,922.56) OX000016430 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING WINDRUSH MEDICAL PRACTICE WITNEY 13975476 (2,091.60) OX000016430 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WINDRUSH MEDICAL PRACTICE WITNEY 13975477 57,347.87 OX000016431 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING WINDRUSH MEDICAL PRACTICE WITNEY 13975477 14,383.08 OX000016431 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES WINDRUSH MEDICAL PRACTICE WITNEY 13975477 2,091.60 OX000016431 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES CHIPPING NORTON HEALTH CENTRE 13975480 (83,552.22) GB186693943 OX000016434 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13975480 (5,947.20) GB186693943 OX000016434 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES CHIPPING NORTON HEALTH CENTRE 13975481 126,148.10 GB186693943 OX000016435 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING CHIPPING NORTON HEALTH CENTRE 13975481 28,116.36 GB186693943 OX000016435 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES CHIPPING NORTON HEALTH CENTRE 13975481 5,947.20 GB186693943 OX000016435 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Prem Notional Rent PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13975483 39,250.00 NO INVOICE Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Prem Rates PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13975483 5,174.00 NO INVOICE Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-PMS Prof fees Dispensing PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13975483 21,771.00 NO INVOICE Department of Health NHS Oxfordshire CCG 31/08/2016 Recharge : Received PRC DELEGATED CO-COMMISSIONING COKER CLOSE HEALTH CENTRE 13975483 (16,500.00) NO INVOICE Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BLOXHAM & HOOK NORTON SURGERIES 13976416 (48,704.80) GB 879120308 OX000016379 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscChrgsCll&RmttdbyGPCntra PRC DELEGATED CO-COMMISSIONING BLOXHAM & HOOK NORTON SURGERIES 13976416 (4,275.60) GB 879120308 OX000016379 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BLOXHAM & HOOK NORTON SURGERIES 13976417 81,722.61 GB 879120308 OX000016380 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prof Fees Dispensing PRC DELEGATED CO-COMMISSIONING BLOXHAM & HOOK NORTON SURGERIES 13976417 17,975.34 GB 879120308 OX000016380 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES BLOXHAM & HOOK NORTON SURGERIES 13976417 4,275.60 GB 879120308 OX000016380 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 13988122 53,729.00 GB654935896 A0099859 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS OXFORD UNIVERSITY HOSPITALS NHS TRUST 14000477 83,097.76 8229299 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS OXFORD UNIVERSITY HOSPITALS NHS TRUST 14000484 37,286.50 8231584 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS OXFORD UNIVERSITY HOSPITALS NHS TRUST 14000485 (128,178.29) CRN4229 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS OXFORD UNIVERSITY HOSPITALS NHS TRUST 14000502 69,983.18 8233756 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS OXFORD UNIVERSITY HOSPITALS NHS TRUST 14000505 56,262.93 8233887 Department of Health NHS Oxfordshire CCG 31/08/2016 Other Research Exp ACUTE COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 14000533 71,396.57 GB654935896 A0099388 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS OXFORD UNIVERSITY HOSPITALS NHS TRUST 14000535 27,108.74 8235216 Department of Health NHS Oxfordshire CCG 31/08/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS OXFORD UNIVERSITY HOSPITALS NHS TRUST 14000551 178,445.87 8235402 Department of Health NHS Oxfordshire CCG 31/08/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING BERKSHIRE INDEPENDENT HOSPITAL 14000567 47,953.92 OXOND0816 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Actual Rent PRC DELEGATED CO-COMMISSIONING VICTORIA HOUSE SURGERY 14008723 36,341.75 Qtr2 Rent 2016 K84073 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Actual Rent PRC DELEGATED CO-COMMISSIONING WEST BAR SURGERY 14008724 83,250.00 Qtr2 Rent 2016 K84028 Department of Health NHS Oxfordshire CCG 31/08/2016 C&M-GMS Prem Actual Rent PRC DELEGATED CO-COMMISSIONING DR A MURPHY & PARTNERS 14008725 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Leeds City Council, Highways & Transportation, Transport Policy Transport Strategy, 8th Floor East, Merrion House, 110 Merrion Centre, Leeds, LS2 8BB Tel 0113 378 7529 Email: jean.siakeu@leeds.gov.uk Jean Siakeu (Senior Road Accident Analyst) ## Reported Road Casualties In 2017 Report To Senior Management Team (Smt) Date: 09 July 2018 ## Executive Summary - Calderdale District Rtc Statistics Of 2017 The overall reduction in the number of casualties of all severities and KSI in Calderdale is reflected in all road user categories; a slight increase in motorbike rider KSI casualties has, however, tarnished the overall performance in 2017. Cyclist injuries have decreased for the third consecutive year, but the 2017 total remains above the baseline. Child casualties have reduced slightly in 2017 after remaining unchanged in the last three years. Numbers of people KSI in 2017 is in line with the ideal trajectory toward meeting the 2026 target. ## Table Of Contents Contents | Calderdale District in 2017: At a glance ________________________________________________________________ 1 | | |---------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------| | Calderdale District Summaries _________________________________________________________________________ 2 | | | Killed or Seriously Injured (KSI) Casualties | ____________________________________________________________ 4 | | Child (0-15years) Casualties ____________________________________________________________________________ 5 | | | Pedestrian Casualties ____________________________________________________________________________________ 6 | | | Contact Information _____________________________________________________________________________________ 7 | | | | | ## Calderdale District In 2017: At A Glance Calderdale KSI in 2017  Fewer casualties of both all severities and for people KSI % share from road traffic collisions in Calderdale. 35%   After remaining static over the last three years, the number -37.1% 22 % share of children injured fell slightly. The reduction of the number 24% of children KSI is not impressive.  -25.0% 15  Pedestrian casualties have risen consistently since 2013, % share and it is pleasing to report the reduction in 2017. 24%  36.4% 15  The number of cyclist casualties has fallen marginally this % share year, confirming the slow and persistent reduction that 13%  started in 2013. 0.0% 8 % share  Powered two-wheeler (PTW) rider casualties continue to 5% Other  decrease in Calderdale. However, more were KSI in 2017 -25.0% 3 compared to last year.  The number of car occupants KSI fell 37% from 35 to 22,  -19.2% 63 while the number of all casualties fell by 15% from 338 to 287. All Casualties (January-December) Road to target* Calderdale 2017 vs last 2017 vs TP TP Reduc. 2017 vs Avg of last Severities 2005~09 year Baseline avg 2012 2013 2014 2015 2016 2017 Trend pattern 2012-2017 2017 2026 Req 3 years KSI 111.8 96 90 99 92 78 63 -19.2%  -43.6%  89.7 -29.7%  76 56 -11.1% All All severities 875.2 616 566 623 556 555 450 -18.9%  -48.6%  578 -22.1%  KSI 15.6 13 8 10 11 8 7 -12.5%  -55.1%  9.7 -27.6%  13 8 14.3% Child All severities 92.4 78 59 66 66 66 60 -9.1%  -35.1%  66.0 -9.1%  KSI 27.4 25 13 28 28 20 15 -25.0%  -45.3%  25.3 -40.8%  18 14 -6.7% Pedestrian All severities 109 94 76 97 102 104 79 -24.0%  -27.5%  101.0 -21.8%  KSI 10 12 14 13 11 8 8 0.0%  -20.0%  10.7 -25.0%  9 5 -37.5% Cyclist All severities 32.8 44 49 46 44 40 38 -5.0%  15.9%  43.3 -12.3%  KSI 24.2 19 24 16 13 11 15 36.4%  -38.0%  13.3 12.5%  17 12 -20.0% PTW All severities 74.8 54 50 51 51 39 33 -15.4%  -55.9%  47.0 -29.8%  KSI 46.8 39 36 39 36 35 22 -37.1%  -53.0%  36.7 -40.0%  30 23 4.5% Car Occupant All severities 621.2 397 361 401 335 338 287 -15.1%  -53.8%  358 -19.8%  * Road to target- Reduc. Req.: reduction required from the current year to meet the 2026 target ## Calderdale District Summaries FATAL CASUALTIES The number of deaths from road traffic collisions has been increasing consistently in the last five years, and so it is pleasing to report the first reduction since 2012. This year, three road users (two pedestrians and one motorbike rider) were killed in road traffic collisions. Nine fatalities were recorded in 2016. No children or cyclists were killed in Calderdale in 2017. KILLED OR SERIOUSLY INJURED (KSI) CASUALTIES The number of road users killed or seriously injured has decreased for the third consecutive year. In 2017, a total of 63 road users (seven children, five of whom were pedestrians) were killed or seriously injured in Calderdale; this is a reduction by 19% on last year's total of 78. This result is sustained by the combined reduction of fatal and serious injuries, which fell by three and six respectively. Those KSI in Calderdale were 22 (35%) car occupants (15 drivers and seven passengers, including one child), 15 (24%) pedestrians (five children), 15 (24%) motorcycle riders and eight (13%) cyclists. CASUALTIES OF ALL SEVERITIES In 2017, the number of casualties (450) of all severities from collisions reported to the police has improved last year's total (555) by 19%. The overall reduction is sustained by the reduction observed in other road user groups. CHILD (0-15 YEARS) CASUALTIES After falling by 24% from xx to 59 in 2013, child casualties of all severities in Calderdale have risen by 12% to 66 in 2014 and have not changed in 2015 (66) and 2016 (66). The slight reduction in 2017 (60) has not affected the trend of the most recent five years, which is fairly flat. The increased number of child pedestrians (up by eight to 32) injured has countered the reduction among car passengers (down by 13 to 19) and reduced the magnitude of the overall reduction in child casualties. There haven't been any child fatalities in Calderdale since 2012; KSI figures are serious injuries only, and have decreased this year by only one to a total of seven. CYCLIST CASUALTIES Since 2013, the number of cyclists injured in the district has fallen, and this continued in 2017. In 2016, 40 riders were injured, down by four from the 44 recorded in 2015. Despite the reduction observed in recent years, cyclist casualties in 2017 remain 22% above the baseline, but compare ## Executive Summary - Calderdale District favorably against the average of the three previous years. Two cyclists were killed in the district (none since 2013), but numbers of cyclists KSI in 2017 (8) are the lowest of the recent five years. PEDESTRIAN INJURIES It is pleasing to report the first reduction in the number of pedestrian injuries since 2013 (when the number of pedestrians (76) declined by 19% from the previous year (94), mostly adults). A total of 79 pedestrian injuries were recorded in 2017, against 104 in 2016. The reduction is explained by the number of adults injured, which fell 41% from 80 to 47 in 2017. By comparison, child pedestrian casualties have increased in 2017. Pedestrian KSI casualties fell for the second year in row, and the total of 15 reported in 2017 is the lowest ever for the district. MOTORBIKE RIDER CASUALTIES In 2017 - and for the second year in a row - fewer motorbike riders injuries (33) were reported in Calderdale compared to the previous year (39). The slight reduction is welcomed, as injuries to motorbike riders have been static around 50 in the five years prior to 2016. One bike rider was killed and further 31 (including a pillion) sustained serious injuries in 2017. The total number of riders KSI has risen from 11 in 2016 to 15 in 2017; it is now 13% above the average of the last three years. CAR OCCUPANT CASUALTIES Car occupant casualties, which represent 64% of all casualties in Calderdale, continue to decrease. A total of 287 car users were injured in 2017 against 338 last year (-15%). This places the district 53% below the baseline and 40% below the average of the last three years, confirming the long term trend in car casualties, which remains firmly downward. ## All Collisions The number of road traffic collisions has fallen by 70 from 407 in 2016 to 337 this year (-17%). Three collisions resulted in death, while 55 (57 in 2016) incurred serious injuries; last year there were 342 slight injuries; in 2017, there were 279. ## Killed Or Seriously Injured (Ksi) Casualties Reduction 2017 vs prev 2017 vs Calderdale Baseline* required from (avg 05~09) 2014 2015 2016 Prev 3yrs avg 2017 Target by 3yrs avg baseline 2026* the current year Fatal 10 6 6 9 7 3 -57%  -70%  5 Target Hit Serious 102 93 86 69 83 60 -27%  -41%  51 -15% Slight 763 524 465 477 489 387 -21%  -49%  Total 875 623 557 555 578 450 -22%  -49%  KSI 112 99 92 78 90 63 -30%  -44%  56 -11% Child KSI 16 10 11 8 10 7 -28%  -55%  8 Target Hit Pedestrian KSI 27 28 28 20 25 15 -41%  -45%  14 -9% Cyclist KSI 10 13 11 8 11 8 -25%  -20%  5 -38% PTW KSI 24 16 13 11 13 15 13%  -38%  12 -19% Car Occ KSI 47 39 36 35 37 22 -40.0%  -53.2%  24 Target Hit Other KSI 3 3 4 4 4 3 -18.2%  -11.8%  2 -43% * Reduction in KSI casualties by 50% over 2005-09 average The overall KSI reduction is sustained by the decreased in serious injuries among all the road user categories, with the exception of motor bike riders (KSI in this group is up 13% to 15). This year's KSI total places the district in line with the best trajectory towards 2026 target. If this trend is maintained, Calderdale will be in a strong position to meet the target. ## Executive Summary - Calderdale District Child (0-15Years) Casualties | Baseline | Previous 3 | 2017 change over | Previous 3 year av | All Children KSI in | |---------------------|--------------------|---------------------|-----------------------|------------------------| | Calderdale | (avg 05~09) | years av. | | | | 2017 | | | | | | 2017 change | | | | | | over 2005~09 | previous 3 year av | change over 2005~09 | | | | Pedestrian | 10 | 7 | 5 | -50% | | Pedal cyclist | 3 | 1 | 0 | -100% | | Car occupants | 2 | 1 | 1 | -50% | | Others | 1 | 0 | 1 | 0% | | Boys | 11 | 7 | 4 | -64% | | Girls | 5 | 3 | 3 | -40% | | Age 0 to 4 | 2 | 3 | 1 | -50% | | Age 5 to 15 | 14 | 7 | 6 | -57% | | All children (0-15) | 16 | 10 | 7 | -56% | The children aged over 5 are most at risk in Calderdale, and more boys are involved in road collisions. Pedestrian casualties are the largest proportion of child casualties in general and of children KSI (shown on the graph above) in particular. This proportion has not changed over the last decade. Acting on reducing the number of pedestrian casualties will certainly help to reduce child casualties and meet the 2026 target. ## Executive Summary - Calderdale District Pedestrian Casualties | All Pedestrian KSI | Baseline | Previous 3 | 2017 change over | Previous 3 year av | |-----------------------|--------------------|---------------------|---------------------|-----------------------| | in Calderdale | (avg 05~09) | year av. | | | | 2017 | | | | | | 2017 change | | | | | | over 2005~09 | previous 3 year av | change over 2005~09 | | | | Age 0 to 4 | 2 | 2 | 1 | -50% | | Age 5 to 15 | 8 | 5 | 4 | -50% | | All child (0 to 15) | 10 | 7 | 5 | -50% | | Age 16 to 19 | 2 | 1 | 0 | -100% | | Age 20 to 29 | 2 | 3 | 2 | 0% | | Age 30 to 59 | 6 | 7 | 4 | -33% | | Age 60 plus | 7 | 7 | 4 | -43% | | All pedestrian | 27 | 25 | 15 | -44% | Among child pedestrians, those over five are most at risk of road traffic collision; it is pleasing to note that the overall numbers of children injured have been decreasing since 2005. Among adults, those aged over 20 are most at risk and there has been no significant improvement recorded in that age group since 2005. Serious injuries among older adults is still an issue in the district. ## End Papers Calderdale District Tabulations Accidents, Casualties, road user group totals End table 1 All casualties by age groups End table 2 Pedestrian casualties by age groups End table 3 Pedal cycle casualties by age groups End table 4 Motor cycle Rider + Pillion casualties by age groups End table 5 Car driver casualties by age groups End table 6 Car passenger casualties by age groups End table 7 Goods occupant casualties by age groups End table 8 Bus occupant casualties by age groups End table 9 Long Term Comparisons End table 10 If a particular tabulation is required that is not presented in this report, please contact: Email: accident.studies@leeds.gov.uk ## Calderdale Accidents 2012 2013 2014 2015 2016 Average 0 Fatal 2 4 5 6 8 5 3 Serious 83 76 85 73 57 75 55 Slight 359 329 337 332 342 340 279 Total 444 409 427 411 407 420 337 Casualties 2012 2013 2014 2015 2016 Average 0 Fatal 2 4 6 6 9 5 3 Serious 94 86 93 86 69 86 60 Slight 520 476 524 465 477 492 387 Total 616 566 623 557 555 583 450 Road User Groups 2012 2013 2014 2015 2016 Average 0 Pedestrian 94 76 97 102 104 95 79 Pedal Cyclist 44 49 46 44 40 45 38 PTW Rider + Pillion 54 50 51 51 39 49 33 Car Driver 250 233 238 224 215 232 197 Car Passenger 147 128 163 112 123 134 90 Goods occupant 16 18 18 14 21 17 10 Bus occupant 10 9 9 4 10 8 3 Other 1 3 3 6 3 4 0 Total 616 566 623 557 555 583 450 * * The figures in the Average column of the following tables do not always sum to the total, due to rounding. ## Wy End Table 1 All Casualties Age Groups All ages 0 - 4 5 - 15 16 - 19 20 - 29 30 - 59 60+ Fatal 0 0 0 0 1 1 2 2012 Serious 1 12 15 19 33 14 94 Slight 9 56 53 117 223 62 520 Total 10 68 68 136 257 77 616 Fatal 0 0 0 1 2 1 4 2013 Serious 1 7 12 25 33 8 86 Slight 13 38 41 122 216 46 476 Total 14 45 53 148 251 55 566 Fatal 0 0 2 2 1 1 6 2014 Serious 3 7 10 15 42 16 93 Slight 4 52 50 137 219 62 524 Total 7 59 62 154 262 79 623 Fatal 0 0 1 0 4 1 6 2015 Serious 3 8 11 15 33 16 86 Slight 7 48 46 115 200 49 465 Total 10 56 58 130 237 66 557 Fatal 0 0 1 3 4 1 9 2016 Serious 2 6 3 25 20 13 69 Slight 9 49 32 112 212 63 477 Total 11 55 36 140 236 77 555 Fatal 0 0 1 1 2 1 5 Average Serious 2 8 10 20 32 13 86 Slight 8 49 44 121 214 56 492 Total 10 57 55 142 248 70 583 Fatal 0 0 0 0 3 0 3 0 Serious 1 6 6 15 19 13 60 Slight 3 50 26 83 156 69 387 Total 4 56 32 98 178 82 450 Calderdale Pedestrian Casualties Age Groups All ages 0 - 4 5 - 15 16 - 19 20 - 29 30 - 59 60+ Fatal 0 0 0 0 0 0 0 2012 Serious 1 9 3 2 4 6 25 Slight 1 25 6 6 19 12 69 Total 2 34 9 8 23 18 94 Fatal 0 0 0 0 0 0 0 2013 Serious 0 4 1 3 3 2 13 Slight 7 17 3 13 13 10 63 Total 7 21 4 16 16 12 76 Fatal 0 0 0 0 0 1 1 2014 Serious 3 5 3 1 7 8 27 Slight 2 23 6 3 23 12 69 Total 5 28 9 4 30 21 97 Fatal 0 0 0 0 3 0 3 2015 Serious 2 8 0 3 7 5 25 Slight 0 20 10 9 17 18 74 Total 2 28 10 12 27 23 102 Fatal 0 0 0 0 0 0 0 2016 Serious 1 3 0 6 4 6 20 Slight 5 15 4 15 29 16 84 Total 6 18 4 21 33 22 104 Fatal 0 0 0 0 1 0 1 Average Serious 1 6 1 3 5 5 22 Slight 3 20 6 9 20 14 72 Total 4 26 7 12 26 19 95 Fatal 0 0 0 0 2 0 2 0 Serious 1 4 0 2 2 4 13 Slight 2 25 3 6 16 12 64 Total 3 29 3 8 20 16 79 Calderdale Pedal Cycle Casualties Age Groups All ages 0 - 4 5 - 15 16 - 19 20 - 29 30 - 59 60+ Fatal 0 0 0 0 0 1 1 2012 Serious 0 2 1 0 8 0 11 Slight 0 8 1 3 18 2 32 Total 0 10 2 3 26 3 44 Fatal 0 0 0 0 0 0 0 2013 Serious 0 1 1 2 9 1 14 Slight 0 6 1 8 20 0 35 Total 0 7 2 10 29 1 49 Fatal 0 0 0 0 0 0 0 2014 Serious 0 1 0 1 9 2 13 Slight 0 3 1 8 18 3 33 Total 0 4 1 9 27 5 46 Fatal 0 0 0 0 0 0 0 2015 Serious 0 0 2 1 7 1 11 Slight 0 7 7 6 11 2 33 Total 0 7 9 7 18 3 44 Fatal 0 0 0 0 2 0 2 2016 Serious 0 2 0 0 3 1 6 Slight 0 4 0 5 21 2 32 Total 0 6 0 5 26 3 40 Fatal 0 0 0 0 0 0 1 Average Serious 0 1 1 1 7 1 11 Slight 0 6 2 6 18 2 33 Total 0 7 3 7 25 3 45 Fatal 0 0 0 0 0 0 0 0 Serious 0 0 1 2 4 1 8 Slight 0 7 2 5 15 1 30 Total 0 7 3 7 19 2 38 | Calderdale | | | | | | | PTW Rider + Pillion Casualties | |-----------------|---------|-------------------------|-----|-----|-----|-----|-----------------------------------| | | | | | | | | | | | | | | | | | | | Age Groups | | | | | | | | | | | | | | | | | | | | | | | | | | | All | | | | | | | | | ages | | | | | | | | | | | | | | | | | | 0 - 4 | 5 - 15 | 16 - 19 20 - 29 30 - 59 | 60+ | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | 2012 | Serious | 0 | 0 | 3 | 5 | 10 | 1 | | | | | | | | | | | Slight | 0 | 0 | 11 | 7 | 16 | 1 | 35 | | | | | | | | | | | Total | 0 | 0 | 14 | 12 | 26 | 2 | 54 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 2 | 0 | 2 | | 2013 | Serious | 0 | 0 | 6 | 5 | 9 | 2 | | | | | | | | | | | Slight | 0 | 0 | 7 | 9 | 9 | 1 | 26 | | | | | | | | | | | Total | 0 | 0 | 13 | 14 | 20 | 3 | 50 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | 2014 | Serious | 0 | 0 | 2 | 6 | 7 | 1 | | | | | | | | | | | Slight | 0 | 0 | 10 | 8 | 17 | 0 | 35 | | | | | | | | | | | Total | 0 | 0 | 12 | 14 | 24 | 1 | 51 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | 2015 | Serious | 0 | 0 | 3 | 5 | 5 | 0 | | | | | | | | | | | Slight | 0 | 0 | 8 | 10 | 18 | 2 | 38 | | | | | | | | | | | Total | 0 | 0 | 11 | 15 | 23 | 2 | 51 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 1 | 1 | 0 | 2 | | 2016 | Serious | 0 | 0 | 0 | 4 | 3 | 2 | | | | | | | | | | | Slight | 0 | 2 | 5 | 7 | 12 | 2 | 28 | | | | | | | | | | | Total | 0 | 2 | 5 | 12 | 16 | 4 | 39 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 1 | 0 | | Average Serious | 0 | 0 | 3 | 5 | 7 | 1 | 16 | | | Slight | 0 | 0 | 8 | 8 | 14 | 1 | | | Total | 0 | 0 | 11 | 13 | 22 | 2 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 1 | 0 | 1 | | 0 | Serious | 0 | 1 | 3 | 4 | 6 | 0 | | | | | | | | | | | Slight | 0 | 0 | 3 | 6 | 7 | 2 | 18 | | | | | | | | | | | Total | 0 | 1 | 6 | 10 | 14 | 2 | 33 | Calderdale Car Driver Casualties Age Groups All ages 0 - 4 5 - 15 16 - 19 20 - 29 30 - 59 60+ Fatal 0 0 0 0 1 0 1 2012 Serious 0 0 2 5 9 4 20 Slight 0 0 13 67 122 27 229 Total 0 0 15 72 132 31 250 Fatal 0 0 0 0 0 1 1 2013 Serious 0 0 2 7 8 1 18 Slight 0 1 8 51 135 19 214 Total 0 1 10 58 143 21 233 Fatal 0 0 0 2 1 0 3 2014 Serious 0 0 2 5 10 3 20 Slight 0 0 15 68 104 28 215 Total 0 0 17 75 115 31 238 Fatal 0 0 0 0 0 1 1 2015 Serious 0 0 2 4 8 8 22 Slight 0 0 6 56 124 15 201 Total 0 0 8 60 132 24 224 Fatal 0 0 1 1 1 1 4 2016 Serious 0 0 1 4 7 2 14 Slight 0 0 9 52 110 26 197 Total 0 0 11 57 118 29 215 Fatal 0 0 0 1 1 1 2 Average Serious 0 0 2 5 8 4 19 Slight 0 0 10 59 119 23 211 Total 0 0 12 65 128 28 232 Fatal 0 0 0 0 0 0 0 0 Serious 0 0 0 4 5 6 15 Slight 0 0 10 44 96 32 182 Total 0 0 10 48 101 38 197 ## Car Passenger Casualties Age Groups All ages 0 - 4 5 - 15 16 - 19 20 - 29 30 - 59 60+ Fatal 0 0 0 0 0 0 0 2012 Serious 0 1 6 7 2 2 18 Slight 8 22 17 33 37 12 129 Total 8 23 23 40 39 14 147 Fatal 0 0 0 1 0 0 1 2013 Serious 1 2 2 5 4 2 16 Slight 6 14 21 36 28 6 111 Total 7 16 23 42 32 8 128 Fatal 0 0 2 0 0 0 2 2014 Serious 0 1 3 2 6 2 14 Slight 2 26 18 42 43 16 147 Total 2 27 23 44 49 18 163 Fatal 0 0 1 0 1 0 2 2015 Serious 0 0 4 2 4 1 11 Slight 6 18 15 30 23 7 99 Total 6 18 20 32 28 8 112 Fatal 0 0 0 1 0 0 1 2016 Serious 1 1 2 9 1 2 16 Slight 4 26 13 27 24 12 106 Total 5 27 15 37 25 14 123 Fatal 0 0 1 0 0 0 1 Average Serious 0 1 3 5 3 2 15 Slight 5 21 17 34 31 11 118 Total 5 22 21 39 34 13 134 Fatal 0 0 0 0 0 0 0 0 Serious 0 1 2 2 0 2 7 Slight 1 17 8 19 18 20 83 Total 1 18 10 21 18 22 90 Calderdale Goods Occupant Casualties Age Groups All ages 0 - 4 5 - 15 16 - 19 20 - 29 30 - 59 60+ Fatal 0 0 0 0 0 0 0 2012 Serious 0 0 0 0 0 1 1 Slight 0 0 2 1 10 2 15 Total 0 0 2 1 10 3 16 Fatal 0 0 0 0 0 0 0 2013 Serious 0 0 0 3 0 0 3 Slight 0 0 1 2 10 2 15 Total 0 0 1 5 10 2 18 Fatal 0 0 0 0 0 0 0 2014 Serious 0 0 0 3 0 0 3 Slight 0 0 1 2 10 2 15 Total 0 0 1 5 10 2 18 Fatal 0 0 0 0 0 0 0 2015 Serious 0 0 0 0 1 1 2 Slight 0 2 0 2 5 3 12 Total 0 2 0 2 6 4 14 Fatal 0 0 0 0 0 0 0 2016 Serious 0 0 0 1 0 0 1 Slight 0 1 0 5 12 2 20 Total 0 1 0 6 12 2 21 Fatal 0 0 0 0 0 0 0 Average Serious 0 0 0 1 0 0 2 Slight 0 1 1 2 9 2 15 Total 0 1 1 3 9 2 17 Fatal 0 0 0 0 0 0 0 0 Serious 0 0 0 1 2 0 3 Slight 0 1 0 3 3 0 7 Total 0 1 0 4 5 0 10 | Calderdale | | | | | | | Bus Occupant Casualties | |-----------------|---------|-------------------------|-----|-----|-----|-----|----------------------------| | | | | | | | | | | | | | | | | | | | Age Groups | | | | | | | | | | | | | | | | | | | | | | | | | | | All | | | | | | | | | ages | | | | | | | | | | | | | | | | | | 0 - 4 | 5 - 15 | 16 - 19 20 - 29 30 - 59 | 60+ | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | 2012 | Serious | 0 | 0 | 0 | 0 | 0 | 0 | | | | | | | | | | | Slight | 0 | 1 | 3 | 0 | 1 | 5 | 10 | | | | | | | | | | | Total | 0 | 1 | 3 | 0 | 1 | 5 | 10 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | 2013 | Serious | 0 | 0 | 0 | 0 | 0 | 0 | | | | | | | | | | | Slight | 0 | 0 | 0 | 2 | 1 | 6 | 9 | | | | | | | | | | | Total | 0 | 0 | 0 | 2 | 1 | 6 | 9 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | 2014 | Serious | 0 | 0 | 0 | 0 | 0 | 0 | | | | | | | | | | | Slight | 0 | 0 | 0 | 2 | 1 | 6 | 9 | | | | | | | | | | | Total | 0 | 0 | 0 | 2 | 1 | 6 | 9 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | 2015 | Serious | 0 | 0 | 0 | 0 | 0 | 0 | | | | | | | | | | | Slight | 1 | 0 | 0 | 0 | 1 | 2 | 4 | | | | | | | | | | | Total | 1 | 0 | 0 | 0 | 1 | 2 | 4 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | 2016 | Serious | 0 | 0 | 0 | 1 | 1 | 0 | | | | | | | | | | | Slight | 0 | 1 | 1 | 0 | 3 | 3 | 8 | | | | | | | | | | | Total | 0 | 1 | 1 | 1 | 4 | 3 | 10 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | | Average Serious | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | | Slight | 0 | 0 | 1 | 1 | 1 | 4 | | | Total | 0 | 0 | 1 | 1 | 1 | 4 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Fatal | 0 | 0 | 0 | 0 | 0 | 0 | 0 | | 0 | Serious | 0 | 0 | 0 | 0 | 0 | 0 | | | | | | | | | | | Slight | 0 | 0 | 0 | 0 | 1 | 2 | 3 | | | | | | | | | | | Total | 0 | 0 | 0 | 0 | 1 | 2 | 3 | Calderdale Long Term Comparisons Accidents Year Killed Ser KSI Slight Total Pedestrians Pedal Cyclists PTW Car Car Car Goods Bus Others All Ages Child All Ages Child Users Drivers Pass Users Users Users 830 1981~85 21 236 257 825 1082 242 126 67 38 196 252 222 474 38 59 3 884 1994~98 11 112 123 1106 1229 194 90 64 30 60 511 301 812 38 56 4 398 2013~17 6 79 84 466 550 92 29 43 6 45 221 123 345 16 7 3 745 2002 11 111 122 990 1112 127 63 32 7 80 519 286 805 45 15 8 810 2003 4 106 110 1136 1246 150 61 44 15 78 563 328 891 45 31 7 811 2004 13 111 124 1079 1203 166 65 33 13 89 556 279 835 53 23 4 635 2005 7 104 111 842 953 107 37 41 15 79 461 203 664 32 25 5 609 2006 14 109 123 821 944 117 43 29 11 60 469 234 703 18 11 6 585 2007 10 90 100 760 860 103 42 32 9 63 379 245 624 23 13 2 547 2008 9 96 105 683 788 109 38 28 6 69 348 195 543 26 9 4 565 2009 9 111 120 711 831 109 43 34 9 74 365 207 572 17 17 8 477 2010 3 78 81 614 695 80 32 29 5 43 307 194 501 26 14 2 433 2011 7 83 90 555 645 89 45 44 11 57 270 143 413 24 15 3 444 2012 2 94 96 520 616 94 36 44 10 54 250 147 397 16 10 1 409 2013 4 86 90 476 566 76 28 49 7 50 233 128 361 18 9 3 427 2014 6 93 99 524 623 97 33 46 4 51 238 163 401 17 9 2 411 2015 6 86 92 465 557 102 30 44 7 51 224 112 336 14 4 6 407 2016 9 69 78 477 555 104 24 40 6 39 215 123 338 21 10 3 337 2017 3 60 63 387 450 79 32 38 7 33 197 90 287 10 3 0 ## Executive Summary - Calderdale District Contact Information Jean Siakeu Leeds City Council, Highways & Transportation, Transport Policy Transport Strategy, 8th Floor East, Merrion House, 110 Merrion Centre, Leeds, LS2 8BB Tel 0113 378 7529 Email: Jean.Siakeu@Leeds.Gov.Uk www.leeds.gov.uk
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## Child Sexual Exploitation Definition and a guide for practitioners, local leaders and decision makers working to protect children from child sexual exploitation February 2017 ## Contents | Introduction | 3 | |--------------------------------------------------------------------|-----| | | | | Section A - advice for all practitioners who work with children | 5 | | | | | What is child sexual exploitation? | 5 | | | | | Potential indicators of child sexual exploitation | 9 | | | | | How are children sexually exploited? | 9 | | | | | How does child sexual exploitation affect children? | 11 | | | | | How to respond: working with young people | 12 | | | | | What does the particular nature of exploitation mean for practice? | 13 | | | | | Section B - advice for managers and strategic leaders | 15 | | | | | The child sexual exploitation context | 16 | | | | | Prevention | 18 | | | | | Educating practitioners | 19 | | | | | Educating children and young people | 21 | | | | | Educating parents and carers | 21 | | | | | Educating communities | 22 | | | | | | | | | | ## Introduction Child sexual exploitation is a crime with devastating and long lasting consequences for its victims and their families. Childhoods and family life can be ruined and this is compounded when victims, or those at risk of abuse, do not receive appropriate, immediate and on-going support. The first response to children, and support for them to access help, must be the best it can be from social workers, police, health practitioners and others who work with children and their families. In *Putting Children First* (July 2016) the Government set out its ambitions to support vulnerable children to lead safe and positive lives, to become successful adults and to have the kind of happy childhood that we want for all our children. We want children and families to have confidence in turning to practitioners for help and protection from abuse, neglect and exploitation. This help and protection should be provided in a timely, enduring and flexible manner, and be the best it can possibly be. This requires children, parents and carers affected by child sexual exploitation to feel part of the solution and confident they will be believed. Practitioners should work together to reduce the immediate risk of harm to children and collaborate to develop long term strategies to improve children's life chances. This applies as much to child sexual exploitation as to other forms of abuse or neglect. The hidden nature of child sexual exploitation and the complexities involved means professional curiosity, and always being alert to the issue, is vital. ## About This Advice This advice is non-statutory, and has been produced to help practitioners, local leaders and decision makers who work with children and families to identify child sexual exploitation and take appropriate action in response. This includes the management, disruption and prosecution of perpetrators. This advice replaces the 2009 guidance Safeguarding children and young people from sexual exploitation. It should be read alongside *Working Together to Safeguard Children* (most recent updates available on gov.uk) which continues to provide statutory guidance covering the legislative requirements on services to safeguard and promote the welfare of children, including in relation to child sexual exploitation. A child is anyone who has not yet reached their 18th birthday. Throughout this advice the terms 'child' and 'children' are used to refer to all those under the age of 18. ## Who Is This Advice For? This advice is intended to help all those working with children, and their parents and carers, to understand child sexual exploitation and what action should be taken to identify and support victims. The online annexes to this document set out work to tackle perpetrators, another critical element of an holistic response. Section A is for everyone whose work brings them into contact with children and families, including those who work in early years, children's social care, health, education (including schools), the police, adult services and youth offending teams. This section sets out first the background to the nature of child sexual exploitation, followed by a series of guiding principles. It is relevant to those working in the statutory, voluntary or the independent sectors, and applies in relation to all children and young people irrespective of whether they are living at home with their families and carers or away from home. Section B is for those in strategic and management roles who are planning responses to child sexual exploitation within local authorities and other agencies working in partnership. It is relevant for Local Safeguarding Children Boards and any new arrangements required in legislation. However, all practitioners may find this information useful to support effective front-line practice on child sexual exploitation. This advice is not intended to be a 'step by step' approach to addressing child sexual exploitation. It sets out the definition of child sexual exploitation; highlights potential vulnerabilities and indicators of abuse; and sets out appropriate action to take in response, using professional judgment and curiosity. Although it focuses on child sexual exploitation, the principles outlined here are those set out in *Working Together* covering all forms of exploitation, abuse and vulnerability in childhood and adolescence. The signs of abuse rarely present in clear, unequivocal ways (The Munro Review of Child Protection, 2011). What is important is that those working with children and families understand the totality of a child's experience in order to assess the nature and level of risk faced by children and respond swiftly and proportionately. ## Section A - Advice For All Practitioners Who Work With Children What Is Child Sexual Exploitation? Child sexual exploitation is a form of child sexual abuse. Sexual abuse may involve physical contact, including assault by penetration (for example, rape or oral sex) or nonpenetrative acts such as masturbation, kissing, rubbing and touching outside clothing. It may include non-contact activities, such as involving children in the production of sexual images, forcing children to look at sexual images or watch sexual activities, encouraging children to behave in sexually inappropriate ways or grooming a child in preparation for abuse (including via the internet). The definition of child sexual exploitation is as follows: Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology. Like all forms of child sexual abuse, child sexual exploitation: - can affect any child or young person (male or female) under the age of 18 years, including 16 and 17 year olds who can legally consent to have sex; - can still be abuse even if the sexual activity appears consensual; - can include both contact (penetrative and non-penetrative acts) and non-contact sexual activity; - can take place in person or via technology, or a combination of both; - can involve force and/or enticement-based methods of compliance and may, or may not, be accompanied by violence or threats of violence; - may occur without the child or young person's immediate knowledge (through others copying videos or images they have created and posting on social media, for example); - can be perpetrated by individuals or groups, males or females, and children or adults. The abuse can be a one-off occurrence or a series of incidents over time, and range from opportunistic to complex organised abuse; and - is typified by some form of power imbalance in favour of those perpetrating the abuse. Whilst age may be the most obvious, this power imbalance can also be due to a range of other factors including gender, sexual identity, cognitive ability, physical strength, status, and access to economic or other resources. Child sexual exploitation is a complex form of abuse and it can be difficult for those working with children to identify and assess. The indicators for child sexual exploitation can sometimes be mistaken for 'normal adolescent behaviours'. It requires knowledge, skills, professional curiosity and an assessment which analyses the risk factors and personal circumstances of individual children to ensure that the signs and symptoms are interpreted correctly and appropriate support is given. Even where a young person is old enough to legally consent to sexual activity, the law states that consent is only valid where they make a choice and have the freedom and capacity to make that choice. If a child feels they have no other meaningful choice, are under the influence of harmful substances or fearful of what might happen if they don't comply (all of which are common features in cases of child sexual exploitation) consent cannot legally be given whatever the age of the child. ## Child Sexual Exploitation Is Never The Victim'S Fault, Even If There Is Some Form Of Exchange: All Children And Young People Under The Age Of 18 Have A Right To Be Safe And Should Be Protected From Harm. One of the key factors found in most cases of child sexual exploitation is the presence of some form of exchange (sexual activity in return for something); for the victim and/or perpetrator or facilitator. Where it is the victim who is offered, promised or given something they need or want, the exchange can include both tangible (such as money, drugs or alcohol) and intangible rewards (such as status, protection or perceived receipt of love or affection). It is critical to remember the unequal power dynamic within which this exchange occurs and to remember that the receipt of something by a child/young person does not make them any less of a victim. It is also important to note that the prevention of something negative can also fulfil the requirement for exchange, for example a child who engages in sexual activity to stop someone carrying out a threat to harm his/her family. Whilst there can be gifts or treats involved in other forms of sexual abuse (e.g a father who sexually abuses but also buys the child toys) it is most likely referred to as child sexual exploitation if the 'exchange', as the core dynamic at play, results in financial gain for or enhanced status of, the perpetrator. Where the gain is only for the perpetrator/facilitator, there is most likely a financial gain (money, discharge of a debt or free/discounted goods or services) or increased status as a result of the abuse. If sexual gratification, or exercise of power and control, is the only gain for the perpetrator (and there is no gain for the child/young person) this would not normally constitute child sexual exploitation, but should be responded to as a different form of child sexual abuse. ## How Common Is Child Sexual Exploitation? The signs and indicators of all forms of abuse can be difficult to detect and child sexual exploitation is no exception. A variety of factors can make it difficult to accurately assess how prevalent child sexual exploitation is. Many children who are sexually exploited may have been victims of other forms of abuse; the grooming methods that may be used can mean that children who are sexually exploited do not always recognise they are being abused, which can also affect detection rates. What is clear is that child sexual exploitation can occur in all communities and amongst all social groups and can affect girls and boys. All practitioners should work on the basis that it is happening in their area. ## Who Is Vulnerable To Child Sexual Exploitation? Any child, in any community: Child sexual exploitation is occurring across the country but is often hidden so prevalence data is hard to ascertain. However, areas proactively looking for child sexual exploitation are uncovering a problem. All practitioners should be open to the possibility that the children they work with might be affected. Age: Children aged 12-15 years of age are most at risk of child sexual exploitation although victims as young as 8 have been identified, particularly in relation to online concerns. Equally, those aged 16 or above can also experience child sexual exploitation, and it is important that such abuse is not overlooked due to assumed capacity to consent. Account should be taken of heightened risks amongst this age group, particularly those without adequate economic or systemic support. Gender: Though child sexual exploitation may be most frequently observed amongst young females, boys are also at risk. Practitioners should be alert to the fact that boys may be less likely than females to disclose experiences of child sexual exploitation and less likely to have these identified by others. Ethnicity: Child sexual exploitation affects all ethnic groups. Heightened vulnerability factors: *Working Together* makes clear the requirements for holistic assessment. Sexual exploitation is often linked to other issues in the life of a child or young person, or in the wider community context. Practitioners should be alert to the fact that child sexual exploitation is complex and rarely presents in isolation of other needs and risks of harm (although this may not always be the case, particularly in relation to online abuse). Child sexual exploitation may be linked to other crimes and practitioners should be mindful that a child who may present as being involved in criminal activity is actually being exploited. ## Practitioners Should Not Rely On 'Checklists' Alone But Should Make A Holistic Assessment Of Vulnerability, Examining Risk And Protective Factors As Set Out In The Statutory Guidance *Working Together.* Sexual exploitation can have links to other types of crime. These include: - Child trafficking; - Domestic abuse; - Sexual violence in intimate relationships; - Grooming (including online grooming); - Abusive images of children and their distribution; - Drugs-related offences; - Gang-related activity; - Immigration-related offences; and - Domestic servitude. The following vulnerabilities are examples of the types of things children can experience that might make them more susceptible to child sexual exploitation: - Having a prior experience of neglect, physical and/or sexual abuse; - Lack of a safe/stable home environment, now or in the past (domestic violence or parental substance misuse, mental health issues or criminality, for example); - Recent bereavement or loss; - Social isolation or social difficulties; - Absence of a safe environment to explore sexuality; - Economic vulnerability; - Homelessness or insecure accommodation status; - Connections with other children and young people who are being sexually exploited; - Family members or other connections involved in adult sex work; - Having a physical or learning disability; - Being in care (particularly those in residential care and those with interrupted care histories); and - Sexual identity. Not all children and young people with these vulnerabilities will experience child sexual exploitation. Child sexual exploitation can also occur without any of these vulnerabilities being present. ## Potential Indicators Of Child Sexual Exploitation Children rarely self-report child sexual exploitation so it is important that practitioners are aware of potential indicators of risk, including: - Acquisition of money, clothes, mobile phones etc without plausible explanation; - Gang-association and/or isolation from peers/social networks; - Exclusion or unexplained absences from school, college or work; - Leaving home/care without explanation and persistently going missing or returning late; - Excessive receipt of texts/phone calls; - Returning home under the influence of drugs/alcohol; - Inappropriate sexualised behaviour for age/sexually transmitted infections; - Evidence of/suspicions of physical or sexual assault; - Relationships with controlling or significantly older individuals or groups; - Multiple callers (unknown adults or peers); - Frequenting areas known for sex work; - Concerning use of internet or other social media; - Increasing secretiveness around behaviours; and - Self-harm or significant changes in emotional well-being. Practitioners should also remain open to the fact that child sexual exploitation can occur without any of these risk indicators being obviously present. Practitioners should also be alert to the fact that some risk assessments have been constructed around indicators of face-to-face perpetration by adults and may not adequately capture online or peerperpetrated forms of harm. It is also important to remember that risk assessments only capture risk at the point of assessment and that levels of risk vary over time, and that the presence of these indicators may be explained by other forms of vulnerability rather than child sexual exploitation. The first step for practitioners is to be alert to the potential signs of abuse and neglect and to understand the procedures set out by local multi-agency safeguarding arrangements. Those working with children and families should access training through those multi-agency arrangements to support them in identifying vulnerability, risk and harm. This will help practitioners to know what action to take and to develop a shared understanding about what best practice looks like. ## How Are Children Sexually Exploited? Child sexual exploitation takes many different forms. It can include contact and noncontact sexual activities and can occur online or in person, or a combination of each. The following illustrative examples, although very different in nature and potentially involving different sexual or other offences, could all fall under the definition of child sexual exploitation: - A 44 year old female posing as a 17 year old female online and persuading a 12 year old male to send her a sexual image, and then threatening to tell his parents if he doesn't continue to send more explicit images; - A 14 year old male giving a 17 year old male oral sex because the older male has threatened to tell his parents he is gay if he refuses; - A 14 year old female having sex with a 16 year old gang member and his two friends in return for the protection of the gang; - A 13 year old female offering and giving an adult male taxi driver sexual intercourse in return for a taxi fare home; - A 21 year old male persuading his 17 year old 'girlfriend' to have sex with his friends to pay off a drug debt; - A mother letting other adults abuse her 8 year old child in return for money; - A group of men bringing two 17 year old females to a hotel in another town and charging others to have sex with them; and - Three 15 year old females being taken to a house party and given 'free' alcohol and drugs, then made to have sex with six adult males to pay for this. ## These examples are not exhaustive: other forms of child sexual exploitation occur and new forms continue to develop. Nor are they mutually exclusive - some children will suffer abuse across a range of scenarios, either simultaneously or in succession. Most child abuse occurs within the home. In cases of child sexual exploitation the risk of harm is generally external or in the community. Child sexual exploitation may occur without the child being aware of events, or understanding that these constitute abuse. Online exploitation includes the exchange of sexual communication or images and can be particularly challenging to identify and respond to. Children, young people and perpetrators are frequently more familiar with, and spend more time in, these environments than their parents and carers. Those who work with and care for children can struggle to remain up-to-date with the latest sites and potential connection points, so practitioners should always seek specialist support if unsure about online environments. Online child sexual exploitation allows perpetrators to initiate contact with multiple potential victims and offers a perception of anonymity, with children and young people, and perpetrators, potentially saying and doing things online they wouldn't do offline. Where exploitation does occur online, the transfer of images can be quickly and easily shared with others. This makes it difficult to contain the potential for further abuse. ## Children Can Be Perpetrators As Well As Victims Children can be both experiencing child sexual exploitation and perpetrating it at the same time. Examples might include a child who is forced to take part in the exploitation of another child under duress, or a child who is forced to introduce other children to their abuser under threats to their family's safety. These situations require a nuanced approach that recognises and engages with the young person's perpetration within the context of their own victimisation. Children who perpetrate child sexual exploitation require a different response to adult perpetrators. Responses may involve criminal justice pathways at times, however every child who displays harmful sexual behaviour should also have their safeguarding and welfare needs actively considered in line with *Working Together*. Different agencies should work together to: (a) identify any prior victimisation and understand how this has contributed to the perpetration; and (b) map the environments and contexts in which peer-perpetrated child sexual exploitation occurs, looking at the social norms or power dynamics at play which may have influenced the perpetration of abuse. Dependent on the issues emerging, this will likely need both an individually-based response and wider work to address harmful social norms or power dynamics that enable the abuse to occur. ## How Does Child Sexual Exploitation Affect Children? The long-term consequences of any form of child abuse can be devastating and early identification and providing support as soon as problems emerge is critical. Child sexual exploitation damages children and like any form of abuse it can have longlasting consequences that can impact on every part of a child's life and their future outcomes. Child sexual exploitation has been shown to affect: - Physical (including sexual) and mental health and well-being; - Education and training and therefore future employment prospects; - Family relationships; - Friends and social relationships, current and as adults; and - Their relationship with their own children in the future. Child sexual exploitation is complex and children are often reluctant to disclose experiences of exploitation due to misplaced feelings of loyalty and shame. Many may not recognise what they are experiencing as abuse or that they require support or intervention, believing they are in control or in a healthy consensual relationship. Online annexes to this document set out in greater detail the context of adolescent development and risk. ## How To Respond: Working With Young People Child sexual exploitation is never the victim's fault: As stated above, all children and young people have a right to be safe and should be protected from harm. "What I want is staff who sit down and talk to you calmly and they don't judge you … you want someone to understand why you did what you did" "Instead of shouting at me and saying 'why did you do it?' …[They should be] letting you get your point across first, then putting their point across and about how they see it differently, instead of just saying that was wrong" (young person cited in Warrington 2013) Early sharing of information is key to providing effective help where there are emerging problems. As above, it is essential to have in place effective child protection services and procedures for sharing information. For guidance on sharing information, which includes a myth-busting guide, see *Information Sharing: Advice for practitioners* providing safeguarding services to children, young people, parents and carers. Wherever possible practitioners should share confidential personal information with consent. However, where there are concerns that a child is suffering, or is likely to suffer, significant harm, practitioners should be willing to disclose information without consent where the public interest served by protecting the child from harm outweighs the duty of confidentiality. Section B below sets out the framework that is required to support effective practice. Safeguarding children is everyone's responsibility. As above, all practitioners should assume that in the course of their work with children they will encounter children at risk of sexual exploitation. All practitioners working with children and families need to know where to get help: Local multi-agency safeguarding arrangements will set out the process for referring concerns about the welfare of children to local authority children's social care. Anyone can make a referral and ask for advice. If a child is considered to be in immediate danger the police should be contacted. Any practitioner working with a child who they think may be at risk of child sexual exploitation should follow the guidance set out in *Working Together* and share this information with local authority children's social care. You should refer any concerns about a child's welfare to local authority children's social care. If you believe a child is in immediate risk of harm, you should contact the police. Managers of services should ensure they are facilitating this type of sharing culture within their agencies and across their local multi-agency partnerships. - All practitioners working with children and families should respond in ways that are: - **Child-centred**: recognising children and young people's rights to participate in decisions about them in line with their maturity, and focusing on the needs of the child. Other considerations, such as the fear of damaging relationships with children or adults, get in the way of protecting children from abuse and neglect. Practitioners should view a referral as the beginning of a process of inquiry, not as an accusation. Victims may be resistant to intervention and some may maintain links with their abusers, even after attempts to help protect them; - Developed and informed by the involvement of a child's family and carers wherever safe and appropriate: a holistic assessment will take account of the wishes and feelings of children and the views of their parents/carers; - **Responsive and pro-active**: everyone should be alert to the potential signs and indicators of child sexual exploitation, as well as other forms of abuse, and exercise professional curiosity in their day to day work. It is better to help children and young people as early as possible, before issues escalate and become more damaging; - **Relationship-based:** practitioners should establish and maintain trusting relationships with children and young people, and continue to exercise professional curiosity and create safe spaces for disclosure; and - Informed by an understanding of the complexities of child sexual exploitation: it is important to avoid language or actions that may lead a young person to feel they are not deserving of support or are in some way to blame for their abuse. ## "All young people can be worked with. It's about finding the right worker..[and the professional] staying strong, staying tough and going along the roller-coaster ride with the young person…The worker needs to always be there to support you whenever you need it…It doesn't go away overnight. It takes time." (young person quoted in the consultation exercise for this advice, 2016) ## What Does The Particular Nature Of Exploitation Mean For Practice? It is important that continued contact is not misinterpreted as informed choice or an indication of absence of harm. Practitioners should maintain their relationships with children and young people, and continue to exercise professional curiosity and create safe spaces for disclosure. Continued contact with perpetrators should be seen as part of the complex power dynamic of the abusive relationship, similar to that in some situations of domestic abuse. Practitioners should continue to reach out to victims and not make the offer of services dependent on formal disclosure. Many victims are only able to disclose after the provision of support, often months or even years down the line. "I was throwing hints to people an all. I was throwing hints 'cause I didn't want it comin' out of my own mouth. I wanted people to work it out … I was getting myself drunk so I could come out with it, 'cause I couldn't say it when I was like sober. I was like 'I can't say it'" (young person cited in Beckett 2011) Parents/carers, teachers, youth workers, other professional workers or, as is often the case, a mixture of the above may have a valuable perspective to add. This will inform the contextual understanding and help to identify changes that represent something more than adolescent behaviours (see online annexes covering adolescent development) and make sense of the range of vulnerabilities the child or young person may be facing. As Working Together makes clear, it is important all such perspectives, alongside that of the child/young person, are incorporated in all risk assessments. ## Working With Families Parents and carers can feel excluded in work with children and young people who are, or who are at risk of being, sexually exploited by perpetrators external to the family. Where assessment shows it is safe and appropriate to do so, parents and families should be regarded as a part of the solution. It is crucial to work with them not only to assess the risks of harm faced by the young person or child but to help them understand what the young person has experienced, the risks they face and how they can be supported and protected. The parents may need direct support and help to improve family relationships and keep their child safe. ## Section B - Advice For Managers And Strategic Leaders Local authorities have overarching responsibility for safeguarding all children in their area. Their statutory functions under the 1989 and 2004 Children Act(s) include specific duties in relation to children in need and children suffering, or likely to suffer, significant harm (under sections 17 and 47 of the Children Act 1989). Local agencies, including the police and health services, also have a duty under section 11 of the Children Act 2004 to ensure they consider the need to safeguard and promote the welfare of children and young people when carrying out their functions. Under section 10 of the Children Act 2004, these agencies are required to cooperate with local authorities to promote the wellbeing of children and young people in each local authority area. Practitioners are responsible for ensuring they fulfil their role and responsibilities in a manner consistent with the statutory duties of their employer. ## An Effective Local Multi-Agency Plan To Combat Child Sexual Exploitation Requires Clear Leadership, Guidance And Support, Delivered According To The Overarching Working Together **Principles.** It Requires Contributions From All Multi-Agency Partners In Accordance With Local Multi-Agency Arrangements. The Effectiveness And Implementation Of Multi-Agency Plans And Arrangements To Tackle Child Sexual Exploitation Should Be Monitored By The Local Safeguarding Children Board Or Its Successor Body. This Should Include Ensuring Joint-Agency Training Is Available. Those planning an effective local multi-agency response to child sexual exploitation should follow the process for managing risk of harm to children and putting their needs first, as set out in *Working Together*. Specifically, an effective response is one that: - Is collaborative and multi-agency (including statutory, voluntary and community sectors) with clear roles and responsibilities and clear lines of communication and accountability; - Has clear and purposeful leadership across local safeguarding partners; - Is locally informed and based on an up-to-date understanding of the local problem profile, but also informed by national learning; - Is underpinned by effective information sharing and intelligence sharing. All multiagency partners should follow the guidance set out in *Working Together,* for example taking part in strategy discussion and child protection conferences; - Locates child sexual exploitation within a wider context of risk and harm, and moves beyond a case by case response to identify wider patterns of concern; - Encompasses preventative, protective (immediate safeguarding) and responsive approaches, focusing on both victims and perpetrators (and recognising the potential for overlap between the two); - Provides help and ongoing support that is responsive to individual need, strengths-based in approach and available over the longer-term (recognising that disclosure, resilience-building and recovery can take time); - Supports staff to 'work with risk,' where required, in order to support a young person to become an active partner in their recovery and reintegration and achieve longer term meaningful change rather than temporary enforced compliance; - Provides a response to children and young people with harmful sexual behaviours that recognises their vulnerabilities and needs, is holistic and provides early help and specialist services to these children and young people and their parents/carers; and - Provides a system for flagging or applying appropriate markers on to systems in order to ensure effective record keeping and retrieval and assist information sharing (this should be based on the policy definition of child sexual exploitation and not just the criminal offences of that name). ## The Child Sexual Exploitation Context - Viewing child sexual exploitation within a wider continuum of exploitation, violence and abuse: Child sexual exploitation is not a catch all category for all forms of sexual harm in adolescence. It should therefore be viewed within the wider continuum of sexual abuse and other relevant issues such as trafficking, modern slavery, domestic abuse and other gendered violence and going missing. The necessary focus on child sexual exploitation should not overshadow a focus on other manifestations of abuse. - **Abuse outside of families:** Though child sexual exploitation can occur in the family, in most cases the response to exploitation may require services to consider a broader perspective than intra-familial child abuse. The response may need to address risk of harm posed outside the family home and draw in partners such as local businesses, licensing authorities, and other sectors. This reflects the context in which perpetrators are operating. - **Agencies should move beyond a reactive approach:** (one that removes the individual from harm) to one that also addresses the existence of harm and/or proactively prevents that harm. - **Local understanding:** Every area should have its own data and intelligence, of which child sexual exploitation should form a part. Local multi-agency plans should be based on an inter-agency assessment of the local profile of perpetration. This requires effective local arrangements for sharing and collating intelligence and other information about communities, environments, perpetrators and victims. - **Engaging with diversity:** The evidence base demonstrates that some cohorts of children and young people - males, children with disabilities, Lesbian, Gay, Bisexual and/or Transgender and Black and Minority Ethnic children, for example - may be less likely to have their abuse identified or responded to. Local areas should ensure responses are accessible, relevant and sensitive to the needs of all children and young people. - **Cross-area working:** Cases of child sexual exploitation frequently cross local authority, police force and even country boundaries in terms of the movement of both perpetrators and victims. A singular area focus cannot therefore adequately capture patterns of harm and risk. - **Inter-agency working:** While significant progress has been made here, challenges remain. Important areas for improvement include: o the practical implementation of information sharing guidance; o common risk assessment processes, as set out in *Working Together*, that follow an evidence-based model which looks at risk factors, vulnerability, protective factors and resilience and which prioritises professional judgement and does not rely on simplistic scoring; o clarity about professional roles and thresholds for action across universal, targeted and specialist services; o more effective sharing and recording of intelligence; o better co-ordination of statutory and voluntary sector services; and o more streamlined management of multiple agencies' engagement with victims and their families. - Enhancing children's and young people's resilience and strengthening the protective factors around them are critical strands of prevention. Resilience is about being able to overcome adversities and avoid negative consequences. It is not a character trait; it involves both internal capabilities and external resources. Resilience is therefore never a substitute for support. - **Openness to learning and improvement**: There has been considerable learning in recent years around how better to identify and respond to child sexual exploitation. Sources of support and how to access learning in this area can be found in the online annexes. ## Prevention The harmful effects of child sexual exploitation are serious and far-reaching for victims, their families and wider communities. The ideal is therefore to prevent the abuse happening in the first place. This section focuses on how we can protect children and young people through awareness-raising and resilience-building work. A local multi-agency plan should: - Educate all children and young people about the nature and risks of child sexual exploitation and other forms of related harm (both online and offline) and how to access support; - Recognise that children and young people can be both victims and perpetrators of child sexual exploitation; - Promote the resilience of children and young people and their families and strengthen the protective factors around them; - Identify and support those settings, such as schools and colleges, in which children and young people can form healthy and safe relationships; - Supplement universal initiatives with targeted work with groups of particularly vulnerable children and young people, such as those in care, whilst being careful not to stigmatise specific groups; - Provide complementary messages to parents and carers about risks to their children (online and offline) and how to access support if they have concerns. - Consider the levels of knowledge and understanding of the wider workforce, so that everyone working with children and young people can play their role in prevention; and - Educate the wider community so they can identify and report concerns and seek support. Although messages and methods of delivery will vary according to the nature and needs of the audience, all education and awareness raising initiatives should: - Be grounded in an evidence-based understanding of child sexual exploitation (both online and offline); - Challenge myths and misconceptions about who is perpetrating and experiencing this form of abuse; - Send a clear message that all forms of child sexual exploitation are abuse; - Recognise the potential overlap between victims and perpetrators; - Challenge any victim-blaming and promote the rights of all victims to protection and support; - Provide information on where and how to report concerns and access support; and - Be inclusive and accessible to the intended audience, in terms of language and delivery methods and ensure information is tailored and relevant to diverse groups such as Lesbian, Gay, Bisexual, Transgender, Black and Minority Ethnic and/or deaf or disabled children and young people. ## Educating Practitioners - **Readiness of the professional workforce**: *Working Together* recognises that everyone who works with children has a responsibility for keeping them safe - that includes all those those who work in social care, adult services, education, health settings, early years, youth work, youth justice, the police, and voluntary and community workers. Local safeguarding arrangements should provide high-quality training and other learning and developmental activities that are rooted in evidence, tailored to different professional groups and responsive to local learning needs. - **Staff support and supervision**: Creating the right organisational environment and ensuring good quality professional leadership and practice supervision are essential for developing and sustaining effective practice. Supervision can help to: o ensure progress and actions are reviewed so cases do not 'drift'; o maintain focus on the child or young person; o test the evidence base for assessment and intervention; o address the emotional impact of the work on the practitioner; and o support reflective practice and help practitioners recognise where personal values and attitudes might be leading to risky practice, assumptions or 'blind spots'. All practitioners working with children and young people, whether in specialist or universal roles, should: - Ensure they are aware of local multi-agency protocols in relation to child sexual exploitation; - Recognise learning and development around this as an essential part of their role; - Discuss learning needs in relation to child sexual exploitation with their supervisor or manager; - Identify and access training opportunities that reflect their professional role (online annexes provides an overview of key messages that training should cover); - Reflect on learning from training and other activity with their manager, and consider how it will impact on practice; - Review their learning needs over time, striving to continuously improve their knowledge, skills and understanding; and - Actively engage in supervision and use it as an opportunity to test out thinking, have practice constructively challenged and discuss support needs. Professional training and local protocols should clearly outline the roles and responsibilities of different practitioners in safeguarding children from harm (see Working Together). Training should address the complexities of identifying and responding to child sexual exploitation, emphasising: - Practitioners' safeguarding responsibilities and local reporting routes; - Child sexual exploitation is a form of child sexual abuse; - Child sexual exploitation can take many different forms (online and offline) and affect any child or young person; - All under 18s are entitled to protection and support and that safeguarding duties do not depend on a child or young person's desire to be safeguarded; - The need to understand the impact of trauma on behaviour and presentation; - The need to look beyond presenting behaviours and exercise 'professional curiosity'; - The need to apply professional judgment, supported by effective supervision and robust tools, in decision-making and practice; - The power of professional reactions to facilitate or close down access to support and protection; - The practical implementation of information sharing guidance where there are concerns about child sexual exploitation; and - The development of practical skills in facilitating conversations with children and young people, and with their parents/carers. Training alone is not sufficient to ensure a skilled and confident workforce, however. Training should be accompanied by: - Opportunities to learn from other practitioners - for example, shadowing, coworking and peer observation; - Ongoing high-quality supervision; - A focus on reflective practice to help practitioners navigate complexity; and - A recognition of the emotional impact that such work can have on practitioners, and access to support in order to manage this. ## Educating Children And Young People Although there is not as yet any proven blueprint for the most effective means of communicating messages around child sexual exploitation to children and young people, the evidence base highlights some important principles: - **The need for early and continuous education**: We are increasingly learning about cases of child sexual exploitation that involve younger children, particularly in the online sphere. If children and young people are not educated about the risk of child sexual exploitation (and other forms of sexual abuse) before perpetrators approach them, they are left unprotected. Schools may want to consider how to build in effective, age-appropriate education, which sensitively supports younger children on these issues and which forms part of a planned programme of study across key stages. This should be accompanied by wider resilience-building work. - **Use all potential avenues of communication**: Schools, colleges and other educational settings have a critical role to play. Personal, social, health and economic (PSHE) lessons are an obvious route for educating children and young people about the risks of child sexual exploitation and other forms of harm, as are pastoral services and school nurse services. Consideration should also be given to how messages can be delivered outside mainstream education, for example, in youth clubs, community settings or the family home. - **Adopt a holistic approach**: Risk of child sexual exploitation should be addressed as part of a wider programme of work on sexuality and sexual development, choice and consent, healthy relationships, harmful social norms and abusive behaviours and online safety. This should build on existing initiatives (around online safety for example) and ensure messages dovetail across these different programmes of work. Educative work should engage both boys and girls and should address both risk of perpetration and risk of victimisation (and the potential for overlap). - **Contextual considerations**: Messages around child sexual exploitation should be delivered within a safe non-judgmental environment, by credible individuals who are confident discussing the issues and able to challenge unhelpful perceptions. Where specific vulnerabilities are identified (going missing, gang-association or drug/alcohol misuse, for example) more targeted educative work should be undertaken, while taking care to avoid stigmatisation or labelling. Accessible and appropriate support should be immediately available should any issues of concern be identified during education activity. ## Educating Parents And Carers Parents and carers have a critical role to play in helping to protect children and young people from child sexual exploitation. They can educate their children about sex, healthy relationships and abuse, enhance resilience, provide a safe base and ensure open channels of communication. They are also well placed to support early identification by identifying emerging vulnerabilities or potential indicators of abuse and seeking support before risks escalate. In order to support them, practitioners should ensure that parents/carers: - Understand the risks of both online and offline child sexual exploitation and recognise this as something that could affect their child; - Know the potential indicators of child sexual exploitation; - Know where and how to access support; - Are reassured that services will, as appropriate, work in partnership with them to try to protect their child; - Have support to manage the emotional impact of child sexual exploitation on their child, themselves and on family relationships; and - Have support that is tailored to their specific circumstances and needs, for example, support that recognises their culture or faith, and are helped to overcome any barriers such as language. ## Educating Communities Harnessing the wider community: Those who do not necessarily 'work with children' also have a contribution to make to tackling child sexual exploitation. Hoteliers, taxi drivers, park wardens, refuse collectors and retail workers (amongst others) may hold vital information about the movement of victims and perpetrators. Emergency services, including the Fire and Ambulance Services, and local community and religious groups can also play a key role. Educating those who work in local services and businesses (including the night-time economy) about what to look for, and how to report concerns, can significantly enhance local disruption and protective capabilities. This focus should also include members of the wider local community who may observe concerns within their areas - for example, those living near a party house location who may see victims coming and going. Educating people about child sexual exploitation, the things to look out for and where to report concerns, will significantly enhance the protective capabilities of our communities. This practice advice was produced by the Department for Education. It is adapted from a review of evidence produced by the University of Bedfordshire and Research in Practice. To view this extended practice advice see www.beds.ac.uk/ic/publications © Crown copyright 2017 This publication (not including logos) is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned. To view this licence: visit www.nationalarchives.gov.uk/doc/open-government-licence/version/3 email psi@nationalarchives.gsi.gov.uk write to Information Policy Team, The National Archives, Kew, London, TW9 4DU Reference: DFE-00056-2017 About this publication: enquiries www.education.gov.uk/contactus download www.gov.uk/government/publications | Follow us on Twitter: | Like us on Facebook: | |--------------------------|-------------------------| | | | | | | | @educationgovuk | |
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## The Office Of Rail And Road 136Th Board Meeting 09:00 -13:15 TUESDAY 23rd MAY 2017 CROWNE PLAZA HOTEL, CENTRAL SQUARE, BIRMINGHAM B1 1HH Non-executive members: Stephen Glaister (Chair), Tracey Barlow, David Franks, Anne Heal, Bob Holland, Michael Luger, Justin McCracken, Graham Mather Executive members: Joanna Whittington (Chief Executive), John Larkinson (Director Railway Markets and Economics), Ian Prosser (Director Railway Safety), Graham Richards (Director Railway Planning and Performance). In attendance: Peter Antolik (Director Highways Monitor - items 1-8), Dan Brown (Director Strategy and Policy), Russell Grossman (Director Communications), Juliet Lazarus (Director Legal Services and Competition), Tess Sanford (Board Secretary), Other ORR staff in attendance are shown in the text. Item 1 WELCOME AND APOLOGIES FOR ABSENCE 1. The chair welcomed everyone to the meeting. 2. There were no apologies for absence. ## Item 2 Declarations Of Interest 3. There Were No Declarations Of Interest In Relation To The Planned Business. Item 3 APPROVAL OF PREVIOUS MINUTES 4. The Board agreed the minutes. The board noted updates on the action list: Joanna Whittington had circulated a note to members about the treatment of vacancies in the quarterly business reports. Item 4: REGIONAL LEARNING 5. The Board reflected on the visits they had undertaken the day before, the discussions with stakeholders over dinner, and the meeting with Birmingham based staff. 6. The three visits had been to Freightliner's Birmingham depot, to the Midlands Metro tram system and to look at maintenance challenges at Gravelly Hill ('spaghetti junction'). All three groups commented on the level of time and resource invested by the hosts in ensuring that visits were informative and enjoyable. The chair would write to thank our hosts. [Action - Secretariat] 7. The board agreed that we should send a note of feedback to guests and invitees. [Action: Russell Grossman]. 8. The arrangements had been well made and delivered and the board thanked the Secretariat team for a successful day. ## Item 5: Headlines And Regular Reports 9. Ian Prosser gave some more detail on the wrong-side failures commented on at the last meeting and their significance. He also reported on: - Questions around fatigue management on trams; - Challenges around the introduction of new rolling stock; - NR's SHE Committee had made the adoption of RM31 by the devolved routes a priority. - Recruitment of new trainee inspectors and a new deputy Director and head of CTSA. 10. Board members sought assurance that the move to SMIS+ and the resultant changes to the PIM was not materially reducing understanding about the overall risk picture. They also discussed issues around the use of regular visual inspection in monitoring deteriorating assets. 11. Graham Richards drew on the CP5 tracker to discuss current performance by NR. 12. John Larkinson discussed the PR18 report and described the progress of discussions with government on their future funding of NR. 13. John also reported on: current funding challenges, progress on the efficiency debate, progress on the TfL/HAL appeal and discussions with Transport Scotland on the EGIP programme. John would send board members the latest draft efficiency document. [Action: JLk] 14. Joanna Whittington reported on: - The IT transformation project and recruitment of a new Director of Corporate Operations and Organisational Development. - No judgement had been issued on the HAL judicial review. ## Item 6 Annual Report And Accounts 15. The board considered the draft annual report and accounts which had been reviewed in detail by the Audit and Risk Committee. The board suggested some drafting and presentational changes to the report. 16. The board thanked Lucy Doubleday and the accounts and communications teams for their work on this. 17. The board approved the accounts and the draft annual report. ## Item 7 End Of Year Monitor Reports Gordon Cole joined the meeting for this item and the next. 18. Graham Richards introduced the paper which set out key comments and evidence on performance. The board was invited to discuss the evidence and comment on the appropriate tone for the report to take. 19. Highways Committee had seen and discussed the draft performance letter to the DfT about Highways England and this was broadly agreed by the board. The board also discussed the importance of establishing better understanding with HE at board level. 20. The board discussed the evidence for the Network Rail Monitor. They commented that while safety was at a good level, it was not improving and it was not clear that all the necessary elements were in place to make current safety levels sustainable. National passenger performance had been distorted by the impact of GTR's industrial relations issues but route-based data help put this in context. There continued to be significant and increasing financial challenges, including with NR's programme of asset disposals. ## Item 8 Highways - Ris2 Programme And Progress David Hunt joined the meeting for this item 21. Peter Antolik introduced the first of the proposed quarterly reports to the Board on the progress of the RIS2 programme. Working relationships with DfT and HE were good. 22. The board discussed the challenges of identifying and evidencing efficiency for Highways England and how these compared to those for NR. 23. The board noted the report and agreed to receive a regular quarterly report in future.[Forward programme] ## Item 9 Pr18 Programme 24. John Larkinson introduced the paper which set out the way that programme was being developed and managed and explained the governance and assurance arrangements. As part of these, an audit of some parts of the programme would be undertaken in Q3 by our internal audit providers. 25. The board also discussed the Joint Steering Group arrangements and the specific role that ORR plays in the overall framework (as illustrated in the paper). ## Item 10 Pr18 Charging Structure And Incentives Chris Hemsley, Deren Olgun and Alex Bobocica joined the meeting for this item 26. John Larkinson introduced the team and the item which built on previous discussions and drew on responses to our charges and incentives consultation run earlier in the year. Paragraphs 27-34 inclusive have been redacted until after the publication of the 'letter to the industry' because they are about policy development and pending publication. Paragraph 33 will be permanently redacted from the public version as legally privileged. 35. The board discussed issues around the communication of these decisions. Public understanding of the Schedule 8 regime in particular needed to be strengthened. 36. The board delegated to John Larkinson agreement of the 'letter to the industry' which would set out these decisions. [action list] ## Item 11 Feedback From Committees 37. The Highways Committee and Audit and risk Committee had met since the last board meeting in order to consider reports which the Board had now considered as part of its business today. Item 12 ANY OTHER BUSINESS 38. The board noted the board forward programme. 39. The board agreed that it would add an awayday to its forward programme to run from dinner on 5 October to close of business on 6 October. Signed by Stephen Glaister 14 August 2017
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WATERHOUSES SEWAGE TREATMENT WORKS STAFFORDSHIRE GREAT CRESTED NEWT MITIGATION STRATEGY A Report to Severn Trent Water Ltd Middlemarch Environmental Ltd. Triumph House Birmingham Road Allesley Coventry CV5 9AZ Tel: 01676 525880 Fax: 01676 521400 E-Mail: admin@middlemarch-environmental.com Web Site: www.middlemarch-environmental.com Report Number: RT-MME-112246 July 2012 ## Waterhouses Sewage Treatment Works Staffordshire Great Crested Newt Mitigation Strategy Controlled Copy 01 Of 02 01 Mwh Global 02 Middlemarch Environmental Ltd. This Study Was Conducted And Compiled By Colin Bundy Bsc (Hons) Mieem This Report Is The Responsibility Of Middlemarch Environmental Ltd, It should be noted, that whilst every effort is made to meet the client's brief, no site investigation can ensure complete assessment or prediction of the natural environment Contract Number C112246 July 2012 ## Contents | A | | PROJECT DETAILS 4 | | |--------------------------------|--------------------------------------------------------|--------------------------------|-----| | A1 | Project Name 4 | | | | A2 | Developer 4 | | | | B | | INTRODUCTION 5 | | | B1 | Background to Development 5 | | | | C | | SURVEY AND SITE ASSESSMENT 7 | | | C1 | Pre Existing Survey Information 7 | | | | C2 | Status of Great Crested Newts in the Local Area | 7 | | | C3 | Recent Survey 7 | | | | C4 | Amphibian Survey | 10 | | | C5 | Interpretation and Evaluation | 12 | | | D | | IMPACT ASSESSMENT 14 | | | D1 | Pre and Mid Development Impacts 14 | | | | D2 | Long Term Impacts | 14 | | | D3 | Post Development Interference Impacts 14 | | | | D4 | Other Impacts 14 | | | | D6 | Impact Assessment General Comments and Wider Context | 15 | | | E | | MITIGATION AND COMPENSATION 16 | | | E1 | Mitigation Strategy | 16 | | | E2 | Receptor Site Selection 16 | | | | E3 | Habitat Creation, Restoration and/or Enhancement | 16 | | | E4 | Capture, Exclusion and Translocation | 18 | | | E5 | Post Development Site Safeguard 18 | | | | E6 | Work Schedule 19 | | | | F | | SUMMARY 20 | | | REFERENCES AND BIBLIOGRAPHY 21 | | | | | APPENDICES 22 | | | | | APPENDIX 1 23 | | | | | APPENDIX 2 25 | | | | | APPENDIX 3 29 | | | | | APPENDIX 4 31 | | | | | APPENDIX 5 33 | | | | | APPENDIX 6 35 | | | | | APPENDIX 7 37 | | | | | | | | | ## A Project Details A1 Project Name Waterhouses Sewage Treatment Works (STW), Staffordshire ## A2 Developer MWH Global in association with Severn Trent Water Ltd. Severn Trent Centre 2 St John!s Street Coventry CV1 2LZ ## B Introduction B1 Background To Development B1.1 Project Name Waterhouses Sewage Treatment Works, Staffordshire. ## B1.2 Location Local Authority Area Peak District National Park Authority ## B1.3 Location Off Leek Road Waterhouses Stoke-on-Trent Staffordshire ST10 3JU Centred at Ordnance Survey National Grid Reference SK 0945 5025 ## B1.4 Land Ownership Severn Trent Water Ltd. (STWL) ## B1.5 Current Land Use Sewage treatment works. ## B1.6 Development Type Provide a new infrastructure of existing sewage treatment works and improving existing structures such as Waste Water Treatment Works. ## B1.7 Planning Status Permitted development. Natural England great crested newt *Triturus cristatus* development licence pending. ## B1.8 Relationship With Impacts Due To Other Nearby Development The current development is not part of a larger project that is likely to have in the future, or has had in the last 5 years, additional impacts on great crested newts in the local area. It is understood that there are no other future developments within the local area that would impact on GCN. ## B2.1 Activities Related To Great Crested Newt (Gcn) Mitigation A Natural England Development Licence will be required to capture, disturb and move great crested newts from the development site. The maximum number of individuals likely to be affected is anticipated to be ten. ## B2.2 Brief Description Of Construction Activities The existing bio-filter capacity will be increased, through the construction of new filters and increasing humus tank capacity. This will involve the replacement of existing tanks and balancing storm flows. In addition, a new soak-away will also be constructed. The existing site access will be closed and three new access points will be constructed. For safety of public using the Manifold Way access track, 5 small pull-ins will also be created. ## C Survey And Site Assessment C1 Pre Existing Survey Information C1.1 Pre Existing Survey Data A survey completed in May 2012 confirmed the presence of a small size class population. Details are recorded in Middlemarch Environmental Report RT-MME-111773. No pre-existing data prior to this survey confirms great crested newt presence. ## C2 Status Of Great Crested Newts In The Local Area C2.1 Local Status (Within Approx 10Km) Occasional, known or likely to occur in one to five ponds per square kilometre. ## C3 Recent Survey C3.1 Objective Of Survey In order to inform this mitigation strategy, a recent survey was undertaken in 2012 to assess the population class size of great crested newts in specified ponds. ## C3.2 Survey Area And Justification Assessment of Ordnance Survey mapping data identified seven potential ponds within 500m of the works site. The survey area is limited to the south by the A523 and to the east by the River Hamps; these features are considered to be dispersal barriers, and therefore excluded Ponds 5, 6 and 7. In addition, the field survey subsequently identified Pond 6 to be a defunct dry concrete dew pond and Pond 7 to be a defunct silted up concrete dew pond. The field survey also identified Ponds 3 and 4 to be defunct, concrete dew ponds and Pond 2 to be absent. Therefore, only one extant pond (Pond 1) with habitat connectivity to the works was present, which was subject to great crested newt survey works (GCN). Middlemarch Environmental Ltd Drawing Number C112246-C3.2 in Appendix 1 shows the location of the development site and extant pond with habitat connectivity to the development site. ## C3.3 Habitat Description: Waterbodies Pond 1 was a small, concrete dew pond within a small enclosure. Pond 2 was absent and therefore not surveyed. Ponds 3 and 4 were small, defunct, dry concrete dew ponds and therefore not surveyed. The survey area was restricted to north of the A523 and River Hamps although field survey subsequently identified Pond 6 to be a defunct dry concrete dew pond and Pond 7 to be a defunct silted up concrete dew pond. ## C3.4 Habitat Description: Terrestrial Habitats The site is dominated by amenity grassland and hardstanding. Small areas of semi-mature woodland are present at the north and south of the site and a hawthorn dominated hedge runs along the western and northern boundaries. Adjacent to the east is a narrow belt of mature woodland on the steep bank of the River Hamps. To the east of the site the river is seasonally dry. The Manifold Way runs along the west boundary beyond which the valley side fields contain species rich, calcareous grassland. Semi-improved grassland is present to the south. The STW occupies a small area (0.1 ha) consisting of small operational structures within amenity grass and gravel hardstanding. The STW is bounded to the south and west by a fence and young and semi mature trees and scrub. A strip of broadleaved woodland forms the north and east boundaries with a small stream along the north boundary. To the south and west, the proposed STW extension (0.57 Ha) is within a semi-improved grass field with low species diversity. ## C3.5 Waterbodies: Habitat Quantitative Assessment Ponds were assessed for their habitat suitability for great crested newts, utilising the modified Great Crested Newt Habitat Suitability Index (Oldham *et al*, 2000). The habitat suitability index provides a means of evaluating habitat quality. The Habitat Suitability Index (HSI) is a numerical index between 0 and 1, where 0 indicates suitable habitat and 1 represents optimal habitat. The HSI score is then utilised to define the suitability of the pond on a categorical scale (Table C3.1). The system is not precise enough to allow the conclusion that a pond with a high score will support great crested newts whilst those with a low score will not. Results of the assessment and distances of the ponds from the development are shown in Table C3.2. | HSI Score | Pond Suitability | |--------------|---------------------| | < 0.5 | Poor | | 0.5 0.59 | Below average | | 0.6 0.69 | Average | | 0.7 0.79 | Good | | > 0.8 | Excellent | Factor Pond 1 Geographic Location Optimal geographic location for GCN (HI 1.0) 50 m2 (HI 0.05) Pond Area (rounded to the nearest 50 m 2) Pond Permanence Dries sometimes (HI 0.5) Water Quality Moderate (HI 0.67) Pond Shading 30% (HI 1.0) No. Water Fowl Absent (HI 1.0) Occurrence of Fish Absent (HI 1.0) Pond Density 5 (HI 0.75) Good (HI 1.0) Quality of terrestrial habitat Macrophyte Cover 70% (HI 1.0) 0.65 (Average) Habitat Suitability Score 145 m Distance of Pond from Development ## C4 Amphibian Survey C4.1 Terrestrial Amphibian Survey No terrestrial amphibian surveys were undertaken. ## C4.2 Aquatic Amphibian Survey C4.2.1 Great Crested Newt Presence / Absence Survey Surveys for the presence of GCN require a minimum of 4 visits per year, with at least 2 visits between 15th April and 15th May to record peak numbers of GCN (English Nature, 2001). Several survey methodologies are to be utilised during these visits. The standard survey methodologies include: Bottle trapping; Torchlight survey; Egg search; and, Refugia search. Bottle traps were laid during the evening using the method described by Gent and Gibson (1998). The traps were then checked for newts before 10 am the following morning. Any newts found were recorded and then released back into the pond. The egg search involves a direct assessment of emergent and submerged vegetation for GCN eggs. Egg surveys can only be undertaken during late spring and early summer (April to June). The torchlight survey is a standard amphibian recording technique employing a high power torch to illuminate the ponds and allow the surveyor to record any GCN seen. This technique is undertaken during the spring, when males will be displaying and courting females. Refuge searching involves looking underneath objects such as rocks, logs, moss and discarded debris in the vicinity of a pond. Adult and juvenile GCN can often be found underneath such objects, between March and October, especially if the objects are flat and retain moisture. Refuge searching is not a reliable method on its own and is only used as a supporting method to the other methods described. ## C4.2.2 Population Size Class Assessment To carry out a population assessment, English Nature guidelines require 6 survey visits in suitable weather conditions including bottle trapping and torchlight surveys at each survey visit (English Nature, 2001). Surveys may be undertaken between mid-March and mid-June with at least 3 survey visits between mid-April and mid-May. It is extremely difficult to determine the actual size of a great crested newt population due to the variation in sampling efficiency even with the best methods employed and the complex metapopulation dynamics involved. Therefore, English Nature (2001) has developed a Population Size Class system for the purposes of development license applications. The peak population count for a single night is used to inform the process, where ponds are within 250 m of each other the peak is summed across these ponds for the same night and a size class assigned using the following: Small where peak count is up to 10; Medium where peak count is 11 to 100; and, Large where peak count exceeds 100. ## C4.2.3 Survey Results The great crested newt surveys were undertaken between 27 th April 2012 and 16 th May 2012 by the following staff: Colin Bundy, Principal Ecological Consultant and licensed GCN Surveyor. Table C4.1 provides a summary of the survey dates and weather conditions. Parameter Survey Temperature Precipitation Wind Visit Date Time 0C Cloud % (Beaufort Number Scale) 1 27/4/10 pm 7 100 Heavy Showers F2 28/4/10 am 6 100 Showers F2 2 4/5/10 pm 7 100 Dry F3 5/5/10 am 7 100 Showers F1 3 7/5/10 pm 9 100 Heavy Showers F1 8/5/10 am 9 80 Heavy Showers F1 4 16/5/10 pm 12 100 Rain F0 17/5/10 am 10 100 Dry F1 5 18/5/10 am 7 0 Dry F2 19/5/10 pm 7 0 Dry F0 6 25/5/10 am 8 100 Showers F3 26/5/10 pm 8 100 Dry F2 During the great crested newt surveys the presence of great crested newts was confirmed within Pond 1. A total of six surveys were therefore undertaken on these this ponds to provide sufficient information for a Population Size Class Assessment. Table C4.2 lists the results obtained from the great crested newt surveys. | | P | |--------------------------|----------------------| | OND | | | P1 | | | Survey Visit 1 | | | [27-04-12 / 28-04-12] | | | | | | Torch Survey | 2 GCN | | Bottle Trapping | 3 1 SN | | Refugia Search | 0 | | Egg Search | 0 | | Peak GCN Count 1 | | | 2 | | | Survey Visit 2 | | | [04-05-12 / 05-05-12] | | | | | | | | | Torch Survey | 1 GCN | | Bottle Trapping | 2 SN | | Refugia Search | 0 | | Egg Search | 0 | | Peak GCN Count 2 | 1 | | Survey Visit 3 | | | [07-05-12 / 08-05-12] | | | | | | | | | Torch Survey | 1 SN, 2 CF | | Bottle Trapping | 2 SN | | Refugia Search | 0 | | Egg Search | 0 | | Peak GCN Count 3 | 0 | | Survey Visit 4 | | | [09-05-12 / 10-05-12] | | | | | | | | | Torch Survey | 5 6 SN | | Bottle Trapping | 2 1 SN | | Refugia Search | 0 | | Egg Search | 0 | | Peak GCN Count 4 | 0 | | Survey Visit 5 | | | [11-05-12 / 12-05-12] | | | | | | | | | Torch Survey | 3 3 SN | | Bottle Trapping | 5 2 SN | | Refugia Search | 0 | | Egg Search | 0 | | Peak GCN Count 5 | 0 | | Survey Visit 6 | | | [16-05-12 / 17-05-12] | | | | | | | | | Torch Survey | 3 8 SN | | Bottle Trapping | 0 | | Refugia Search | 0 | | Egg Search | 0 | | Peak GCN Count 6 | 0 | | Key: | | | GCN Great crested newt | Triturus cristatus | | SN Smooth newt | Lissotriton vulgaris | | CF Common frog | Rana temporaria | | - male, - female | | | | | ## C5 Interpretation And Evaluation The population size class assessment is determined by taking the maximum count for the water feature during a single survey visit by a single technique (English Nature, 2001). Pond 1 was found to contain great crested newts. No other suitable ponds were located within 250 m of this water body to create a potential great crested newt meta-population. The population size class assessment is taken as the maximum count for the pond. The results from the assessment are presented in Table C5.1. Photographs of the pond are provided in Appendix 2. Maximum GCN Count Population Pond (using a single survey Size technique) Pond 1 2 Small for Surveyed Waterbodies ## Site Status Assessment Natural England has developed a methodology for determining a site status assessment using English Nature guidelines (Great Crested Newt Mitigation Guidelines, English Nature 2001). Assessment results are provided in Table C5.2. | Factor | Assessment | |-------------------------------------|---------------------------------------------------------------| | Quantitative | Minor importance - small population | | Qualitative | Minor - no breeding on site; habitats common in area | | Functional | Minor importance - population completely isolated | | Contextual | Moderate importance population size class typical for area. | | Table C5.2: Site Status Assessment | | The survey suggests the presence of a small, possibly isolated population, potentially under threat from lack of suitable breeding ponds. Pond 1 was considered to be declining in value due to dense vegetation and leaf litter. ## D Impact Assessment D1 Pre And Mid Development Impacts Before main construction works, the areas of semi-mature woodland in the north and south of the site will be removed, as will sections of hedgerow, to allow construction of structures and new access into works. Areas will be topsoil stripped which will be stockpiled within the development area. Two concrete drying beds will be knocked down to create car parking and temporary compound areas constructed. These works may kill or injure newts or create temporary habitats such as spoil piles which newts may attempt to use if still on site. In addition, outside of the works site, five passing places will be created on the Manifold Trail verge used for access to the works resulting in the small loss of grassland and tall ruderal vegetation. Post development works the passing places will be restored and reseeded. It is not considered that works would significantly impact on migration routes. ## D2 Long Term Impacts Construction of the new balancing tank in the south (intermediate) and soak-away in the north (distant) will destroy 0.03 ha and 0.06 ha respectively of broad-leaved woodland considered suitable terrestrial habitat. 119 m of hedge would be removed for construction, although 81 m of this will be replanted. This loss is not considered significant from a dispersal point of view. Remaining habitat loss mainly includes low value amenity grass, tall ruderal vegetation and hardstanding, which will be partially restored. ## D3 Post Development Interference Impacts The development would not result in any increased vehicular use of the site which would remain as occasional access for operational reasons only. There would be no resulting interference impacts to Pond 1. ## D4 Other Impacts No other impacts are anticipated. ## D5 Quantitative Analysis D5.1 Quantitative Impact Assessment Table D5.1 shows the effects of the development of the works on Pond 1. Effects of development are shown without any mitigation or compensation planned. | Effect | Effect on | Effect on | Effect on | Fragmentation | Interference | Pond | |------------|--------------|--------------|--------------|------------------|-----------------|-----------| | Peak | on | immediate | intermediate | distant | effect | and other | | Count | pond | terrestrial | terrestrial | effects | terrestrial | | | habitat (< | habitat (50 | habitat (> | | | | | | 50 m from | 250 m from | 250 m | | | | | | pond) | pond) | from | | | | | | pond) | | | | | | | | Pond 1 | 2 | | | | | | | No | | | | | | | | effect | | | | | | | | No effect | | | | | | | | Minor | | | | | | | | negative | | | | | | | | effect | | | | | | | | Minor | | | | | | | | negative | | | | | | | | effect | | | | | | | | No effect | No effect | | | | | | ## D5.2 Quantitative Summary Of Long Term Impacts Impact Number or area (ha) to be lost Number of ponds to be lost 0 Number of ponds to be damaged 0 Total area of ponds to be lost (ha) 0 Area of immediate terrestrial habitat (<50 m from pond) to be lost 0 Area of immediate terrestrial habitat (<50 m from pond) to be damaged 0 Area of intermediate terrestrial habitat (50-250 m from pond) to be lost 0.024 Area of intermediate terrestrial habitat (50-250 m from pond) to be damaged 0.13 Area of distant terrestrial habitat (250-500 m from pond) to be lost 0.03 Area of distant terrestrial habitat (250-500 m from pond) to be damaged 0.18 ## D6 Impact Assessment General Comments And Wider Context There would be a risk that works may kill or injure newts or create temporary habitats such as spoil piles which newts may attempt to use if still on site. Main habitat losses of note are the loss of broad-leaved woodland and hedgerow, and in addition, newts may use existing structures for refuge. Otherwise remaining impacts on habitat are mainly temporary and short term, resulting only in the long term loss of a small area of habitat considered of low value. Existing dispersal routes for newts will be maintained long term. ## E Mitigation And Compensation E1 Mitigation Strategy The main impacts on GCN will be the destruction and mainly temporary loss of non-core terrestrial habitat. Trapping and translocation followed by a supervised destructive search (where appropriate) will be undertaken to clear the site of newts before development work commences and prevent access for newts to the site during works. The receptor site is adjacent to the development site, within areas currently utilised by the great crested newt population, and newts will be moved to suitable terrestrial habitat. The site will be restored to include grass seeding and hedge planting. ## E2 Receptor Site Selection E2.1 Existing Great Crested Newt Status At Receptor Site On site receptor area - great crested newts present: small population ## E2.2 Survey Information For Receptor Site The receptor site is *in situ*, adjacent to the development area. Survey for GCN was undertaken in 2012 and results are detailed in Section C4.2 which confirms the presence of a small population. Captured newts will be moved to the site boundary. ## E2.3 Receptor Site Location On site, adjacent to works area. ## E2.4 Receptor Site Ownership And Land Status Owned by Severn Trent Water Ltd and is part of the sewage treatment works site ## E2.5 Receptor Site Habitat Description A three metre wide strip of the sewage works site along the southern boundary will be set aside from the exclusion fenced area. This area contains grassland and is adjacent to the river valley to the east with scattered trees, scrub and ruderal vegetation on the west bank. It also has connectivity with semi-improved grassland to the southwest. Within the receptor area the grass will be allowed to grow and refuges created with brash, logs and carpet tiles from which newts can disperse. ## E3 Habitat Creation, Restoration And/Or Enhancement Table E3.1 shows a quantitative summary of habitat creation, restoration and enhancement measures. The table summarises those impacts specified in Section D with proposed compensation detailed in the right hand column. Habitat creation, restoration and enhancement measures are shown on Drawing C112246-E3.1 in Appendix 5. | Habitat | Impact | Compensation | |--------------------------|------------------------|---------------------| | Effect | No. or | | | area (ha) | | | | lost | | | | No. or | | | | area | | | | gained | | | | Habitat creation, | | | | restoration or | | | | enhancement | | | | measure | | | | Breeding | | | | Ponds | | | | No. ponds lost | 0 | No. ponds to be | | created | | | | 0 | | | | No. ponds damaged | 0 | No. ponds to be | | restored or enhanced | | | | 0 | | | | Area ponds lost | 0 | Total area ponds to | | be created | | | | 0 | | | | 0 | | | | Core | | | | Terrestrial | | | | Habitat | | | | Core terrestrial | | | | habitat lost or | | | | damaged | | | | 0 | Area of habitat within | | | 50 m of breeding | | | | pond to be created or | | | | enhanced | | | | 0.013 | | | | Intermediate | | | | terrestrial | | | | habitat | | | | Intermediate | | | | terrestrial habitat lost | | | | or damaged | | | | 0.154 | Area of habitat 50- | | | 250 m of breeding | | | | pond to be created or | | | | enhanced | | | | 0.18 | Distant | | | terrestrial | | | | Habitat | | | | Distant terrestrial | | | | habitat lost or | | | | damaged | | | | 0.21 | Area of habitat > 250 | | | m of breeding pond to | | | | be created or | | | | enhanced | | | ## E3.1 Aquatic Habitat No new aquatic habitat would be created. ## E3.2 Terrestrial Habitat Measures Given the small area of the works and the tight constraints of space for new infrastucture, opportunities for habitat creation are very limited. The works however, located in an area of extensive and high quality terrestrial habitat. Feature Number/area/length Grassland Managed for Biodiversity 0 Hedgerow Planting 81 m Grassland re-seeding 0.193 ha Refuge creation 0 Other reed bed 0 ## E3.3 Integration With Roads And Other Hard Surfaces Access onto the site is from the Manifold Way (a surfaced walking and cycle route). Access to the works will be revised to allow vehicle access to all operation structures where required however, there would be no increase in the use of the site by vehicles which is only occasional by a single vehicle during daylight hours and as such is not significant. The access will be created without kerbs and gully pots. Overall, the increased impact of vehicle access and surfaces is considered to be negligible and not significant. ## E3.4 Integration With Other Species And Habitat Requirements No other protected or notable species have been recorded and there are no other known species issues that would conflict with GCN mitigation. ## E4 Capture, Exclusion And Translocation Exclusion fencing will be erected around the perimeter of the sewage treatment works with the exception of a strip along the eastern boundary which will be used as a receptor area to release newts. The site will be further divided up by the use of temporary internal, drift fencing. Exclusion fencing will be erected around the perimeter of the sewage treatment works except along the west boundary where the hedge prevents this. Along this boundary the exclusion fence will be erected along the inside edge of the hedge. Small scale vegetation clearance by hand will be necessary within the woodland areas to allow access for fence construction. This route will be subject to detailed hand search prior to vegetation removal. The site will be further divided up by the use of temporary internal, drift fencing where hardstanding/structures allow. Pitfall traps and refugia will be located at 10 m intervals (min trap density 50/ha) along the inside of the perimeter fence and both sides of the drift fencing. Minimum capture effort will be 30 days as recommended by English Nature for a small population (EN 2001). This will be subject to suitable weather conditions with 5 clear days at the end of the trapping period where no newts are caught. Newts will be relocated in black plastic buckets to the receptor area. A hand and destructive search will be undertaken where appropriate, such as where sections of hedge are to be removed which are outside the exclusion fence or within the woodland areas. Proposed passing places on the Manifold Trail will be strimmed to 100 mm no more than 48 hours before and then subject to a hand search before works. Drawing C112246-F1 in Appendix 7 shows the final development layout and mitigation measures. ## E5 Post Development Site Safeguard E5.1 Habitat Management And Maintenance No specific habitat management or maintenance is required. ## E5.2 Post Development Population Monitoring Given the low impact of the development, no monitoring is required (EN 2001). ## E5.3 Mechanism For Ensuring Site Safeguard And Post Development Works Low, mainly temporary impacts within the sewage treatment works which will not impact on Pond 1. The entire site is located within the Hamps and Manifold Valleys SSSI. In addition, the Peak District Dales Special Area of Conservation (SAC) lies at its closest point approximately 800 m to the north of the works. It is considered that the site is adequately safeguarded. ## E6 Work Schedule Timings for works are subject to the receipt of planning permission and a Natural England development licence. Anticipated timings are shown in Tables E6.1 and E6.2 for major categories of work detailed in Section E. Pre and mid development Activity Timing Comments August 2012 Creation of temporary log and brash refuges for newt dispersal Receptor site terrestrial habitat works - features e.g. hibernacula, refuges Newt fence installation August/September 2012 Subject to Natural England Development Licence. Newt capture (pitfall trapping etc) September/October 2012 Minimum of 30 days trapping in suitable weather conditions, with 5 clear days at the end of the trapping period where no newts are caught. Destructive or hand searches August / September / October 2012 Prior to fence in woodland & passing Development site preparation Sep/Oct - 12 to March/April - 13 Subject to completion of trapping Site checks & maintenance during construction Daily By contractor throughout works on site Newt fence removal April 2013 Habitat reinstatement March/April 13 Hedge planting and grass reseeding March/April 13 Hedge planting and grass reseeding Post construction mitigation/compensation on development site or other ## F Summary The development will see the upgrade of treatment processes at the Waterhouses STW, to meet new discharge consents from the Environment Agency. The impacts on newts will be the potential to kill or injure newts or create temporary habitats such as spoil piles which newts may attempt to use if still on site. In addition, there would be a temporary and permanent loss of mainly intermediate and distant terrestrial habitat. There will be no impacts on Pond 1. Exclusion of great crested newts from the development area during construction will protect individuals from death or injury. Overall the loss of habitat is considered negligible and non-core to the population. The site will be restored after works. It is considered that the mitigation strategy will ensure the favourable conservation status of this species. REFERENCES AND BIBLIOGRAPHY Convention on the Conservation of European Wildlife and Natural Habitats 1979 (Berne Convention). Countryside Rights of Way Act 2000. English Nature (2001) *Great Crested Newt Mitigation Guidelines*. English Nature, Peterborough. European Community Directive 92/43/EEC on the Conservation of Natural Habitats and of Fauna and Flora. Gent A and Gibson S (1998), *Herpetofauna Workers Manual*, Joint Nature Conservation Committee, Peterborough. Langton, T, Beckett, C. and Foster J. (2001) *Great Crested Newt: Conservation Handbook*. Froglife, Suffolk. The Conservation (Natural Habitats, & c.) Regulations 1994. The Wildlife and Countryside Act 1981 (as amended). ## Appendices Appendix 1: Middlemarch Environmental Drawing C112246-01 Fig C3.2 Map to show development site location, survey area and ponds surveyed. Appendix 2: C9.4 Photographs to show GCN ponds and habitats on development site. Appendix 3: Middlemarch Environmental Drawing C112246-Fig D Map to show impacts. Appendix 4: Middlemarch Environmental Drawing C112246-Fig E2 Map to show location of receptor site in relation to development site. Appendix 5: Middlemarch Environmental Drawing C112246-Fig E3.1 Map to show habitat creation, restoration and enhancement. Appendix 6: Middlemarch Environmental Drawing C112246-Fig E4. Map to show capture and exclusion measures Appendix 7: Middlemarch Environmental Drawing C112246-Fig F1 Map to show final layout of development and mitigation measures. Passing bay Passing bay Passing bay Passing bay ## Legend Existing Habitat: © Crown copyright and database right 2012. ## Legend | Permanent habitat loss | Passing places | |----------------------------|---------------------------| | Existing habitat: | | | T | emporary habitat loss | | Permanent loss of hedgerow | | | T | emporary loss of hedgerow | | 50 m radius from GCN pond | | | 250 m radius from GCN pond | | | 500 m radius from GCN pond | | | Habitat type | A | rea lost (ha) | A | |-------------------------|-------------------|-----------------|------| | 2 | | | | | ) | Length lost (m) | | | | 50-250 m from GCN pond | | | | | Permanent loss | | | | | Amenity grassland | 0.020 | 199 | | | Broad-leaved woodland | 0.004 | 45 | | | Hedgerow | 8 | | | | Temporary loss | Amenity grassland | 0.094 | 940 | | Broad-leaved woodland | 0.023 | 233 | | | Tall ruderal | 0.011 | 114 | | | Semi-improved grassland | 0.008 | 82 | | | Hedgerow | 65 | | | | 250-500 m from GCN pond | | | | | Permanent loss | Amenity grassland | 0.01 | 102 | | Broad-leaved woodland | 0.021 | 213 | | | Hedgerow | 30 | | | | Temporary loss | Amenity grassland | 0.124 | 1235 | | Broad-leaved woodland | 0.037 | 373 | | | Semi-improved grassland | 0.003 | 26 | | | Tall ruderal | 0.019 | 191 | | | Hedgerow | 16 | | | C112246-D | D | at e | |---------------------------|-------------| | 00 | June 2012 | | D | r awn By | | Amenity grassland | | | SKS | | | 1:1,500 | | | Appr oved By | N | | Broad-leaved woodland | | | CB | - | | Hardstanding & structures | | | Semi-improved grassland | | | T | all ruderal | Triumph House, Birmingham Road, Allesley, Coventry CV5 9AZ T:01676 525880 F:01676 521400 E:admin@middlemarch-environmental.com $ © Esri, i-cube d, USDA, USGS, AEX, GeoEye, Getmappin g, Ae rogrid, IGN, IGP, and the GIS User Community Map to show location of receptor site in relation to development site. Triumph House, Birmingham Road, Allesley, Coventry CV5 9AZ T:01676 525880 F:01676 521400 E:admin@middlemarch-environmental.com $ © Esri, i-cube d, USDA, USGS, AEX, GeoEye, Getmappin g, Ae rogrid, IGN, IGP, and the GIS User Community Middlemarch Environmental Drawing C112246-Fig E3.1 Map to show habitat creation, restoration and enhancement. ## Legend Triumph House, Birmingham Road, Allesley, Coventry CV5 9AZ T:01676 525880 F:01676 521400 E:admin@middlemarch-environmental.com $ © Esri, i-cube d, USDA, USGS, AEX, GeoEye, Getmappin g, Ae rogrid, IGN, IGP, and the GIS User Community ## Legend Destructive search GCN exclusion fencing - perimeter pitfall traps & refugia on the inside GCN exclusion fencing - drift pitfall traps & refugia on either side Triumph House, Birmingham Road, Allesley, Coventry CV5 9AZ T:01676 525880 F:01676 521400 E:admin@middlemarch-environmental.com $ © Esri, i-cube d, USDA, USGS, AEX, GeoEye, Getmappin g, Ae rogrid, IGN, IGP, and the GIS User Community ## Legend Areas re-seeded with wildflower grassland Areas re-seeded as amenity grassland Triumph House, Birmingham Road, Allesley, Coventry CV5 9AZ T:01676 525880 F:01676 521400 E:admin@middlemarch-environmental.com $ © Esri, i-cube d, USDA, USGS, AEX, GeoEye, Getmappin g, Ae rogrid, IGN, IGP, and the GIS User Community # Middlemarch Environmental Ltd. QUALITY ASSURANCE WATERHOUSES SEWAGE TREATMENT WORKS, STAFFORDSHIRE GREAT CRESTED NEWT MITIGATION STRATEGY A Report to Severn Trent Water Ltd Contract Number: C112246 Report Number: RT-MME-112246 Revision Number: 00 Description: Final Date: July 2012 Checked by: David Smith Ecology and Landscapes Director Approved by: Dr Philip Fermor Managing Director
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## Material Requirements For Infrastructure Development Mr Son Quang Pham and Dr Michael Burrow University of Birmingham February 2018 ## About This Report The K4D Emerging Issues report series highlights research and emerging evidence to policy-makers to help inform policies that are more resilient to the future. K4D staff researchers work with thematic experts and DFID to identify where new or emerging research can inform and influence policy. K4D services are provided by a consortium of leading organisations working in international development, led by the Institute of Development Studies (IDS), with Education Development Trust, Itad, University of Leeds Nuffield Centre for International Health and Development, Liverpool School of Tropical Medicine (LSTM), University of Birmingham International Development Department (IDD) and the University of Manchester Humanitarian and Conflict Response Institute (HCRI). For any enquiries, please contact helpdesk@k4d.info. ## Suggested Citation Pham, Son Quang, and Burrow, Michael (2018) Material Requirements for Infrastructure Development. K4D Emerging issues Report. Brighton, UK: Institute of Development Studies. ## Copyright This report was prepared for the UK Government's Department for International Development (DFID) and its partners in support of pro-poor programmes. It is licensed for non-commercial purposes only. K4D cannot be held responsible for errors or any consequences arising from the use of information contained in this report. Any views and opinions expressed do not necessarily reflect those of DFID, K4D or any other contributing organisation. © DFID - Crown copyright 2018. ## Contents 1 Overview .................................................................................................................................. 1 2 Methodology ............................................................................................................................ 2 3 Financial requirements .......................................................................................................... 4 4 Aluminium ............................................................................................................................... 6 5 Cement ..................................................................................................................................... 9 6 Steel........................................................................................................................................ 11 7 Wood ...................................................................................................................................... 12 8 Human resource requirements ........................................................................................... 14 9 References ............................................................................................................................. 16 ## 1 Overview This literature review aims to identify published studies providing projections of the global demand for, and remaining stock of, materials important for construction that could be constraints to the development of infrastructure worldwide. Our review found very little evidence and few projections addressing this issue. Although a wide variety of materials could potentially constrain infrastructure development, in our research we were only able to identify good quality projections for four materials: aluminium, cement, steel, and wood. Estimates of the energy needs, water requirements and likely carbon emissions of mining and processing these resources are also provided. Demand for all of the materials we were able to study is projected to increase exponentially, along with related trends such as population and economic growth. Although this suggests the possibility of exhausting the available reserves of raw materials, it is highly likely that substitution of alternative materials, changes in construction techniques, and scarcity enabling the exploitation of formerly uneconomic reserves may help prolong reserves of commodities. We did not identify any commodities that appear to be in near-term short supply on a global aggregate basis, although local shortages of individual materials are quite possible. We also found several studies projecting the financial investment needed to meet the demand for infrastructure, so we have presented a summary of this information as well. We also attempted to estimate the skilled labour requirements in terms of the number of additional qualified consulting engineers which would be required to design and construct the additional road infrastructure required; we were unable to make similar estimates for other types of infrastructure due to limited information being available. Our key findings are: - The global infrastructure investment requirement for the period 2015-2030 is approximately $63 trillion (i.e. $3.9 trillion per year). This is an increase of about 56% of the current global infrastructure spend. - Global production of aluminium is growing exponentially at a rate of 4.1% per year (Menzie et al. 2010). Assuming no changes in techniques, this suggests that known bauxite reserves could be exhausted by 2055. - Global production of cement has been projected by the IEA (2009) to grow exponentially at a rate of 0.8% to 1.2% per year, but actual production has already far exceeded this projection due to high growth in emerging markets and developing countries. - Global production of steel is projected to grow exponentially at a rate of 1.4% per year (Accenture 2017). Assuming no changes in techniques, known iron ore reserves could be exhausted by 2070. - Global production of wood is projected to grow exponentially at a rate of 1.9% per year (Turner et al. 2006). Although wood is in principle a renewable resources, water stress appears likely to be an important constraint, as one source suggests that future wood production could require as much water as 29% of total current global water consumption (World Water Exchange 2016). | Materials | Cumulative | Energy | Water | CO | |-----------------------|---------------|------------|-----------|---------| | 2 | | | | | | | Energy | | | | | | | | | | | Water | | | | | | | | | | | | CO | | | | | | 2 | | | | | | | | | | | | per tonne of material | In total | | | | | material | | | | | | demand | | | | | | (billion | (kWh/t) | (Litres) | (kgCO | | | 2 | | | | | | ) | (TWh) | (Million | (Mt CO | | | 2 | | | | | | ) | | | | | | tonnes) | m | | | | | 3 | | | | | | ) | | | | | | Cement | | | | | | 50.1 | | | | | | (1) | | | | | | | 110 | 307 | 914 | 5,518 | | Steel | | | | | | 26.7 | | | | | | (2) | | | | | | | 5,700 | 28,500 | 2,000 | 152,147 | | Aluminium | | | | | | 1.7 | | | | | | (3) | | | | | | | 72,000 | 88,000 | 20,900 | 120,967 | | | | | | | | Total | | | | | | | | | | | | | 278,632 | 923,982 | 134,349 | | Source: (1) adapted from IEA, 2010; (2) adapted from Accenture, 2017; (3) adapted from Menzie et al., 2010. It should be emphasised that all of these projections have a high degree of uncertainty associated with them. ## 2 Methodology The review question lends itself to an unbiased aggregation approach where the aim of the study is to identify a sufficient number of studies that provide relevant forecasts. With sufficient resources, such an approach would ideally seek to identify all relevant literature, but in keeping with the resource constraints of this particular study, careful consideration was given to locating a sample of studies most pertinent to addressing the research question. This was achieved by carrying out a key word search of titles and abstracts of studies via internet based search engines and via accessing databases and the websites of specific organisations. Following the initial screening process the full text of pertinent studies were retrieved for further scrutiny. To be included in the scope, identified studies had to satisfy the following criteria: i. Resources: raw and processed physical materials and human resources used in the investment, design, construction and maintenance of physical infrastructure (airports, bridges, commercial and residential buildings, dams, energy extraction/generation facilities, freshwater, storm water and sewage infrastructure, ports, power stations, railways, roads and telecommunications) ii. Study design: Projections which determine the current and future resource requirements associated with planning, financing, building and maintaining infrastructure iii. Language: English language only. The review focused on identifying good quality studies which projected global demands, rather than those which focused on individual countries or groups of countries. The primary raw materials used for the construction of physical infrastructure include clays, gravels, rock, sands and wood. Processed materials primarily used for physical infrastructure include asphalt / bitumen (processed from petroleum but also found naturally), bricks (made from clays), cement (i.e. clay, limestone or calcium silicate), ceramics (primarily from clays), concrete (i.e. cement plus sands and gravels of various sizes and water), foam (synthetic polystyrene or polyurethane), glass (melted sand and silicates), metals (primarily aluminium from bauxite; iron and steel from iron ore), paper (from wood) and plastics. In our research, however, we were only able to identify good quality projections of the availability of four materials: aluminium, cement, steel and wood. Secondary sources of information were used to project the associated raw material requirements: bauxite for aluminium, limestone and clay for cement, and iron ore for steel. Estimates associated with the energy and water requirements and likely carbon emissions associated with mining and using these resources are also provided. The study utilised the following databases, websites and search engines: - Scopus - Web of Science - Google Scholar - Google - World Bank - Asian Development Bank - African Development Bank - OECD - New Climate Economy - FindIT.bham.ac.uk. ## 3 Financial Requirements The review of the literature found estimates of the total global infrastructure investment requirement for the period 2015-2030 at 2015 prices ranging between $21.8 trillion and $96.6 trillion. The average across all of the studies was $63 trillion, equivalent to an annual investment of about $3.9 trillion per year which is 50% more than current annual infrastructure spending of $2.5 trillion per year (McKinsey & Company, 2016). Figure 1 shows the global cumulative projected investment in infrastructure by different authors. All estimates have been converted to 2015 prices and adapted for the period 2015-2030; the red line shows the average investment value of the projections. Our review found six studies which estimated the investment needed for global infrastructure development (see Table 2). The studies apply a wide range of methodologies, estimate periods, definition of infrastructure, assumptions and scenarios. This results in significant differences in the projected infrastructure demand as well as the required investment to meet such demand. | Source | Global | |---------------------|-------------------| | Infrastructure | | | requirement | | | (annual) | | | Global | | | Infrastructure | | | requirement | | | (total) | | | GCEC, 2014 | | | $ 6 trillion/year | | | $96.5 trillion by | | | 2030 | | | | | | $ 5 trillion/year | $80.5 trillion by | | 2030 | | | Bhattacharya | | | et al., 2016 | | | | | | $ 1.2 trillion/year | $8.1 trillion by | | 2020 | | | Ruiz-Nuñez. & | | | Wei , 2015 | | | | | | $ 3.2 trillion/year | | | $19.2 trillion by | | | 2020 | | | Kennedy,& | | | Morlot ,2013 | | | | | | $3.5 trillion/year | $62.1 trillion by | | 2030 | | | McKinsey & | | | Company, | | | 2013 | | | | | | Dulac, 2013 | | | $ 3.2 trillion/year | | | $128.6 trillion by | | | 2050 | | | | | A study by The Global Commission on the Economy and Climate (GCEC) (2014) projects that the world will need to invest about $88.6 trillion in infrastructure by 2030 (i.e. $ 5.5 trillion per year). The study is based on a business-as-usual (BAU) scenario and assumes that there will be no new policy actions to address additional infrastructure which might be required to tackle the effects of climate change and the requirements for additional energy security. The projections were calculated at 2010 prices and derived from sectoral estimates provide by OECD (2006 and 2012), the International Energy Agency - IEA (2012), and the analysis by Climate Policy Initiative (The Global Commission on the Economy and Climate, 2014). The projection includes the investment for replacement, maintenance and construction for transport (road, rail, airport, and port), water supply and waste (for both human and agricultural use), energy (power generation, electricity transmission and distribution, fossil fuel supply chain, and energy end-use sectors) and | What is included | |-----------------------| | period | | 2015- | | 2030 | | New construction & | | maintenance for | | Transport, Water & | | waste, Energy & | | Telecoms | | 2015- | | 2030 | | New construction & | | maintenance for | | Transport, Water | | supply & sanitation, | | Energy, & Telecoms | | 2014- | | 2020 | | New construction & | | maintenance for | | Transport, Water | | supply & waste, | | Energy, & Telecoms | | 2015- | | 2020 | | New construction & | | maintenance for | | Transport, Water, | | Energy, & Telecoms | | 2013- | | 2030 | | New construction & | | maintenance for | | Transport, Water | | supply & waste, | | Energy, & Telecoms | | 2010- | | 2050 | | New construction & | | maintenance for road, | | railway and parking | | place | telecommunications infrastructure (fixed-line telephony and data, mobile telephony and data, broadband mobile communications). Bhattacharya et al (2016) estimate that between $75 trillion and $86 trillion (at 2015 prices) of investment is needed for new construction and maintenance of core infrastructure (including energy, transport, water supply & sanitation, and telecommunication) for the period 2015 to 2030. They made the calculation based on the average infrastructure investment spending in 2015 and assumptions of GDP growth and investment rates. The uncertainties in these assumptions are the major limitation of the report. Ruiz-Nuñez and Wei (2015) estimate that the required resource to satisfy new infrastructure demand while still maintaining existing global infrastructure will amount to $1.1 trillion (US$ 2011) or 2.2 percent of current world GDP per year over the period 2014 and 2020. To estimate the infrastructure investment demand Ruiz-Nuñez and Wei (2015) adopted Fay's (2000) model and Yepes (2008) methodology to develop a model in which infrastructure investment requirement is estimated to satisfy the customer and producer demand for services given an expected GDP growth rate. The GDP growth rates between 2014 and 2020 were predicted from the average GDP growth rates of the previous five years. McKinsey and Company (2013) projects global infrastructure needs through combining independent estimates of future needs by sector, including those of the OECD, IEA, and Global Water Intelligence (GWI). The report forecasts that $57 trillion, at 2010 prices, in global infrastructure investment will be required between 2013 and 2030. This figure includes the investment for transport, power, water and telecommunications infrastructure, with roads and power accounting for almost half of the demand. Similar to the above studies, McKinsey and Company's report suggest that the infrastructure investment requirement up until 2030 is greater than the estimated value of today's infrastructure worldwide. Similar studies were also conducted by Kennedy & Morlot (2013) and Dulac, (2013). While Kennedy & Morlot (2013) focus on a wide range of infrastructure categories (transport, energy generation, transmission and distribution, water, and telecommunication), Dulac, (2013) only calculates the needs for roads, railways and parking demands. As a whole, Kennedy, & Morlot (2013) forecast that the world will need an investment of $18.7 trillion for infrastructure by 2020. For the transport sector, Dulac (2013) estimates an investment of $120 trillion (US$ 2010) is required by 2050. ## 4 Aluminium Aluminium's strength to weight properties and its resistance to corrosion make it an important material for the construction infrastructure and transport (trains and aircraft). Due to its light weight and electrical conductivity, aluminium is also widely in electricity transmission. Approximately 26% of aluminium production is used for the construction sector in 2016 (Statista.com, 2018). The demand for aluminium is expected to continue to increase to match with the exponential growth in global population, the increasing trend in globalization and urbanization. Menzie et al. (2010) project that aluminium consumption by 2025 is likely to reach 120 million tonnes per year, representing a compound growth rate of 4.1 % per year. The growth rate is expected to relatively slow in high-income countries, but remain rapid in low and middle income countries. At this growth rate, aluminium production will double after 15 years and triple after about 23 years. Figure 2 shows actual and predicted aluminium production from 1994 to 2025. Utizling the Menzie et al. (2010) projection for the period 2015 to 2025 and extrapolating to 2030 the resulting accumulated aluminium demand is given in Figure 3. To meet this projected demand, the world will need to produce about 1.7 billion tonnes of aluminium by 2030. Typically four tonnes of bauxite is required to produce a tonne of aluminium (Ashraf, 2014; Australianbauxite.com, 2017). This means to produce 1.7 billion tonnes of aluminium by 2030, the world will need about 6.8 billion tonnes of bauxite. The total global bauxite reserves are estimated to be about 27.8 billion tonnes (The Bauxite Index, 2017). If the aluminium demand keeps growing at 4.1% per year, there are no significant changes in aluminium production technologies and no new bauxite reserves are found, current known world reserves of bauxite are likely to be exhausted by 2055. This projection is based on current trends continuing unchanged, but substitution, changes in construction techniques, and exploitation of formerly uneconomic reserves are likely to prolong reserves of bauxite. The production of a tonne of aluminium requires 72,000 kWh of energy (Rankin, 2012; Low-tech Magazine, 2014), 88 m3 water (Zygmunt, 2007) and results in 21 tonnes of CO2 (Rankin, 2012; Carbon Trust, 2011). To produce 1.7 billion tonnes of aluminium requires approximately 121,000 TWh of energy, 148 billion m3 water and result in about 35 billion tonnes of CO2. The annual average amount of energy required for aluminium production to 2030 is 5% of the entire global energy consumption in 2015 (Ritchie and Roser, 2017). The carbon emission resulting from aluminium production is about 2.2 billion tonnes per year to 2030, which is equivalent to about 6% of the global carbon emissions in 2015. ## 5 Cement Cement is an essential component of concrete, a fundamental material used in buildings, bridges, dams and roads. IEA (2009) suggests a cement production road map up to 2050 with two scenarios in which global cement demand may increase on average by 0.8% to 1.2% per year between 2006 and 2050, reaching between 3.7 and 4.4 billion tonnes per year in 2050. At the high demand growth rate, cement production would increase by 50% after about 30 years and double after 56 years. Figure 4 shows the actual and predicted global cement production between 1994 and 2050. The blue line presents actual cement production between 1994 and 2016 derived from USGS's database; the red and green lines show the range of cement demand projected by IEA (2010) between 2006 and 2050. Demand has in fact greatly exceeded IEA projections, possibly because IEA underestimated the growth of the cement market in emerging markets and developing countries. For instance, the projection suggests that China's cement production will peak in 2015 at nearly 1.7 billion tonnes per year, whereas USGS (2017) reported that actual cement production in China was approximately 2.4 billion tonnes in 2015 (i.e. 40% higher than the forecast). Unfortunately, we were unable to find other projections of global cement requirements. Adjusting IEA's estimate in the high-demand scenario for the period 2015 and 2030, the accumulated cement demand is calculated and shown in Figure 5. By 2030 the world is predicted to require the production of about 50 billion tonnes of cement. Typically about 1.65 tonnes of limestone and 0.4 tonnes of clay are quarried for each tonne of cement produced (British Geological Survey, 2005). This means to produce 50 billion tonnes of cement by 2030, there will be a need for about 83 billion tonnes of limestone and 20 billion tonnes of clay (see table 3). | Clay required | | Accumulated | |---------------------|----------|----------------| | cement demand | | | | Limestone per tonne | | | | of cement (*) | | | | Clay per tonne | | | | of cement (*) | | | | Limestone | | | | required | | | | (billion tonnes) | (tonnes) | (tonnes) | | 50.16 | 1.65 | 0.40 | To produce a tonne of cement requires about 110 kWh of energy (GNCS, 2017; IEA-ETSAP, 2010) and 307 litres of water (Lafarge, 2011; World Steel Association, 2015), and 914 kg CO2 are produced (GNCS, 2017; NRMCA, 2012). This means to meet the projected cement demand of 50 billion tonnes by 2030 about 5,518 TWh of energy, 15 billion m3 of water will be required, and 46 billion tonnes CO2 will be produced. Thus the annual average amount of energy required for cement production up until 2030 is 0.24% of the entire global energy consumption in 2015 i.e. 146,000 TWh, (Ritchie and Roser, 2017). As a result, between 2015 and 2030, the cement industry will create 2.9 billion tonnes of CO2 per year on average which is equivalent to 8.1% of the current global carbon emissions of 36 billion tonnes per year (Edgar, 2017). This share of carbon emission is similar to that reported by Andrew (2017) of 8% of global CO2 emissions per year. ## 6 Steel The world's steel consumption has more than doubled in the past twenty years, from 0.7 billion tonnes per year in 1994 to 1.6 billion tonnes per year in 2015 (USGS, 1996 & 2017). Steel demand is expected to grow at 1.4% per year, reaching about 2.0 billion tonnes per year by 2035 (Accenture, 2017). Construction is the largest steel-consuming sector, accounting for approximately 50% of global steel consumption (Lee and Dai, 2016). Error! Reference source not found. shows global actual steel production from 1994-2015 (blue line) and predicted steel production to 2035 (red line) according to a study by Accenture (2017). By 2030 the world will need a total of about 27 billion tonnes of new steel produced (Error! Reference source not found.). Producing 1 tonne of crude steel typically requires about 1.4 tonnes of iron ore (World Steel Association, 2016). To produce 27 billion tonnes of crude steel will require 37.4 billion tonnes of iron ore by 2030. According to The Statistics Portal (2017), world reserves of iron ore as of 2016 are approximately 170 billion tonnes. Therefore if steel demand keeps increasing at a rate of 1.4%, there are no significant changes in steel production technologies, and no new iron ore reserves are found, current known world reserves of iron ore may be exhausted by 2070. This projection is based on current trends continuing unchanged, but substitution, changes in construction techniques and exploitation of formerly uneconomic reserves are likely to prolong reserves of iron ore. Typically in order to produce a tonne of steel requires about 5,700 kWh of energy (Horvath, 2013; Rankin, 2012) and 28.5 m3 water (World Steel Association, 2015; Colla et al., 2017), and produces about 2 tonnes CO2 (Horvath, 2013; Rankin, 2012). Thus, producing 27 billion tonnes of steel requires about 152,000 TWh of energy, 761 billion m3 water, and results in about 53 billion tonnes of CO2. The annual average amount of energy required for steel production to 2030 is about 7% of the entire global energy consumption, 146,000 TWh, in 2015 (Ritchie and Roser, 2017), and the annual carbon emissions from steel production to the year 2030 may amount to about 3.3 billion tonnes per year, which is equivalent to about 9% of the global carbon emissions of 36 billion tonnes per year in 2015 (Edgar, 2017). ## 7 Wood The studies identified which project the requirement of wood do so in terms of the value of wood harvested or consumed, rather than the mass of wood. This measure has therefore been used in the report. The amount of energy required and carbon emissions produced as a result of wood production are not provided because of a lack of good quality studies, but the amount of water required to produce wood is estimated. Turner et al. (2006) report that global wood consumption value increased from US$348 billion per year in 1958 to US$597 billion per year in 2002. They also project that the wood consumption will continue to increase at 1.9% per annum, reaching US$1,023 billion per year in 2030. With this growth rate, global wood production value will double by 2038 (see Error! Reference source not found.). The construction sector accounts for about 25% of the global wood consumption (Ebohon and Rwelamila, 2001). Source: Turner et al., 2006 According to Turner et al. (2006), between 2015 and 2030 at total the world will need about 39.7 billion m3 of round wood; 7.9 billion m3 of sawn wood; 1.8 billion m3 of veneer/plywood; 2.5 billion m3 of particle board; and 1.5 billion m3 of fibrewood. To grow and process such an amount of wood, about 21.2 trillion m3 of water is required (see table 4). The annual average requirement for this is 29% of the global water consumption in 2015 of approximately 4.5 trillion m3 (World Water Exchange, 2016). | Type of Wood | Water required per | Product demand | |-----------------|-----------------------|-------------------| | m | | | | 3 (*) | | | | | | | | (m | | | | 3 | | | | ) | x 1000 m | | | 3 | | | | | Billion m | | | 3 | | | | | | | | Round wood | | | | 293 | 39,733,053 | 11,642 | | Sawn wood | | | | 580 | 7,921,641 | 4,595 | | veneer/ plywood | | | | 652 | 1,848,440 | 1,205 | | particleboard | | | | 847 | 2,524,682 | 2,138 | | Fiberwood | | | | 1093 | 1,494,787 | 1,634 | | Total | | | | | | | | 21,214 | | | Source: (*) Schyns et al. (2017) ## 8 Human Resource Requirements As requested, we attempted to estimate the human resource requirements (considering in this case only skilled engineers, rather than all labour requirements) to meet road construction needs until 2030. The assumptions made are presented in Table 3. We were unable to provide similar estimates for other infrastructure types due to a lack of reliable data. Based on figures provided by Dulac (2013), by 2030 the world will need to construct an additional of 14 million paved road lane‐km at a cost of $18.2 trillion. This will require about 17 million manyears of qualified engineer design input, or roughly 1.2 million person-years per year. This is about four times the total number of civil engineering jobs in the US in 2016 (which was 303,500; US Department of Labour, 2016)5 Additional Road (lane-km) 14,000,000 Average construction cost / km ($ million)1 1.30 Total capital costs ($ million) 18,200,000 Planning and Design Cost2 10% Avg. salary ($/year) 3 43000 Overhead cost /labour cost 4 150% Total person-years (2015-2030) 17,438,140 Annual person-years 1,162,543 1. Dulac, 2013 Grant (2017) reports that the average salary for engineering graduates, by country, ranges from $6,379 to $79,243 per year. 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Water: Expectation of Demand Outstripping Supply and Increasing Volatility *World water consumption* [online]. Available at: http://worldwaterexchange.com/about-us/ [Accessed 12 Dec. 2017] Yepes, Tito. (2008)*. Investment Needs for Infrastructure in Developing Countries 2008-15.* World Bank. Zygmunt, J. (2007). Hidden water: We consume a lot more water than we can even imagine, and our water footprints extend far beyond our own nation's boundary. London: Water wise. Available at: http://waterfootprint.org/media/downloads/Zygmunt_2007.pdf [Accessed 12 Dec. 2017]
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Proven Re-offending Statistics Quarterly Bulletin January to December 2009, England and Wales Ministry of Justice Statistics bulletin ## Contents Page Introduction 4 Executive Summary 7 15 Chapter 1 - Overall proven re-offending rates 22 Chapter 2 - Adult proven re-offending rates 26 Chapter 3 - Juvenile proven re-offending rates 30 Chapter 4 - Proven re-offending by index disposal (sentence type), Prison and Probation Trust 39 List of quarterly tables 42 Annex A: How the measure has changed and the effect of these changes 57 Appendix A: Glossary of terms Explanatory notes 64 . ## Introduction The Proven Re-offending Statistics Quarterly bulletin is a new Ministry of Justice publication which provides key statistics on proven re-offending in England and Wales. It gives proven re-offending figures for offenders, who were released from custody, received a non-custodial conviction at court, received a caution, reprimand, warning or tested positive for opiates or cocaine between January and December 2009. Proven re-offending is defined as any offence committed in a one year follow-up period and receiving a court conviction, caution, reprimand or warning in the one year follow up or a further six months waiting period. This is referred to as a proven re-offence. This report merges 6 previous measures of re-offending which were split across many publications into a single coherent overview of proven reoffending for the first time. It is a significant step forward for measuring reoffending as for the first time users can:  get figures for the total number of proven re-offenders in an area and the total number of offences they commit in a year;  see re-offending rates for adults, juveniles, drug misusing and prolific offenders measures on a consistent basis both nationally and locally;  measure individual prison and probation level re-offending on a consistent basis. This report presents the proportion of offenders who re-offend (proven reoffending rate) and the number of proven re-offences those offenders commit by age group, gender, ethnicity, criminal history, offence type, serious proven re-offending, prolific and priority offenders and drug misusing offenders. Also included are proven re-offending rates for different types of sentence and by individual prison, probation trust and youth offending team. Latest figures for 2009 are provided with comparisons to 2008, results are also compared to 2000 to highlight long-term trends; 2000 is the earliest reoffending data that exists on a comparable basis. The accompanying 'Definitions and Measurement' document gives more information. www.justice.gov.uk/publications/statistics-and-data/reoffending/provenreoffending-quarterly.htm Measuring proven re-offending There is no agreed international standard for measuring and reporting reoffending. An offender's journey through the justice system can be a complex one; offenders can appear on numerous occasions. Measuring true re-offending is difficult. Official records are taken from either the police or courts, but they will underestimate the true level of re-offending because only a proportion of crime is detected and not all crimes are recorded on one central system. Other methods of measuring re-offending, such as self report studies, are likely to be unreliable. Therefore this report aims to measure proven re-offending. Since re-offending is now measured on a consistent basis across all groups it is possible to tailor analysis of re-offending to meet specific requirements. This report and the accompanying 'Early Estimates of proven re-offending' www.justice.gov.uk/publications/statistics-and-data/reoffending/provenreoffending-quarterly.htm present measures on three different levels to meet users needs:  The headline measure - this is the main measure of re-offending and is presented for different demographic groups and by offence. To provide this **overview of proven re-offending**, offenders are tracked and their proven re-offending behaviour is recorded, taking the **first event**1 in the **relevant period** as the start point and subsequent events as proven re-offences.  A headline measure where the first event is related to criminal justice and offender management - this provides a realistic and relevant view of proven re-offending by disposal (sentence type), prison and probation trust. Offenders are tracked and their proven re-offending behaviour is recorded **within** each disposal (caution, court order, discharge from prison, etc) or operational unit (prison or probation trust) taking the first event **within** each as the start point and subsequent events as re-offences.  Early estimates of re-offending - these use shorter follow-up and waiting periods but otherwise measure re-offending in exactly the same way as the headline measure. This is intended to provide offender managers feedback on the proven re-offending trends of offenders they are working with in time for them to adjust or build on offender management operational policy. For a more detailed explanation, please see the accompanying 'Definitions and Measurement' document at www.justice.gov.uk/publications/statisticsand-data/reoffending/proven-reoffending-quarterly.htm Differences in data compared to previous publications This new measure has been developed in response to public consultation (see below). It is a single measure of proven re-offending which reflects the need to provide a complete picture of re-offending which is easily understood by all. The new framework creates far more flexibility to break the data down into offender groups of interest. As such, this measure is substantially different from the previous National Statistics on adult re-convictions and juvenile re-offending. These differences are mainly due to:  the inclusion of a wider range of offenders  measuring re-offending based on offenders identified across a whole year rather than only one quarter of a year  measuring proven re-offending for all offenders rather than just reconvictions for adults For more detail and a summary of the differences between the results please refer to Annex A Consultation This report has been developed in response to a consultation in late 2010 and early 2011 by the Ministry of Justice on "Improvements to Ministry of Justice Statistics". The main points from the consultation that affect this publication can be found in Annex A. Users The contents of the report will be of interest to government policy makers, the agencies responsible for offender management at both national and local levels, providers, practitioners and others who want to understand more about proven re-offending. In particular there are two Ministry of Justice impact indicators2 which will be monitored using results from this report;  adult and juvenile re-offending - the percentage of adult and juvenile offenders who re-offend, measured quarterly by local authority  the percentage of adults released from custody who re-offend measured annually, by prison Government policy makers also use these statistics to develop, monitor and evaluate key elements of its policies including those on payments by results, legal aid, sentencing guidelines and drug and alcohol policies. Offender management agencies use these statistics to gain a local understanding of the criminal justice system, understand performance and to highlight best practice. Key agencies include; the National Offender Management Service, Youth Justice Board, private and voluntary sector providers of prison and probation services and local authorities. As proven re-offending is related to the characteristics of offenders, the actual rate of proven re-offending will depend, in part, on the characteristics of 2 www.justice.gov.uk/publications/corporate-reports/moj/index.htm This is a new bulletin produced in response to a consultation. The MOJ has addressed the main issues from the consultation. We have separately announced plans for further analysis on proven re-offending rates using a two year follow up period and to develop a measure of re-offending while on license under probation supervision for publication in May 2012. If you have any feedback, questions or requests for further information about this statistical bulletin, please direct them to the appropriate contact given at the end of this report. Executive Summary This report provides key statistics on proven re-offending in England and Wales. It gives proven re-offending figures for offenders who were released from custody, received a non-custodial conviction at court, received a caution, reprimand, warning or tested positive for opiates or cocaine between January and December 2009. Proven re-offending is defined as any offence committed in a one year follow-up period and receiving a court conviction, caution, reprimand or warning in the one year follow up. Following this one year period, a further 6 months is allowed for cases to progress through the courts. Between January and December 2009, there were just under 700,0003 offenders who were cautioned4, convicted (excluding immediate custodial sentences) or released from custody5. Just over 180,000 of these offenders committed a proven re-offence within a year. This gives a one-year proven reoffending rate of 26.3 per cent. These re-offenders committed an average of 2.79 offences each - around 510,000 offences in total - 79 per cent were committed by adults and 21 per cent were committed by juveniles. - Just over half of these offences were committed by offenders with 11 or more previous offences. - 0.7 per cent (around 3,400) were serious violent/sexual proven reoffences. Recent Changes Between 2008 and 2009, the proven re-offending rate decreased slightly from 26.9 per cent to 26.3 per cent. This trend held across most sub-groups looked at. Between 2008 and 2009, the average number of proven re-offences per reoffender decreased by 3.3 per cent from 2.89 to 2.79. quarterly.htm This means that numbers of offenders in this bulletin will be different from the numbers published in the Offender Management Caseload Statistics www.justice.gov.uk/publications/statistics-and-data/prisons-and-probation/oms-quarterly.htm. and Criminal Justice Systems statistics www.justice.gov.uk/publications/statistics-anddata/criminal-justice/criminal-justice-statistics.htm 4 Includes reprimands and warnings for juveniles 5 Also includes those who tested positive for opiates or cocaine Percentage change 2008 to 20091 Percentage change 2000 to 20091 2000 2008 2009 All Offenders Proportion of offenders who re-offend (%) Average number of re-offences per re-offender Proportion of offenders who re-offend - Adjusted to baseline2 (%) (predicted Average number of re-offences per offender (frequency rate) Number of re-offences Number of re-offenders Number of offenders in cohort 27.9 26.9 26.3 -1.6pp ↓ -0.6pp ↓ 3.37 2.89 2.79 -17.3% ↓ -3.3% ↓ 25.5 26.9 27.1 - - 0.94 0.78 0.73 -21.9% ↓ -5.6% ↓ 579,770 571,469 511,668 -11.7% ↓ -10.5% ↓ 171,935 197,958 183,382 6.7% ↑ -7.4% ↓ 617,024 735,527 697,362 13.0% ↑ -5.2% ↓ Proportion of offenders who re-offend (%) Average number of re-offences per re-offender Proportion of offenders who re-offend - Adjusted to baseline2 (%) (predicted Number of re-offences Average number of re-offences per offender (frequency rate) Number of re-offenders Number of offenders in cohort Adult offenders 26.2 25.4 24.9 -1.2pp ↓ -0.5pp ↓ 3.39 2.93 2.80 -17.4% ↓ -4.4% ↓ 23.6 25.4 25.7 - - 0.89 0.75 0.70 -21.3% ↓ -6.3% ↓ 423,989 439,539 402,409 -5.1% ↓ -8.4% ↓ 125,023 150,067 143,715 15.0% ↑ -4.2% ↓ 477,698 589,948 576,255 20.6% ↑ -2.3% ↓ Proportion of offenders who re-offend (%) Average number of re-offences per re-offender Proportion of offenders who re-offend - Adjusted to baseline2 (%) (predicted Average number of re-offences per offender (frequency rate) Number of re-offences Number of re-offenders Number of offenders in cohort Juvenile offenders 33.7 32.9 32.8 -0.9pp ↓ -0.1pp ↓ 3.32 2.75 2.75 -17.1% ↓ 0.0% → 32.0 32.9 33.5 - - 1.12 0.91 0.90 -19.3% ↓ -0.4% ↓ 155,781 131,930 109,259 -29.9% ↓ -17.2% ↓ 46,912 47,891 39,667 -15.4% ↓ -17.2% ↓ 139,326 145,579 121,107 -13.1% ↓ -16.8% ↓ 1. pp = percentage point and percentage changes may not add up due to rounding of raw figures 2. See the definitions and measurement paper for an explanation on how to use and interpret the predicted rate. ## Longer Term Changes In The Longer Term, Between 2000 And 2009, The Proven Re-Offending Rate Fell Overall From 27.9 Per Cent To 26.3 Per Cent. The Rate: - fell a similar amount for both adults and juveniles - fell for offenders commencing court orders, for offenders discharged from prison, for those given reprimands, warnings and first tier penalties6, but rose for cautions, fines, discharges and youth community penalties. - fell for offenders aged 15 to 29 and rose for all other age groups. - fell more for adult women (-2.5 percentage points) than adult men (-0.8 percentage points). Between 2000 and 2009 the average number of proven re-offences per reoffender fell from 3.37 to 2.79, a fall of 17.3%. Re-offending by age In 2009, as in previous years, 15 to 17 year olds had the highest proven reoffending rate at 34.3 per cent (Table 3). The proven re-offending rate falls with increasing age (after 15-17) as shown in Figure 1. Between 2000 and 2009, the proven re-offending rate rose for 10-14 year olds and for those aged 30 or more, but fell for offenders aged 15 to 29. The largest decreases in the average number of re-offences per re-offender were among those aged in the 21-24 age group (of around 25 per cent). Previous offences Offenders with a large number of previous offences have a higher rate of proven re-offending and this is true for both adults and juveniles. Compared to 2000 the largest decrease in the proven re-offending rate was among offenders who had 7 or more previous offences (-3.8 percentage points):  Adult offenders with 11 or more previous offences represented just over a quarter (27.8 per cent) of adult offenders in 2009 but committed almost two thirds of all adult proven re-offences.  For juveniles, there were 5,800 offenders with 11 or more previous offences and they had a proven re-offending rate of 76.8 per cent. This group make up only 4.8 per cent of juvenile offenders in 2009 but committed almost a fifth of all juvenile proven re-offences. Re-offending by Index offence The offence that leads to a offender being included in the relevant year is called the index offence. In 2009, as in most previous years, domestic burglary had the highest proven re-offending rate at 48.1 per cent (Table 5c) with sexual (child) offences the lowest at 9.8 per cent. The largest decrease between 2000 and 2009 in the proven re-offending rate was for soliciting and prostitution, a decrease of 18.6 percentage points while other motoring offences had the second largest decrease of 9.7 percentage points. Adult proven re-offending In 2009, there were around 580,000 adult offenders3. Just over 140,000 of these offenders were proven to have committed a re-offence within a year. This gives a one year proven re-offending rate of 24.9 per cent. The average number of proven re-offences committed by these re-offenders was 2.80. Since 2008, there has been a slight decrease in the proven re-offending rate of 0.5 percentage points from 25.4 per cent. Overall there was a 1.2 percentage point decrease in the proven re-offending rate between 2000 and 2009 (from 26.2 to 24.9 per cent). However compared to 2000 the offenders in 2009 had characteristics which meant they were more likely to re-offend. This means that after controlling for offender characteristics the decrease was larger at 3.4 percentage points. ## Proven Re-Offending Rates For Offenders Discharged From Prison Or Commencing A Court Order In 2009, There Were Around 200,000 Adult Offenders3 Who Were Discharged From Prison Or Commenced A Court Order. Just Over 72,000 Of These Offenders Were Proven To Have Committed A Proven Re-Offence Within A Year. This Gives A One Year Proven Re-Offending Rate Of 36.2 Per Cent. The Average Number Of Proven Re-Offences Committed By These Re-Offenders Was 3.27. Overall There Was A 4.7 Percentage Point Decrease (From 40.9 To 36.2) In The Proven Re-Offending Rate Between 2000 And 2009 And A 20.8 Per Cent Decrease (From 4.13 To 3.27) In The Average Number Of Proven Re-Offences Per Re-Offender. Prisoner's proven re-offending In 2009, around 64,000 adult offenders3 were discharged from custody. Just under 30,000 of these (46.8 per cent) were proven to have committed a proven re-offence within a year. These offenders committed around 120,000 proven re-offences, an average of 4.03 each. Almost 55 per cent of adult offenders discharged from custody were released from sentences of less than 12 months. These offenders had a one year proven re-offending rate of 56.8 per cent an increase of 2.6 percentage points from 2000 (54.3 per cent) Proven re-offending of adults starting court orders In 2009, just under 110,000 adult offenders3 started a community order. Around 39,000 of these (35.6 per cent) committed a proven re-offence within a year. These proven re-offenders committed just under 123,000 proven reoffences, an average of 3.15 proven re-offences each. Similarly, of the 37,000 adult offenders starting a suspended sentence order, 31.0 per cent committed a proven re-offence within a year, committing an average of 2.86 proven reoffences each. Juvenile proven re-offending In 2009, there were just 120,000 juvenile offenders. Just under 40,000 of these offenders were proven to have committed a proven re-offence within a year. This gives a one year proven re-offending rate of 32.8 per cent. The average number of proven re-offences committed by these re-offenders was 2.75. Since 2008, there has been a very slight decrease in the proven re-offending rate of 0.1 percentage points from 32.9 per cent. Overall there was a 0.9 percentage point decrease in the proven re-offending rate between 2000 and 2009 (from 33.7 to 32.8 per cent). Compared to 2000 the characteristics of the offenders meant that they were more likely to reoffend in 2009 therefore after controlling for offender characteristics this was a decrease of 2.5 percentage points. Prolific and Priority Offenders (PPO) Around 8,000 offenders (adult and juvenile) were on the PPO scheme at some point during 2009. Of these just over 6,000 committed a proven reoffence within a year (75.1 per cent). These offenders represented 1.2 percent of all offenders but were responsible for 5.6 per cent of all proven reoffences committed. The proportion of PPO offenders who committed a proven re-offence decreased by 2.1 percentage points between 2008 and 2009. This compares to a decrease of 1.9 percentage points since the scheme began in 2005. Drug Misusing Offenders (DMO) Around 53,000 adult offenders were identified as drug misusers at some point during 2009. Of these just over 29,000 committed a proven re-offence within a year (54.7 per cent). These offenders represented 9.2 percent of all adult offenders but were responsible for 27.8 per cent of all proven re-offences committed. The proportion of drug-misusing offenders who committed a proven re-offence fell slightly between 2008 and 2009 (1.7 percentage points). Looking longer term there was a decrease of 10.6 percentage points between 2005 and 2009, although most of this change occurred between 2005 and 2006 when there was a large expansion in the drug intervention programme. Iain Bell Chief Statistician Chapter 1 - Overall proven re-offending rates One of the key changes from previous publications is that we can now present overall proven re-offending rates for offenders aged 10 years and over. Adult and juvenile re-offending rates are presented in subsequent sections. Between January and December 20097, there were just under 700,000 offenders1 who were cautioned8, convicted (excluding immediate custodial sentences) or released from custody. Just over 180,000 of these offenders were proven to have committed a proven re-offence within a year. This gives a one-year proven re-offending rate of 26.3 per cent. These re-offenders committed an average of 2.79 offences each (around 510,000 offences in total) (Table 1). Overall, the one year proven re-offending rate fell by 1.6 percentage points from 27.9 per cent in 2000 to 26.3 per cent in 2009. Between 2008 and 2009 the re-offending rate fell slightly by 0.6 percentage points from 26.9. An adjusted proven re-offending rate based on the 2008 cohort has been developed to control for changes in the composition of the relevant year group which could affect the estimates. It can be applied back to 2000 to measure progress between 2000 and 2009 in the proven re-offending rate after controlling for changes in offender characteristics.9 Compared to 2000 the offenders in 2009 had characteristics which meant they were more likely to re-offend. This means that after controlling for offender characteristics the decrease in the overall one year proven reoffending rate was larger at 3.2 percentage points. Between 2000 and 2009, the overall number of offenders rose by 13 percent, from just under 620,000 in 2000 to just under 700,000 in 2009, while the number of proven re-offences fell by 11.7 per cent, from around 580,000 in 2000 to just above 510,000 in 2009. The rise in the number of offenders was primarily driven by an increase among adult offenders with an index offence of non-serious violence which has more than doubled from just under 66,000 in 2000 to around 140,000 in 2009, and among offenders who received a caution with an increase of nearly 50 per cent from just over 140,000 in 2000 to just over 210,000 in 2009. The fall in the number of proven re-offences was mainly a result of a fall in the number of proven re-offences committed by juvenile offenders which fell by almost a third (30 per cent), compared to adult offenders, where the number of proven re-offences fell by 5.1 per cent. Between 2000 and 2009 the average number of proven re-offences per reoffender fell from 3.37 to 2.79. ## Age In 2009, as in previous years, 15 to 17 year olds had the highest proven reoffending rate at 34.3% (Table 3). The proven re-offending rate falls with increasing age (after 15-17) as shown in Figure 3. Between 2008 and 2009, there was a slight decrease in the proven reoffending rate for most age groups apart from those aged 15-17 or 45 and over, whose re-offending rates rose slightly. Among those offenders who committed a proven re-offence the average number of proven re-offences fell for offenders aged 15-50 but rose for offenders aged 50 or more. Over the longer-term, between 2000 and 2009, the proven re-offending rate rose for 10-14 year olds and for those aged 30 or more, but fell offenders aged 15 to 29. The largest decreases in the average number of re-offences per re-offender were among those aged in the 21-24 age group (of around 25 per cent). Gender Among the offenders in 2009, 80 per cent (around 560,1003) were males and 20 per cent (around 140,000) were females. Just under 160,000 male offenders were proven to have committed a proven re-offence within a year - a proven re-offending rate of 28.3 per cent, which was higher than for females (18.3 percent or around 26,000 females). This difference was true for both adults (26.7 per cent compared with 17.3 per cent) and for juveniles (36.9 per cent compared to 21.6 per cent), and is similar to previous years. (Table 2) However, on average both male and female adult offenders commit a similar number of proven re-offences each within a year (2.82 and 2.70 on average). Male juveniles, on average, commit slightly more proven re-offences than female juveniles (2.84 compared to 2.38). Previous offences Offenders with a large number of previous offences have a higher rate of proven re-offending and this is true for both adults and juveniles. (Table 6) Compared to 2000 the largest decrease in the proven re-offending rate was among offenders with 7 to 10 previous offences and those with 11 or more previous offences (-3.8 percentage points):  46.5 per cent of adult offenders with 11 or more previous offences committed a proven re-offence within a year, compared with 8.7 per cent of those who had no previous offences.  Adult offenders with 11 or more previous offences represented just over a quarter (27.8 per cent) of offenders in 2009 but committed almost two thirds of all proven re-offences.  For juveniles, there were 5,800 offenders with 11 or more previous offences and they had a proven re-offending rate of 76.8 per cent. This group make up only 4.8 per cent of juvenile proven offenders in 2009 but committed almost a fifth of all re-offences. Trends in proven re-offending across the country Map 1 shows proven re-offending rates by Upper Tier Local Authority. This chart is not controlled for the characteristics of offenders and is designed for users to gain an understanding of what the level of proven re-offending is in their area and how it is changing over time. When comparing between Local Authorities, the differences may be due to:  different types of offenders; areas where the offenders have high numbers of previous offences are likely to have higher proven re-offending rates  police activity; areas with high police detection rates are likely to have higher proven re-offending rates  age profile of offenders in the area; areas with a younger population are likely to have higher proven re-offending rates. When comparing proven re-offending over time within Local Authorities, any significant changes in these factors may affect the comparison. Very few local authorities have shown substantial change compared to the same period last year. The largest decrease was seen in York (4.3 percentage points), the largest increase was in Darlington (4.5 percentage points). (Table 13) ## Serious Proven Re-Offending Serious Violent/Sexual Re-Offences10 The Proportion Of Offenders Who Committed A Serious Violent/Sexual Proven Reoffence Is Very Small; Around 3,100 Out Of Just Under 700,000 Proven Offenders3 (0.4 Per Cent) Committed A Serious Re-Offence. Just Over 3,400 Serious Violent/Sexual Proven Re-Offences Were Committed. (Table 8) Serious Acquisitive Re-Offences11 The proportion of offenders who committed a serious acquisitive proven reoffence is small; out of just under 70,000 offenders3, around 18,000 (2.7 per cent) committed a serious acquisitive proven re-offence. Just over 27,000 serious acquisitive proven re-offences were committed. The proportion of juvenile offenders who committed a serious acquisitive reoffence was notably higher than for adult offenders (5.4 per cent (around 10,000) compared to 2.1 per cent (around 17,000)). Compared to 2000 the proportion of offenders who committed a serious acquisitive offence fell for both adults and juveniles. However, since 2008 there has been a slight increase for juvenile offenders, although the proportion of offenders who committed a serious re-offence remains low. All serious re-offences The proportion of offenders who committed a serious proven re-offence is just under 22,000 out of just under 700,000 proven offenders3 (3.1 per cent) committed a serious re-offence. Just under 30,000 serious proven re-offences were committed. Chapter 2 - Adult proven re-offending This section provides proven re-offending rates for adults with a section for juveniles to follow. In 2009, there were around 580,000 adult offenders3. Just over 140,000 of these offenders were proven to have committed a proven reoffence within a year. This gives a one year proven re-offending rate of 24.9 per cent. The average number of proven re-offences committed by these reoffenders was 2.80. (Table 1) Changes between 2008 and 2009 Overall there was a 0.5 percentage point decrease (from 25.4 to 24.9) in the proven re-offending rate between 2008 and 2009 and a 4.4 per cent decrease (from 2.93 to 2.80) in the average number of proven re-offences per reoffender. Between 2008 and 2009 the proven re-offending rate remained broadly stable for most groups. The largest changes were seen in the following groups:  those with 11 or more previous offences, a fall of 1.3 percentage points.  offenders with an index offence of domestic burglary (-3.2 percentage points), soliciting and prostitution (+2.4 percentage points) and theft from vehicles (-3.6 percentage points)  offenders discharged from custody, a fall of 2.4 percentage points Changes between 2000 and 2009 Overall there was a 1.2 percentage point decrease (from 26.2 to 24.9) in the proven re-offending rate between 2000 and 2009 and a 17.4 per cent decrease (from 3.39 to 2.80) in the average number of proven re-offences per re-offender. Using the adjusted proven re-offending rate to control for changes in the composition of the relevant year group there was a reduction of 3.4 percentage points in the proven re-offending rate12. The average number of proven re-offences per re-offender fell more steeply than the proportion who re-offended due to the large fall in proven reoffending among the most prolific offenders. Between 2000 and 2009, the following groups showed the largest changes in proven re-offending rates:  young adults aged 18-24, a fall of 2.9 percentage points  females, a fall of 2.5 percentage points  those with 11 or more previous offences, a fall of 3.4 percentage points.  offenders with an index offence of domestic burglary (-10.7 percentage points), taking and driving away (-11.2 percentage points), soliciting and prostitution (-18.5 percentage points) and other offences (+7.7 percentage points)  offenders commencing court orders, a fall of 3.4 percentage points  offenders discharged from custody, a fall of 2.6 percentage points Comparison with previous measure The new adult proven re-offending rate includes all people who were released from custody, received a non-custodial conviction at court, or received a caution13 in a full year not just those who started a community sentence or were released from prison in the first quarter of the year (as previously). The previous adult re-conviction measure shows that the one-year reconviction rate among those starting a community sentence or being released from custody was 39.3% in 2009 and had fallen by 0.8 percentage points since 2008 and 3.7 percentage points since 2000 .When controlling for changes in the offender mix this change from 2000 was 4.6 percentage points. Therefore although the proportion identified as re-offenders was higher in the old measure, the trends are similar between both measures. Comparisons between levels of re-offending among those discharged from prison or those starting Court Orders are also broadly similar between both measures. Please see Annex A for more details on the differences between the old measure and the new measure of re-offending. Index offence type Table 5a shows that among adults, the highest proportion of offenders who committed a proven re-offence had an index offence of theft from vehicles (a proven re-offending rate of 47.7 per cent), domestic burglary (47.4 per cent) and other burglary (48.1 per cent). The offences with the lowest proven reoffending rates were sexual (child) offences (9.3 per cent), drink driving (12.0 per cent) and fraud and forgery (14.0 per cent). (Table 5a) For certain index offences the proven re-offending rate has increased since 2000. The largest increase was for those with a first offence of 'other' - driven by the introduction of Anti-Social Behaviour Orders (ASBO) which when breached lead to a conviction. There were also rises in proven re-offending rates for those with an index offence of sexual offences, public order, theft from vehicles, drugs possession/small scale supply and criminal and malicious damage. Re-offence type Table 10 shows that for adult offenders the most common proven re-offence type was theft (23.0 per cent of all proven re-offences) and the second most common was non-serious violence (14.9 per cent). The proportion of all proven re-offences which were non-serious violence showed the largest overall increase compared to 2000 (6.6 percentage points from 8.2 to 14.9 of all proven re-offences). The proportion of proven offences which were other motoring offences showed the largest overall decrease since 2000 (9.4 percentage points). This is consistent with findings from the Criminal Justice System Statistics Quarterly. www.justice.gov.uk/publications/statistics-and-data/criminal-justice/index.htm In 2009, just under a third (29.3%) of proven re-offences were in the same offence category as the index offence. The categories with the largest proportion in the same category were theft (51.6 per cent), motoring offences (34.2 per cent), sexual offences (31.4 per cent) and public order (31.3 per cent). (Table 11) Chapter 3- Juvenile proven re-offending In 2009, there were just over 120,0003 juvenile offenders, of whom 32.8 per cent (around 40,000) committed a proven re-offence within one year. Those who committed a proven re-offence committed an average of 2.75 proven reoffences each, just under 110,000 proven re-offences in total. (Table 1) Changes between 2000 and 2009 Overall, there was a 0.9 percentage point decrease (from 33.7 to 32.8) in the proven juvenile re-offending rate between 2000 and 2009 and a 17.1 per cent decrease (from 3.32 to 2.75) in the average number of proven re-offences per re-offender. Between 2000 and 2009, the following groups saw the largest changes in proven re-offending rates: - Offenders aged 15-17, a fall of 2.1 percentage points - Juvenile Offenders with 11 or more previous offences (-5.4 percentage points) and 1-2 previous offences (-5.2 percentage points) - offenders with an index offence of taking and driving away, motoring and drink driving all showed decreases of around 7 percentage points, whereas those offenders with an index offence of 'other' increased by 12.7 percentage points - offenders who had an first tier penalty index disposal or were discharged from custody showed a decrease of around 6 percentage points whereas offenders commencing a youth community penalty showed an increase of 5 percentage points Using the adjusted proven re-offending rate to control for changes in the composition of the relevant year group there was a reduction of 2.5 percentage points in the proven re-offending rate14 between 2000 and 2009. Changes between 2008 and 2009 Compared to 2008 the level of juvenile proven re-offending has remained stable, 32.9 per cent compared to 32.8 per cent in 2009. The average number of proven re-offences per re-offender also remained stable at 2.75. However, the number of juvenile proven offenders has decreased by 16.8 per cent. This is in line with the pattern of first time entrants to the criminal justice system where the number of young people receiving their first reprimand, warning or conviction has also decreased. More information on first time entrants for both adults and juveniles can be found in the Criminal Justice System Statistics Quarterly at www.justice.gov.uk/publications/statistics-and-data/criminal-justice/index.htm The proven re-offending rate remained broadly stable for most juvenile groups between 2008 and 2009. Comparison with previous juvenile measure The new juvenile proven re-offending rate includes all people who were released from custody, convicted at court, or received a reprimand or warning in a full year not just those in the first quarter of the year (as previously). The previous juvenile re-offending measure showed that one year reoffending rates among those convicted, cautioned or discharged from prison in the first quarter of the year were 36.9% in 2009 and had fallen by 0.4 percentage points since 2008 and 3.3 percentage points since 2000. After controlling for changes in the offender mix this change on the previous measure was 4.0 percentage points since 2000. These figures are broadly similar to those based on the new measure. Please see Annex A for more details on the differences between the old measure and the new measure of re-offending. Index offence type Among juveniles, the highest proportion of offenders who committed a proven re-offence had an index offence in the categories of absconding or bail offences (a proven re-offending rate of 64.7 per cent), domestic burglary (49.9 per cent) and other (42.4 per cent). With the exception of sexual (child) offences, the proportion committing a proven re-offence was higher than 20 per cent for every index offence category. (Table 5b) Compared to 2000, there were a number of categories of index offence that showed an increase in the proportion who commit a re-offence. The largest increase was 'other' (12.7 per cent). As was the case for adult offenders, this increase is mainly the result of the introduction of Anti-Social Behaviour Orders (ASBO) which, when breached, lead to a conviction. Re-offence type For juveniles the most common proven re-offence was non-serious violence (20.2 per cent) and the second most common was theft (15.9 per cent). (Table 15) As was the case for adults, the proportion of proven re-offences which were non-serious violence showed the largest overall increase compared to 2000 (7.9 percentage points). In 2009, 22.0 per cent of proven re-offences were in the same offence category as the index offence. The categories with the largest proportion in the same category were theft (28.5 per cent) and non-serious violence (30.3 per cent). Chapter 4- Proven re-offending by index disposal (sentence type), prison and Probation Trust As described in the Introduction, this section presents measures of reoffending related to criminal justice and offender management. To provide a realistic and relevant view of proven re-offending by disposal (sentence type) or prison or probation trust, offenders are tracked and their proven reoffending behaviour is recorded **within** each disposal (caution, court order, discharge from prison, etc) or operational unit (prison or probation trust) taking the first event **within** each as the start point and subsequent events as reoffences. Please see 'Definitions and Measurement' for more details. www.justice.gov.uk/publications/statistics-and-data/reoffending/provenreoffending-quarterly.htm Proven re-offending by index disposal (sentence type) The disposal (sentence type) that leads to an offender being included in the relevant year is called the index disposal. This can be an out of court disposal such as a caution15, court conviction (excluding immediate custodial sentences) or discharge from custody that occurs in the relevant period16. Reoffending rates by disposal (sentence type) should not be compared to assess the effectiveness of sentences, as there is no control for known differences in offender characteristics and the type of sentence given. The Compendium of Re-offending Statistics and Analysis 2011 compares like for like offenders which enables a more reliable comparison of proven re-offending rates between offenders receiving different sentences. The key results from the Compendium were:  those sentenced to 1 to 2 years in custody had lower re-offending rates than those given sentences of less than 12 months - the difference was 4.4 percentage points in 2008  custodial sentences of less than 12 months were less effective at reducing re-offending than both community orders and suspended sentence orders - between 5 and 9 percentage points in 2008. www.justice.gov.uk/publications/statistics-and-data/reoffending/compendiumof-reoffending-statistics-and-analysis.htm Proven re-offending rates for offenders discharged from prison or commencing a court order The previous measure of adult re-convictions was based on offenders discharged from prison or commencing court orders under probation supervision, i.e. they were or had been in contact with offender management agencies in the relevant year. This section looks at this specific group of offenders. However these results will not be directly comparable with the previous measure. This is because the new measure is based on proven reoffending rather than re-conviction and uses a full year of offenders instead of the first quarter (see Annex A) In 2009, there were around 200,000 adult offenders3 who were discharged from prison or commenced a court order. Just over 72,000 of these offenders were proven to have committed a proven re-offence within a year. This gives a one year proven re-offending rate of 36.2 per cent. The average number of proven re-offences committed by these re-offenders was 3.27. Overall there was a 4.7 percentage point decrease (from 40.9 to 36.2) in the proven re-offending rate between 2000 and 2009 and a 20.9 per cent decrease (from 4.13 to 3.27) in the average number of proven re-offences per re-offender. ## Prison Or Commencing A Court Order | 2000 | 2002 | 2003 | 2004 | 2005 | 2006 | |-------------------------------------------------------------------------|---------|---------|--------|--------|--------| | 2007 | 2008 | 2009 | | | | | Proportion of offenders who re-offend (%) | | | | | | | 40.9 | 43 | 42.4 | 39.8 | 38.4 | 37.6 | | Average number of re-offences per re-offender | | | | | | | 4.13 | 4.36 | 4.15 | 3.87 | 3.65 | 3.48 | | Average number of re-offences per offender (frequency rate) | | | | | | | 1.69 | 1.87 | 1.76 | 1.54 | 1.4 | 1.31 | | Number of offenders in cohort | | | | | | | 148,052 157,243 159,686 163,775 170,021 181,726 190,418 197,035 200,077 | | | | | | Proven re-offending of adult offenders discharged (released) from prison The figures in this section relate to the proven re-offending of adult offenders released from prison overall. In 2009, around 64,000 adult offenders3 were discharged (released) from prison, of whom 46.8 per cent (just under 30,000) committed a proven reoffence within one year. Those who committed a proven re-offence committed just over 120,000 proven re-offences in total, an average frequency of 4.03 proven re-offences each. (Table 18a and 19) Among offenders discharged from short sentences (less than 12 months), long term trends show that the proportion who committed a proven re-offence increased, but that the average number of offences committed by those reoffenders decreased :  the one year proven re-offending rate for this group was 56.8 per cent in 2009, an increase of 2.6 percentage points from 2000 (54.3 per cent)  the average number of proven re-offences committed per re-offender has decreased by 9.9 per cent from 4.99 in 2000 to 4.50 proven reoffences in 2009. However, between 2008 and 2009 the one year proven re-offending rate has decreased by 2.6 percentage points from 59.4 per cent. Among offenders given any sentence of more than 12 months the proportion who committed a proven re-offence decreased by 7.4 percentage points compared to 2000. The average number of proven re-offences committed per re-offender also decreased and by a larger amount than for the short sentence prisoners (23.5 per cent compared with 9.9 per cent). Adult proven re-offending rates by individual prison Tables 22a and 22b show the number of adult offenders discharged (released) from each prison and their respective proven re-offending rates for those serving sentences of less than 12 months and those serving sentences of 12 months or more. This takes the first discharge from within each prison as the start point for measuring re-offending and subsequent events as reoffences17. Among prisons which discharged thirty or more offenders in 2009 re-offending rates varied considerably from 10.6 per cent to 87.1 per cent for offenders sentenced to under twelve months and 5.1 per cent to 70.6 per cent for offenders sentenced to more than twelve months. A large part of this variability reflects the mix of offenders who are held in different prisons and therefore comparisons between prisons should not be made using these raw re-offending rates. The Ministry of Justice has developed a model that aims to account for differences in the mix of prisoners to help explain if re-offending rates are affected by the specific prison they are discharged from or if the rate of reoffending reflects the mix of offenders. For example, a group of prisoners with a high number of previous offences is more likely to re-offend than a group with a low number of previous offences. The model estimates an expected rate of re-offending taking into account the mix of offenders discharged from each prison. If the actual rate is significantly different from the expected rate than this could mean that there is something specific to the prison that is impacting prisoners' proven re-offending behavior. For details of the model please see the 'Definitions and Measurement' document www.justice.gov.uk/publications/statistics-anddata/reoffending/proven-reoffending-quarterly.htm Among prisons discharging prisoners serving sentences of less than 12 months only three prisons showed significantly different re-offending rates than expected. Wellingborough and Ashkam Grange had lower (better) than expected re-offending rates while re-offending rates for Hindley were higher (worse). Among prisons discharging offenders serving sentences of 12 months or more, two prisons showed significantly lower (better) re-offending rates (Latchmere house and Askham Grange) than expected and only one (Warren Hill) showed higher (worse). Proven re-offending of adults starting court orders18 As described previously, the measure of re-offending for adults starting court orders takes the first commencement for each court order as the start point for measuring re-offending and subsequent events as re-offences19. The figures in this section relate to the proven re-offending of all adult offenders starting court orders, while the following section looks at these figures for individual Probation Trusts. In 2009, just under 100,0003 adult offenders started a **community order**. Just under 39,000 of these (35.6 per cent) committed a proven re-offence within a year. These proven re-offenders committed around 123,000 proven reoffences, an average of 3.15 proven re-offences each. Similarly, of the 37,0001 adult offenders starting a **suspended sentence order**, 31.0 per cent committed a proven re-offence within a year, committing an average of 2.86 further offences each. (Table 20 and 21) The Compendium of Re-offending Statistics and Analysis 2011 compares like for like offenders which enables a more reliable comparison of proven reoffending rates between offenders receiving different sentences. The results showed that after controlling for differences between offenders, the proven reoffending rate of offenders given short term prison sentences (less than 12 months) was 8.3 percentage points higher than for similar offenders given Community Orders and 8.8 percentage points higher than for similar offenders given Suspended Sentence Orders (in 2008). www.justice.gov.uk/publications/statistics-and-data/reoffending/compendiumof-reoffending-statistics-and-analysis.htm The proportion of offenders starting community orders who committed a proven re-offence within a year has decreased by 2.2 percentage points since their introduction in 2005. Offenders starting suspended sentence orders showed a larger decrease of 5.3 percentage points. There was some variation in the proven re-offending rates depending on the requirements attached to these orders; this reflects the differing characteristics of offenders receiving each combination of requirements. For both community orders and suspended sentence orders, proven re-offending was lowest among those with a standalone work requirement (25.4 per cent and 17.3 per cent respectively). There was a slight reduction in proven reoffending for most combinations of requirements. Although care should be taken with this comparison as it has yet to be controlled for different mixes of offenders. Proven re-offending rates by probation trust Offenders given a Court Order are managed by the probation service which comprises 35 Probation Trusts. Proven re-offending rates of these offenders are presented by Probation Trust in Table 24. This takes the first court order commencement from within each probation trust as the start point for measuring re-offending and subsequent events as proven re-offences. Re-offending rates varied considerably between probation trusts from 28.2 per cent to 43.7 per cent in 2009. A large part of this variability reflects the mix of offenders who are given a Court Order and therefore comparisons between probation trusts should not be made using these raw re-offending rates. For probation trusts an adjusted proven re-offending rate to control for differences in the composition of the offender group in each trust has been developed from the national model. Proven re-offending among juveniles by index disposal (sentence) Among juvenile proven offenders there have been overall reductions in the proportion who committed a proven re-offence for most disposals since 2000. The largest falls have been:  Offenders commencing first tier penalties20. There was a decrease of 5.7 percentage points (from 50.9 per cent to 45.2 per cent). This was driven by the decrease in the re-offending rates for youth referral orders (4.1 percentage points).There was also a slight decrease when comparing with the same period last year (0.4 percentage points).  Offenders discharged from custodial sentences. There was a decrease of 6.3 percentage points (from 76.8 per cent to 70.6 per cent). There was also a slight decrease when comparing the same period last year (1.6 percentage points). However, for community penalties21 compared to 2000, the proportion of juvenile offenders who committed a proven re-offence has increased by 5.0 percentage points from 60.5 per cent to 65.6 per cent, although the average number of proven re-offences per proven re-offender has decreased by 19.4 per cent from 4.60 to 3.70 proven re-offences. (Table 18b) Proven re-offending rates by YOT Offenders between the ages of 10 and 17 who receive a pre-court disposal or court conviction are managed by Youth Action Teams (YOT). These are made up of representatives from the police, Probation Service, social services, health, education, drugs and alcohol misuse and housing officers. Proven reoffending data are presented by YOT in Table 1722. Re-offending rates varied considerably between YOTs from 21.4 per cent to 46.3 per cent in 2009. A large part of this variability reflects the mix of offenders in a given YOT and therefore comparisons between YOTs should not be made using these raw re-offending rates. Differences between the previously published measures of youth re-offending within Youth Action Teams and the current measure are discussed in Annex A. Prolific and Priority Offenders (PPO) The Prolific and Priority Offenders (PPO) scheme targets those who pose the greatest threat to the safety and confidence of their local communities. It allows local partners to concentrate their joint efforts on those people identified locally as causing most harm to their communities23. (Table 16) Around 8,000 offenders24 were on the PPO scheme at some point during 2009. Of these just over 6,000 committed a proven re-offence within a year (75.1 per cent), which is considerably higher than the national rate of 26.3 per cent. The average number of proven re-offences committed by these reoffenders was 4.65 compared to the national figure of 2.79. These differences reflect the profile of offenders who are selected to go onto the scheme. For example, PPO offenders have committed an average of 57.5 previous offences, compared to 10.3 previous offences among offenders in general. These offenders represented 1.2 percent of all offenders but were responsible for 5.6 per cent of all proven re-offences committed. The proportion of PPO offenders who committed a proven re-offence decreased (2.1 percentage points) between 2008 and 2009. Looking longer term there was a decrease of 1.9 percentage points since the scheme began in 2005. Drug Misusing Offenders Around 53,000 adult offenders were identified as drug misusers at some point during 2009. Of these just over 29,000 committed a proven re-offence within a year (54.7 per cent). These offenders represented 9.2 percent of all adult offenders but were responsible for 27.8 per cent of all proven re-offences committed. (Table 15) A higher proportion of drug-misusing offenders25 committed a proven reoffence than adult offenders in general (54.7 per cent compared to 24.9 per cent). The average number of proven re-offences committed by re-offenders was 3.84 for this group compared with 2.80 overall. This difference reflects the profile of drug misusing offenders. For example, drug-misusing offenders have committed an average of 35.7 previous offences, compared to 11.9 previous offences among adult offenders in general. The proportion of drug-misusing offenders who committed a proven re-offence fell slightly between 2008 and 2009 (1.7 percentage points). Looking longer term there was a decrease of 10.6 percentage points between 2005 and 2009, although most of this change occurred between 2005 and 2006 when there was a large expansion in the drug intervention programme. The expansion of this programme led to a change in the characteristics of the drug misusing offender group (a lower average number of previous offences) which meant they were less likely to re-offend. ## List Of Quarterly Tables Proven Re-Offending - Overview Table 1 Summary proven re-offending data, by adults and juveniles, 2000, 2002 - 2009 Table 2 Proven re-offending data, by gender, 2000, 2002 -2009 Table 3 Proven re-offending data, by age, 2000, 2002-2009 Table 4a Adult proven re-offending data, by ethnicity, 2000, 2002-2009 Table 4b Juvenile proven re-offending data, by ethnicity, 2000, 2002-2009 Table 4c Adult and juvenile proven re-offending data, by ethnicity, 2000, 2002-2009 Table 5a Adult proven re-offending data, by index offence, 2000, 2002- 2009 Table 5b Juvenile proven re-offending data, by index offence, 2000, 2002- 2009 Table 5c Adult and juvenile proven re-offending data, by index offence, 2000, 2002-2009 Table 6a Adult proven re-offending data, by number of previous offences, 2000, 2002-2009 Table 6b Juvenile proven re-offending data, by number of previous offences, 2000, 2002-2009 Table 6c Adult and juvenile proven re-offending data, by number of previous offences, 2000, 2002-2009 Table 7a Adult proven re-offending data, by number of previous custodial sentences, 2000, 2002-2009 Table 7b Juvenile proven re-offending data, by number of previous custodial sentences, 2000, 2002-2009 Table 8 Serious proven re-offending data, 2000, 2002-2009 Table 9 Number and proportion of proven re-offences by month of offence into the one-year follow-up period, 2000 to 2009 Table 10 Number and proportion of proven re-offences committed in the follow-up period, 2000 to 2009 Table 11 Proven re-offending by index offence group and re-offence group, 2009 Table 12 Proven re-offending by index disposal and first re-offence disposal, 2009 Table 13 Proven re-offending of adult and juvenile offenders by upper-tier local authority, 2005 to 2009 rolling quarters Table 14 Proven re-offending of adult offenders by lower-tier local authority, 2005 to 2009 rolling quarters Table 15 Proven re-offending of drug-misusing offenders by DAT, 2004 to 2009 Table 16 Proven re-offending of Prolific and other Priority Offenders by upper tier local authority, 2005 to 2009 Table 17 Proven re-offending by Youth Offending Team: 2005 to 2009 cohorts ## Proven Re-Offending By Index Disposal, Prison And Probation Trust Table 18a Adult proven re-offending data, by index disposal, 2000, 2002- 2009 Table 18b Juvenile proven re-offending data, by index disposal, 2000, 2002-2009 Table 19 Adult proven re-offending data, by custodial sentence length, 2000, 2002-2009 Table 20 Adult proven re-offending data, by the most frequently-used combinations of requirements for offenders starting Community Orders, 2005-2009 Table 21 Adult proven re-offending data, by the most frequently-used combinations of requirements for offenders starting Suspended Sentence Orders, 2005-2009 Table 22a Proven re-offending of adult offenders given sentences of less than 12 months by individual prison, first discharge from each prison, 2007 to 2009 Table 22b Proven re-offending of adult offenders given sentences of 12 months or more by individual prison, first discharge from each prison, 2007 to 2009 Proven re-offending of juvenile offenders by individual prison, first discharge from each prison, 2007 to 2009 Table 24 Adult proven re-offending by probation trusts based on first commencement from each trust, 2005 to 2009 ## Annex A How The Measure Of Proven Re-Offending Has Changed And The Effect Of These Changes Background The Ministry of Justice launched a statistical consultation on improvements to the transparency and accessibility of our information in 2010 and a response to the consultation was published in March 201126. One aspect of the consultation was the measurement of proven re-offending. Prior to the consultation there were six different measures of proven reoffending:  national adult proven re-offending;  local adult proven re-offending;  national youth proven re-offending;  local youth proven re-offending;  Prolific and other Priority Offending (PPO); and  drug-misusing proven offending. The new approach to measuring proven re-offending integrates these approaches into a single framework. This allows users to:  form a clear picture of proven re-offending at national and local levels;  compare adult and youth results, and enable other work on transition between the youth and adult criminal justice systems;  understand how results for different offender groups (such as those managed by the prison and probation services, those under the PPO schemes, drug-misusing offenders, first time entrants, etc) fit in to the overall picture on proven re-offending; and  continue to be able to analyse proven re-offending behaviour of particular types of offender. ## Comparing Trends In Re-Offending Table A1 shows the proportion of offenders with a proven re-offence/reconviction using the new measure of re-offending and the previous measures of adult re-conviction and juvenile re-offending. Re-offending rates are lower using the new measure than using the previous measure. The differences are as follows:  For adult and juvenile offenders the new measure is based on all offenders released from custody, receiving a non-custodial conviction at court, a caution, reprimand, warning or tested positive for opiates or cocaine over a 12 month period, but the previous measures only included offenders released from custody or commencing a court order in the first three months of the year. Using a 3 month sample overrepresents prolific offenders in comparison to a full year's worth of data.  For adults the new measure counts all offenders including those who received a caution, fine or discharge, where the previous adult measure only included those who commenced a court order or were discharged from custody.  For adult offenders, the new measure is a measure of proven reoffending (which counts offences proven through a court conviction or a caution) whereas the previous measure is a measure of re-conviction (which only counts offences proven through a court conviction). As a result, re-offending rates are 14.4 percentage points lower for adults and rates for juveniles are 4.1 percentage points lower using the new measure. However, the re-offending rates are similar for adults given a court order or who received a custodial sentence, including those given a sentence of less than 12 months. Rates are between 1.0 and 2.6 percentage points lower using the new measure. | | New measure | Previous measure(s) | |----------------------------------------------------|----------------|-----------------------| | Adults | 24.9 | 39.3 | | Juveniles | 32.8 | 36.9 | | Adults given a court order | 34.5 | 35.5 | | Adults given a custodial sentence | 46.8 | 48.5 | | Adults given a custodial sentence of less than 12m | 56.8 | 59.4 | | | | | Figure A1 shows re-offending rates for adult offenders between 2000 and 2009 using the new and previous measure. In 2009 24.9 per cent of adult offenders have a proven re-offence within twelve months using the new measure compared to 39.3 per cent reconvicted using the previous measure. However, trends for adult offenders are similar using the two measures. The proportion of offenders with a proven re-offence/re-conviction rose between 2000 and 2002, fell between 2002 and 2006, rose between 2006 and 2008, and fell between 2008 and 2009 using both measures. The overall reduction in re-offending is smaller using the new measure (1.2 percentage points between 2000 and 2009 and 0.5 percentage points between 2008 and 2009) than using the previous measure (3.7 percentage points between 2000 and 2009 and 0.8 percentage points between 2008 and 2009). In 2009, 32.8 per cent of young offenders re-offended within twelve months using the new measure compared to 36.9 per cent using the previous measure. The reduction in re-offending is smaller using the new measure (0.9 percentage points between 2000 and 2009 and 0.1 percentage points between 2008 and 2009) than using the previous measure (3.3 percentage points between 2000 and 2009 and 0.4 percentage points between 2008 and 2009). Overall, the trends are broadly similar. Trends in proven re-offending/re-conviction rates for adult custodial offenders are similar using the new and previous measures. The proportion of offenders given a custodial sentence of less than 12 months who re-offended rose between 2000 and 2009 using both measures (by 2.6 percentage points using the new measure and 1.4 percentage points using the previous measure). The proportion of offenders given any custodial sentence who re-offended fell between 2000 and 2009 using both measures (by 2.6 percentage points using the new measure and 2.9 percentage points using the previous measure). ## The Change In Methodology The following sections provide a detail regarding the change in methodology between the methods in measuring re-offending and how those changes impact on the data. The table below provides a comparison of the previous methodologies with the new approach. Comparison of previous and new measures of proven re-offending Previous measures of re-offending New measure of re-offending National adult re-conviction Local adult reoffending National youth reoffending The cohort Offenders aged 18+ discharged from custody or commencing court orders under probation supervision between January to March Offenders aged 18+ on the probation caseload at the end of each calendar quarter Offenders aged 10- 17 discharged from custody, receiving a court conviction or receiving a caution/reprimand or final warning between January and March The follow up period to measure reoffending 12 months for offences to occur and a further 6 months for offences to be proved 3 months for offences to occur and a further 3 months for offences to be proved 12 months for offences to occur and a further 6 months for offences to be proved Local youth reoffending Prolific and other Priority Offending (PPO) Drug misusing offending Offenders aged 10-17 discharged from custody, receiving a court conviction or receiving a caution/reprimand or final warning between January and March All offenders identified as being on the PPO scheme as at 1 April All Class A drug offenders identified through positive drug tests on arrest, OASyS or drug requirement as part of a court order, CJIT identification, or identification on prison release between January and March All offenders who received a caution/reprimand or warning, were convicted at court (other than custody), were discharged from custody, or tested positive for cocaine or opiates on arrest over a 12 month period. 12 months for offences to occur and a further 3 months for offences to be proved 12 months for offences to occur and a further 3 months for offences to be proved 12 months for offences to occur and a further 3 months for offences to be proved 12 months for offences to occur and a further 6 months for offences to be proved The headline measure Frequency of reoffending (the number of proven re-offences per 100 offenders) Proportion of offenders reoffending, compared to the rate that would be expected based on the offender characteristics Frequency of reoffending (the number of proven reoffences per 100 offenders) What counts as a proven reoffence Offences committed within the follow up period which were proved by a court conviction either within the follow up period or in a further six months Offences committed within the follow up period which were proved by a court conviction or caution either within the follow up period or in a further three months Offences committed within the follow up period which were proved by a court conviction or reprimand or final warning either within the follow up period or in a further six months Frequency of reoffending (the number of proven re-offences per 100 offenders) Number of further offences compared to number in previous year, against the reduction that would be expected given time on the PPO scheme Number of further offences compared to what would be expected based on their previous offending history Proportion of offenders reoffending We also include information on the frequency of reoffending and information on the predicted rate based on offender characteristics Offences committed within the follow up period which were proved by a court conviction or reprimand or final warning either within the follow up period or in a further three months Offences committed within the follow up period which were proved by a court conviction or caution either within the follow up period or in a further three months. Breach offences that lead to substantive recorded convictions are included Offences committed within the follow up period which were proved by a court conviction either within the follow up period or in a further three months Offences committed within the follow up period which were proved by a court conviction or caution/reprimand or warning either within the follow up period or in a further six months Use of a predicted rate A predicted rate of re-offending was included for the proportion of offenders expected to reoffend based on their characteristics A predicted rate of re-offending was included for the proportion of offenders expected to reoffend based on their characteristics A predicted rate of re-offending was included for the proportion of offenders expected to re-offend based on their characteristics No predicted rate Evidence on the link between time on the PPO scheme and expected reductions in further offending were used to assess reductions in number of offences compared to the previous year A predicted rate of re-offending was included for the proportion of offenders expected to reoffend based on their previous criminal history A predicted rate of re-offending is included for the proportion of offenders expected to re-offend based on their characteristics Logistic regression is used Response surface methodology was used Logistic regression was used Logistic regression was used Logistic regression was used Data source Police National Computer Police National Computer Police National Computer Youth Offending Teams data Police National Computer Police National Computer Police National Computer Geographic breakdown None Region, Probation area, Local Authority None Youth Offending Team level Police Force and Local Authority level Drug Action team and Local Authority level Upper and lower tier local authority areas for all offenders. Other breakdowns for specific categories of offender. ## The Effect Of The Changes Adults Differences In Methodology Are Reflected In Different Results. Table A3 Shows The Impact On Reported Rates Of Adult Re-Conviction/Re-Offending. The Table Breaks Down The Changes Between The Previous Measure And The New Measure To Identify The Different Effects Of The Changes In Methodology. Previous1 measure: reconvictions (prison and probation offenders only), first quarter of the year Previous measure: reconvictions (prison and probation offenders only), whole year New measure: reoffending (prison and probation offenders only), whole year New measure: proven reoffending (all offenders), whole year Proportion 2000 43.0 40.0 40.9 26.2 2002 45.5 42.0 43.0 27.6 2003 45.4 41.5 42.4 26.9 2004 42.9 38.6 39.8 25.5 2005 41.2 36.6 38.4 24.9 2006 38.6 35.6 37.6 24.6 2007 39.0 35.9 37.9 24.8 2008 40.1 36.1 37.9 25.4 2009 39.3 34.7 36.2 24.9 Frequency (average per offender) 2000 1.85 1.66 1.69 0.89 2002 2.13 1.84 1.87 0.99 2003 2.05 1.73 1.76 0.93 2004 1.81 1.51 1.54 0.83 2005 1.66 1.36 1.40 0.77 2006 1.44 1.26 1.31 0.73 2007 1.47 1.27 1.32 0.73 2008 1.55 1.27 1.31 0.75 2009 1.41 1.15 1.18 0.70 Frequency of re-offenders (average per re-offender) 2000 4.30 4.15 4.13 3.39 2002 4.68 4.39 4.36 3.59 2003 4.52 4.18 4.15 3.44 2004 4.23 3.91 3.87 3.27 2005 4.03 3.70 3.65 3.10 2006 3.73 3.54 3.48 2.95 2007 3.78 3.53 3.48 2.94 2008 3.88 3.51 3.46 2.93 2009 3.57 3.31 3.27 2.80 Number of offenders 2000 42,734 148,052 148,052 477,698 2002 43,247 157,243 157,243 495,664 2003 44,095 159,686 159,686 520,660 2004 46,532 163,775 163,775 512,600 2005 43,429 170,021 170,021 532,045 2006 50,281 181,726 181,726 571,458 2007 50,085 190,418 190,418 595,020 2008 53,718 197,035 197,035 589,948 2009 56,616 200,077 200,077 576,255 1. Based on the national adult re-convictions publication (March 2011) Among adult offenders in 2009, the previous national measure (the first column) shows that 39.3 per cent of adult offenders were re-convicted within a year based on a sample of 56,616 offenders. The second column shows the re-conviction rates from the previous measure looking at offenders who were released from custody or commenced a court order but at any point during the year. The inclusion of offenders from a full twelve month period means the results are calculated using the full proven offender population rather than a sample - this ensures we do not over-represent prolific offenders in the cohort, which is a problem in using a January to March sample as in the previous adult re-conviction measure. This leads to a lower proportion of re-convicted offenders (between three and five percentage points, eg 34.7 per cent compared to 39.3 per cent in 2009). The change to a full year also increases the number of offenders, to 200,077 in 200927. The third column shows the proven re-offending rates from the new measure but still based only on those offenders who were released from custody or commenced a court order at any point during the year. Proven re-offending includes offences which result in a caution in addition to those resulting in a conviction at court. The proportion of offenders who were proven to re-offend is between 1 and 2 percentage points higher than for those who were re-convicted (36.2 per cent compared to 34.7 per cent in 2009). There is little difference at this stage because we are still only considering offenders who already have a prison or a court order. The fourth column shows the re-offending rates from the new measure looking at all adult offenders who received a caution, a conviction at court, discharged from custody, or tested positive for cocaine or opiates. The inclusion of these offenders increases the numbers considerably. In 2009, the previous adult measure tracks the re-offending behaviour of 56,616 offenders; the new measure tracks 576,255 offenders. The inclusion of offenders who received less severe disposals and are generally less prolific in nature reduces the proportion who re-offend by around 11 to 16 percentage points (36.2 per cent compared to 24.9 per cent in 2009). Change over time Compared to the previous measure, the reduction over time in the proportion of offenders who re-offend is much lower using the new measure. Using the previous measure, between 2000 and 2009 the proportion of offenders who were re-convicted fell 3.7 percentage points (from 43.0 per cent to 39.3 per cent). Using the new measure, the proportion of offenders who committed a proven re-offence fell 1.2 percentage points (from 26.2 per cent to 24.9 per cent). Juveniles The only change between the previous measure and the new measure of re-offending among young people is the move from a one quarter sample to including all young offenders over the period of a year. Previous measure1 proven re-offending New measure proven reoffending Proportion 2000 40.2 33.7 2002 38.5 33.4 2003 39.0 34.3 2004 38.6 33.6 2005 38.4 33.6 2006 38.7 33.9 2007 37.5 32.5 2008 37.3 32.9 2009 36.9 32.8 Frequency (average per offender) 2000 1.51 1.12 2002 1.42 1.10 2003 1.42 1.09 2004 1.32 1.03 2005 1.25 0.98 2006 1.23 0.97 2007 1.16 0.90 2008 1.14 0.91 2009 1.10 0.90 Frequency of re-offenders (average per re-offender) 2000 3.77 3.32 2002 3.69 3.29 2003 3.63 3.19 2004 3.43 3.06 2005 3.26 2.91 2006 3.18 2.86 2007 3.08 2.77 2008 3.06 2.75 2009 2.99 2.75 Number of offenders 2000 41,176 139,326 2002 40,753 136,401 2003 40,297 138,379 2004 44,153 149,452 2005 45,337 163,545 2006 48,938 171,061 2007 52,544 171,454 2008 44,837 145,579 2009 37,472 121,107 1. Based on the national juvenile re-offending publication (March 2011) publication As for adults, using the whole year reduces the proportion of offenders who re-offended because we do not over-represent prolific offenders in the cohort, which is a problem in using a January to March sample. Table A4 shows the reduction is between four and seven percentage points. For 2009 with the previous measure, 36.9 per cent commit a proven re-offence within one year; with the new measure, 32.8 per cent do so. The new measure, which is based on offenders from a 12 month period, includes over three times as many offenders as the existing measure. Change over time Compared to the previous measure, the reduction in the proportion of offenders who reoffend between 2000 and 2009 is much lower using the new measure. Using the previous measure, between 2000 and 2009, the proportion of offenders who were proven to re-offend fell 3.3 percentage points (from 40.2 per cent to 36.9 per cent). Using the new measure, the proportion of offenders who committed a proven re-offence fell 0.9 percentage points (from 33.7 per cent to 32.8 per cent). Drug-misusing offenders Published results for drug-misusing offenders on the previous measure covered 2008 and 2009; results using the new measure cover from 2004 onwards. The previous measure:  Includes offenders who have been identified in the first quarter of the year, whereas the new measure includes offenders from any point during the year,  Includes all drug-misusing offenders irrespective of the date of proven offence, whereas the new measure includes identified drug-misusing offenders who have received a caution, been convicted at court, been discharged from custody, or tested positive for cocaine or opiates on arrest during a twelve month period.  Counts re-offences that were proven through a court conviction, whereas the new measure counts re-offences that were proven by a court conviction or caution. As for adult and juvenile offenders, using the whole year to identify offenders reduces the proportion of offenders who re-offend, because we do not over-represent prolific offenders in the cohort, which is a problem in using a January to March sample. Table A5 shows the impact on reported rates of re-offending/re-conviction by drug-misusing offenders. Previous measure1 proven reconviction New measure of proven reoffending Proportion 2004 67.3 2005 65.3 2006 58.6 2007 57.2 2008 61.0 56.4 2009 57.0 54.7 Frequency (average per offender) 2004 3.20 2005 2.94 2006 2.37 2007 2.34 2008 2.6 2.29 2009 2.2 2.10 Frequency of re-offenders (average per re-offender) 2004 4.75 2005 4.51 2006 4.03 2007 4.09 2008 4.3 4.06 2009 3.9 3.84 Number of offenders 2004 20,652 2005 29,112 2006 44,597 2007 54,474 2008 20,934 59,039 2009 20,109 53,109 Table A5 shows that the proportion of offenders who commit a proven re-offence is between two and five percentage points lower using the new measure (57.0 per cent using the previous measure compared to 54.7 per cent using the new measure). The new measure, which follows offenders over a 12 month period, includes between two and three times as many offenders as the existing measure. Prolific and other Priority Offenders (PPO) Published results for PPOs on the previous measure presented the frequency of proven re-offending for all PPOs; results using the new measure cover the proportion of offenders proven to re-offend, and the frequency of proven re-offending for all offenders and for reoffenders from 2005 onwards. The previous measure:  Includes offenders who have been identified in the first quarter of the year, whereas the new measure includes offenders from any point during the year. However, PPOs are generally on the PPO programme for a sustained period of time so this only has a moderate impact on numbers of offenders included.  Includes all identified PPOs, whereas the new measure includes identified PPOs who have tested positive for cocaine or opiates, received a caution, been convicted at court, or been discharged from custody during a twelve-month period.  Counts re-offences that are proven through a court conviction or caution and also includes breach offences that lead to substantive recorded convictions. The new measure only includes re-offences proven through a court conviction or caution. ## Table A6 Shows The Impact On Reported Rates Of Proven Re-Offending By Prolific And Other Priority Offenders And On Numbers Of Offenders Included In The Measure. Table A6: Re-Offending Data For Prolific And Other Priority Offenders 1 Previous measure proven reoffending New measure of proven reoffending Proportion 2005 77.0 2006 75.7 2007 75.8 2008 77.2 2009 56.0 75.1 Frequency (average per offender) 2005 4.01 2006 3.83 2007 3.80 2008 2.6 3.80 2009 2.4 3.49 Frequency of re-offenders (average per re-offender) 2005 5.21 2006 5.06 2007 5.01 2008 4.93 2009 4.3 4.65 Number of offenders 2005 8,555 2006 8,239 2007 8,309 2008 10,771 8,607 2009 10,635 8,156 1. Based on the national Prolific and other Priority Offenders publication (March 2010) The average number of proven re-offences committed by PPOs in 2009 is lower for the previous measure than for the new measure in 2008 (2.4 re-offences per offender using the previous measure, but 3.49 using the new). The previous measure includes PPOs who have not been proven guilty of an offence or been discharged from custody in the twelve month period when the re-offending cohort is formed. This type of offender is likely to have a lower level of re-offending. These differences may help to explain  why the frequency of re-offending is lower for the previous measure than for the new measure in 2009 (2.4 re-offences per offender using the previous measure, but 3.49 using the new), and  why the previous measure includes nearly 2,500 more PPOs in 2009 than does the new measure. ## Local Adult Re-Offending The Most Similar Results For The New Measure Of Re-Offending And The Existing Local Measure Of Adult Re-Offending Are The Early Estimates Of Re-Offending Of Offenders Given A Court Order. Like The Existing Measure Of Local Adult Re-Offending, The Early Estimates Of Offenders Given A Court Order:  measure re-offending over three months,  only measures offenders under probation supervision,  provides results by probation trust,  compares actual re-offending rates with an predicted re-offending rate. There remain significant differences between the early estimates and the existing local adult measure of re-offending, including  The existing local adult measure includes offenders on license - the early estimates include offenders commencing court orders only.  The existing local adult measure uses a 'snapshot' approach. This means offenders are counted if they are on the caseload at certain times in the year. Offenders who are on the caseload for a short period of time may not get counted with the existing measure. The early estimates count every offender who commences a court order.  Because the existing local adult measure uses a 'snapshot' approach some offenders may get counted up to four times if they are on the caseload for over twelve months. The early estimates count every offender once.  The existing local adult measure measures the re-offending of offenders at any point during the court order - the early estimates measure re-offending in the first three months after an offender commenced a court order.  The predicted score for the existing local adult measure was derived from analysis of 2007 re-offending data - the prediction for the early estimates was derived from analysis of 2008 re-offending data. These differences explain why the re-offending rate is higher with the early estimates of reoffending by offenders commencing a court order than with the existing measure of local adult re-offending:  offenders on license have lower rates of re-offending than those commencing a court order, and  offenders serving a court order have lower rates of re-offending the longer they are on that court order. However, the prediction for the early estimates has been tailored specifically to the relevant group of offenders. Local youth re-offending The previous measure of youth re-offending used data that Youth Offending Teams (YOT) collected themselves from their local police and courts. The measure was used as management information and was never published or put into the public domain. The new measure uses data from the Police National Computer (PNC). Internal analysis and discussion with stakeholders has highlighted a number of differences between the two data-sources:  The PNC includes a number of offenders who have received a reprimand or final warning which do not always appear on the YOT systems. As a result, there are more youth offenders and a higher overall youth re-offending rate using the new measure than using the previous local youth re-offending measure.  The PNC includes more comprehensive data on re-offending as adults by offenders who originally offended as youths.  Using PNC data reduces the data-collection burden on YOT and local police forces.  PNC data measures re-offending on recordable offences and YOT data measures re-offending on all offences. Offences which are not recordable include speeding offences, parking offences and other minor motoring offences. As a result, YOT data is more comprehensive for motoring re-offences.  The new measure allocates offenders to a locality using their home address data from the PNC; the previous local youth measure allocated offenders using offender management data. As a result, Looked After Children (LAC) who are in foster care, or in a children's home, or in a boarding school or live with another adult known to children's services, maybe allocated to a different YOT under the previous youth measure than the new measure.  For their re-offending to be included in the new measure, administrative data on young people in custody and secure accommodation has to be matched to the PNC. Some cases are not successfully matched. This process was not required for these offenders to be included in the previous local youth measure. As a result, YOT data can be more comprehensive regarding custodial offenders or those in secure accommodation.  Using PNC data provides an external measure of youth re-offending, which makes it an appropriate data-source to support any future policies which tie local funding to re-offending performance.  Using PNC data allows local youth re-offending to be measured on the same basis as national youth re-offending and adult re-offending, permitting adult and youth reoffending to be measured on a like-for-like basis and a more comprehensive picture of re-offending to be formed. Work is underway to fully quantify the extent of these differences. ## Appendix A: Glossary Of Terms Re-Offending Terms Cohort - this is the group of individuals whose re-offending is measured. Index offence - the index offence is the proven offence that leads to an offender being included in the cohort. Index disposal - the index disposal of the offender is the type of sentence the offender received for their index offence. Start point (also known as the index date) - this is the set point in time from when reoffences are measured. Follow up period - this is the length of time proven re-offending is measured over. Waiting period - this is the additional time beyond the follow up period to allow for offences committed towards the end of the follow up period to be proved by a court conviction, caution, reprimand or final warning. Adjusted baseline - proven re-offending is related to the characteristics of offenders which means that any overall rate of proven re-offending will depend, in part, on the characteristics of offenders coming into the system (just as the examination pass rate of a school will be related to the characteristics of its pupils). We use a modelling technique to produce a baseline figure adjusted to match the characteristics of the cohort we are comparing. For more details see the chapter on Statistical modelling and coefficients (p x) Reconviction - where an offender is convicted at court for an offence committed within a set follow up period and convicted within either the follow up period or waiting period Proven re-offence - where an offender is convicted at court or receives some other form of criminal justice sanction for an offence committed within a set follow up period and disposed of within either the follow up period or waiting period. ## Cohort Defined Used In The Proven Re-Offending Statistic Quarterly Bulletin In England And Wales Publication The proven re-offending cohort consists of all offenders discharged from custody, otherwise sanctioned at court, receiving a caution, reprimand or warning or tested positive for opiates or cocaine in each year. This cohort's criminal history is collated and criminal behaviour is tracked over the following one year. Any offence committed in this one-year period which is proven by a court conviction or out-of-court disposal (either in the one-year period, or in a further six months waiting period) counts as a proven re-offence. The latest available publication is the Proven Re-offending statistic quarterly bulletin in England and Wales: results from the 2009 cohort; Ministry of Justice, October 2011. ## Cohort Defined Used In The Local Measure Of Re-Offending Quarterly Bulletin Publication The local adult re-offending measure takes a snapshot of all offenders, aged 18 or over, who are under probation supervision at the end of a quarter, and combines four such snapshots together. This cohort's criminal history is collated and criminal behaviour is tracked over the following three months. Any offence committed in this three month period which is proven by a court conviction or out-of-court disposal (either in the three month period, or in a further three months waiting period) counts as a proven re-offence. The latest available publication is the Local Adult Re-offending: 1 April 2010 - 31 March 2011 England and Wales; Ministry of Justice, August 2011. http://www.justice.gov.uk/publications/statistics-and-data/reoffending/local-adultreoffending.htm ## Cohort Defined Used In The Adult Re-Convictions In England And Wales Publication The adult re-conviction cohort consists of adults discharged from custody or commencing a court order under probation supervision in the first quarter of each year. This cohort's criminal history is collated and criminal behaviour is tracked over the following one year. Any offence committed in this one-year period which is proven by a court conviction (either in the one-year period, or in a further six months waiting period) counts as a reconviction. The latest available publication is the Adult re-convictions: results from the 2009 cohort; Ministry of Justice, March 2011. http://www.justice.gov.uk/publications/statistics-and-data/reoffending/adults.htm ## Cohort Definition Used In The Reoffending Of Juveniles In England And Wales Publication The juvenile reoffending cohort is formed of juvenile offenders discharged from custody, otherwise sanctioned at court, or receiving a reprimand or warning in January to March of each year. This cohort's criminal history is collated and criminal behaviour is tracked over the following one year. Any offence committed in this one-year period which is proven by a court conviction or out-of-court disposal (either in the one-year period, or in a further six months waiting period) counts as proven reoffending. The latest available publication is the Reoffending of juveniles: results from the 2009 cohort; Ministry of Justice, March 2011. www.justice.gov.uk/publications/statistics-and-data/reoffending/juveniles.htm Disposals (Sentences) ## Fine A financial penalty imposed following conviction. ## Court Orders Court orders include community sentences, community orders and suspended sentence orders supervised by the Probation Service. They do not include any pre or post release supervision. ## Criminal Justice Act 2003 (Cja03) For offences committed on or after 4 April 2005, the new community order replaced all existing community sentences for adults. The Act also introduced a new suspended sentence order for offences which pass the custody threshold. It also changed the release arrangements for prisoners. See Appendix A of Offender Management Caseload Statistics96 for more information. ## Community Order For offences committed on or after 4 April 2005, the new community order introduced under the CJA 2003 replaced all existing community sentences for those aged 18 years and over. This term refers to all court orders except suspended sentence orders and deferred sentences which may have a custodial component to the sentence. The court must add at least one (but could potentially comprise of all 12) requirements depending on the offences and the offender. The requirements are:  unpaid work (formerly community service/community punishment) - a requirement to complete between 40 and 300 hours' unpaid work;  activity - for example, to attend basic skills classes;  programme - there are several designed to reduce the prospects of reoffending;  prohibited activity - a requirement not do so something that is likely to lead to further offender or nuisance;  curfew - which is electronically monitored;  exclusion - this is not used frequently as there is no reliable electronic monitoring yet available;  residence - requirement to reside only where approved by probation officer;  mental health treatment (requires offender's consent);  drug rehabilitation (requires offender's consent);  alcohol treatment (requires offender's consent);  supervision - meetings with probation officer to address needs/offending behaviour; and,  attendance centre - three hours of activity, between a minimum of 12 hours and a maximum of 36 in total. Typically, the more serious the offence and the more extensive the offender's needs, the more requirements there will be. Most orders will comprise one or two requirements but there are packages of several requirements available where required. The court tailors the order as appropriate and is guided by the Probation Service through a pre-sentence report. ## Suspended Sentence Order (Sso) The Criminal Justice Act 2003 introduced a new suspended sentence order which is made up of the same requirements as a community order and, in the absence of breach is served wholly in the community supervised by the Probation Service. It consists of an 'operational period' (the time for which the custodial sentence is suspended) and a 'supervision period' (the time during which any requirements take effect). Both may be between six months and two years and the 'supervision period' cannot be longer than the 'operational period', although it may be shorter. Failure to comply with the requirements of the order or commission of another offence will almost certainly result in a custodial sentence. ## Pre Cja03 Court Orders - Community Sentences: Community punishment order (CPO): the offender is required to undertake unpaid community work. Community rehabilitation order (CRO): a community sentence which may have additional requirements such as residence, probation centre attendance or treatment for drug, alcohol or mental health problems. Community punishment and rehabilitation order (CPRO): a community sentence consisting of probation supervision alongside community punishment, with additional conditions like those of a community rehabilitation order. Drug treatment and testing order (DTTO): a community sentence targeted at offenders with drug misuse problems. Custody - the offender is awarded a sentence to be served in prison or YOI (Youth Offenders Institute). If the offender was given a sentence of 12 months or over, or was aged under 22 on release, the offender is supervised by the Probation Service on release. It is important to note that the sentence length awarded will be longer than the time served. For more information please refer to Appendix A of the Offender Management Caseload Statistics. ## Prison Categories Category B and Category C prisons hold sentenced prisoners of their respective categories, including life sentenced prisoners. The regime focuses on programmes that address offending behaviour and provide education, vocational training and purposeful work for prisoners who will normally spend several years in one prison. High Security Prisons hold Category A and B prisoners. Category A prisoners are managed by a process of dispersal, and these prisons also hold a proportion of Category B prisoners for whom they provide a similar regime to a Category B prison. The Category B prisoners held in a High Security Prison are not necessarily any more dangerous or difficult to manage than those in category B prisons. Female prisons. As the name implies, they hold women prisoners. Because of the smaller numbers, they are not divided into the same number of categories although there are variations in security levels. Local prisons serve the courts in the area. Historically their main function was to hold unconvicted and unsentenced prisoners and, once a prisoner had been sentenced, to allocate them on to a Category B, C or D prison as appropriate to serve their sentence. However, pressure on places means that many shorter term prisoners serve their entire sentence in a local prison, while longer term prisoners also complete some offending behaviour and training programmes there before moving on to lower security conditions. All local prisons operate to category B security standards. Open prisons have much lower levels of physical security and only hold Category D prisoners. Many prisoners in open prisons will be allowed to go out of the prison on a daily basis to take part in voluntary or paid work in the community in preparation for their approaching release. ## Prisoner Categories These categories are based on a combination of the type of crime committed, the length of sentence, the likelihood of escape, and the danger to the public if they did escape. The four categories are: Category A prisoners are those whose escape would be highly dangerous to the public or national security Category B prisoners are those who do not require maximum security, but for whom escape needs to be made very difficult Category C prisoners are those who cannot be trusted in open conditions but who are unlikely to try to escape Category D prisoners are those who can be reasonably trusted not to try to escape, and are given the privilege of an open prison. ## Short Sentences - Under Twelve Months Those sentenced to **under twelve months** (made under the Criminal Justice Act 1991) spend the first half of their sentence in prison and are then released and considered 'at risk' for the remaining period. This means they are under no positive obligations and do not report to the probation service but, if they commit a further imprisonable offence during the at risk period, they can be made to serve the remainder of the sentence in addition to the punishment for the new offence. The exception to this is those aged 18 to 20 who have a minimum of three months' supervision on release. ## Sentences Of 12 Months Or Over The Criminal Justice Act 2003 created a distinction between standard determinate sentences and **public protection sentences**. Offenders sentenced to a standard determinate sentence serve the first half in prison and the second half in the community on licence. ## Reprimand Or Warnings A reprimand is a formal verbal warning given by a police officer to a juvenile offender who admits they are guilty for a minor first offence. A final warning is similar to a reprimand, but can be used for either the first or second offence, and includes an assessment of the juvenile to determine the causes of their offending behaviour and a programme of activities is designed to address them. ## First-Tier Penalties Discharge - a juvenile offender is given an absolute discharge when they admit guilt, or are found guilty, with no further action taken. An offender given a conditional discharge also receives no immediate punishment, but is given a set period, during which if they commit a further offence, they can be brought back to court and re-sentenced. Fine - the size of the fine depends on the offence committed and the offender's financial circumstances. In the case of juveniles under 16, the fine is the responsibility of the offender's parent or carer. Referral order - this is given to juveniles pleading guilty and for whom it is their first time at court (unless the offence is so serious it merits a custodial sentence or it is of a relatively minor nature). The offender is required to attend a Youth Offender Panel to agree a contract, aimed to repair the harm caused by the offence and address the causes of the offending behaviour. Reparation order - the offender is required to repair the harm caused by their offence either directly to the victim or indirectly to the community. ## Miscellaneous Terms National Probation Service The National Probation Service generally deals with those aged 18 years and over. (Those under 18 are mostly dealt with by Youth Offending Teams, answering to the Youth Justice Board.) They are responsible for supervising offenders who are given community sentences and suspended sentence orders by the courts, as well as offenders given custodial sentences, both pre and post their release. ## Police National Computer The Police National Computer (PNC) is the police's administrative IT system used by all police forces in England and Wales and managed by the National Policing Improvement Agency. As with any large scale recording system the PNC is subject to possible errors with data entry and processing. The Ministry of Justice maintains a database based on weekly extracts of selected data from the PNC in order to compile statistics and conduct research on reoffending and criminal histories. The PNC largely covers recordable offences - these are all indictable and triable-either-way offences plus many of the more serious summary offences. All figures derived from the Ministry of Justice's PNC database, and in particular those for the most recent months, are likely to be revised as more information is recorded by the police. ## Recordable Offences Recordable offences are those that the police are required to record on the Police National Computer. They include all offences for which a custodial sentence can be given plus a range of other offences defined as recordable in legislation. They exclude a range of less serious summary offences, for example television licence evasion, driving without insurance, speeding and vehicle tax offences. Indictable and summary offences - Summary offences are triable only by a magistrates' court. This group includes motoring offences, common assault and criminal damage up to £5,000. More serious offences are classed either as **triable either way** (these can be tried either at the Crown Court or at a magistrates' court and include criminal damage where the value is £5,000 or greater, theft and burglary) or **indictable** (the most serious offences that must be tried at the Crown Court. These 'indictable-only' offences include murder, manslaughter, rape and robbery). Offence Group - A split of offences into twelve separate groups. A more detailed split of the ten indictable offence groups (violence against the person, sexual offences, burglary, robbery, theft and handling and stolen goods, fraud and forgery, criminal damage, drug offences, other indictable offences (excluding motoring), indictable motoring) and the two summary offence groups (summary non-motoring and summary motoring offence types). Explanatory notes The United Kingdom Statistics Authority has designated these statistics as National Statistics, in accordance with the Statistics and Registration Service Act 2007 and signifying compliance with the Code of Practice for Official Statistics. Designation can be broadly interpreted to mean that the statistics: - meet identified user needs; - are well explained and readily accessible; - are produced according to sound methods, and - are managed impartially and objectively in the public interest. Once statistics have been designated as National Statistics it is a statutory requirement that the Code of Practice shall continue to be observed. The statistics in this bulletin relate to re-offending data in England and Wales. This is the first set of quarterly re-offending statistics to be published by the Ministry of Justice, subsuming a number of previous publications including: Adult re-convictions, juvenile reoffending, drug misusing offenders and prolific and priority offenders. Symbols used .. not available 0 nil or less than half the final digit shown - not applicable * One or both of the comparison figures are less than 50 (p) Provisional data ## Contact Points Press enquiries should be directed to the Ministry of Justice press office: Tel: 020 3334 3536 Other enquiries about these statistics should be directed to: Iain Bell Ministry of Justice Justice Statistics Analytical Services 7th Floor 102 Petty France London SW1H 9AJ Tel: 020 3334 3737 General enquiries about the statistical work of the Ministry of Justice can be e-mailed to: statistics.enquiries@justice.gsi.gov.uk General information about the official statistics system of the UK is available from www.statistics.gov.uk © Crown copyright Produced by the Ministry of Justice Alternative formats are available on request from statistics.enquiries@justice.gsi.gov.uk
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## Cabinet Wednesday, 13 September 2017 Decisions PRESENT: Councillor Nunn (Chair); Councillor Larratt (Deputy Chair); Councillors Hadland, Hibbert, King and Eldred . Set out below is a summary of the decisions taken at the meeting of the Cabinet held on Wednesday, 13 September 2017. The wording used does not necessarily reflect the actual wording that will appear in the minutes. These decisions will come into force and then may be implemented on the expiry of three working days after the publication of this list. If you have any queries about any matters referred to in this decision sheet please contact Emma Powley. 14th September 2017 ## This List Of Decisions Published: | DATE OF EXPIRY OF CALL IN: | |------------------------------------| | th | | September 2017 AT 17:00 HOURS | | | | Agenda | | Item No | | Declaration/Conflict of Interests: | | None | ## 7. Public Space Protection Order - Marble Arch 2.1 Cabinet authorised the making of a PSPO to gate the Highway known as Marble Arch in accordance with the results of the public consultation as detailed in Appendix 1 of the report. 2.2 Cabinet approved that the PSPO goes live as soon as the gates can be installed (date dependent on contractor availability). Agenda Item No Declaration/Conflict of Interests: None ## 8. Business Rates - Discretionary Rate Relief 2017/18 2.3 Cabinet agreed that support for small businesses losing Small Business Rate Relief, to limit increases in their bills to the greater of £600 or the transitional relief cap for small businesses, for one year from 1 April 2017. 2.4 Cabinet agreed a £1,000 business rate discount for public houses with a rateable value of up to £100,000, subject to state aid limits for businesses with multiple properties, for one year from 1 April 2017 2.5 Cabinet agreed to support individual businesses in the local area who have large increases in their business rates bills as a result of the 2017 revaluation, by restricting the increase in a bill to a maximum of 5%, for one year from 1 April 2017. Subject to the criteria detailed in the body of the report. Agenda Item No Declaration/Conflict of Interests: None ## 9. Nbc Street Lighting 2.6 Cabinet approved the proposed transfer of up to 607 street lights from NCC to NBC on 2 October 2017. 2.2 Cabinet approved an additional revenue budget of £70,000 per year that is included as part of setting the 2018/19 budget and to address ongoing electricity and maintenance costs. 2.3 Cabinet approved that an additional new budget of £35,000 for the 2017/2018 financial year to fund the additional costs of electricity and maintenance for the existing financial year. To be funded by underspends within the Regeneration, Enterprise & Planning Directorate at the end of the financial year or a drawdown from reserves 2.4 Cabinet noted that further investigation would be undertaken by Officers into an invest to save programme for all NBC street lights that may lead to a further report to Cabinet in due course. An additional capital budget may need to be considered at this point as part of the Council's overall capital programme. 2.5 Cabinet noted that Officers would continue to investigate whether it was appropriate to use the HRA to fund some of the costs of the maintenance or electricity of certain additional street lights. 2.6 Cabinet delegated authority to the Director of Regeneration, Enterprise and Planning, in consultation with the Section 151 Officer and the Deputy Leader of the Council, to conclude the transfer of the responsibility of street lights from NCC to NBC. Agenda Item No Declaration/Conflict of Interests: None ## 10.Revenues And Benefits Joint Committee 2.1.1 Cabinet noted the contents of the Agreement and terms agreed and; 2.1.2. Cabinet noted the recommended appointment of Cllr Brandon Eldred (Cabinet Member for Finance) as the Council representative on the Revenues and Benefits Joint Committee to full Council on September 18th 2017. Agenda Item No Declaration/Conflict of Interests: None ## 11.Adoption Of The Biodiversity Supplementary Planning Document Cabinet adopted the Biodiversity SPD as a statutory Supplementary Planning Document. Agenda Item No Declaration/Conflict of Interests: None ## 12.Northampton Borough Council Local Plan Part 2 - Emerging Site Options Consultation 2.7 Cabinet agreed the Northampton Local Plan (Part 2) Sites Consultation, as shown in Appendix 1 of the report, for public consultation. 2.8 Cabinet noted that the outcome of the Sites Consultation and further work would need to be considered before deciding what would go into the final plan. 2.9 Cabinet agreed the Consultation and Communications Strategy for the Sites Consultation (Appendix 3) of the report. | 2.10 | |--------------------------------------------------------| | Options Paper Consultation (Appendix 2) of the report. | | | | Agenda | | Item No | | Declaration/Conflict of Interests: | | None | ## 13.Adoption Of The Upper Nene Valley Gravel Pits Special Protection Area (Spa) Supplementary Planning Document (Spd) Cabinet adopted the Upper Nene Valley Gravel Pits SPA SPD as a statutory Supplementary Planning Document Agenda Item No Declaration/Conflict of Interests: None ## 14.Semilong/ Trinity Designation Of Neighbourhood Forum & Neighbourhood Area 2.11 Cabinet noted the analysis of representations received in response to the publicising of the Semilong and Trinity Neighbourhood Area and Neighbourhood Forum applications (Appendix 1 of the report) 2.12 Cabinet designated the Semilong and Trinity Neighbourhood Area as published in Appendix 2 of the report for the purposes of preparing a Neighbourhood Plan under Section 61G of the Town and Country Planning Act 1990 (as amended) 2.13 Cabinet agreed that, following the designation of the Semilong and Trinity Neighbourhood Area, Cabinet designates Semilong and Trinity Neighbourhood Forum (Appendix 3) under Section 61F of the Town and Country Planning Act 1990 for a period of five years for the purposes of producing a Neighbourhood Plan, subject to the following conditions:  Maintaining a written constitution  Holding an Annual General Meeting within 12 weeks of the designation  Maintaining a minimum of 21 members drawn from each of the subsections set out within the Localism Act section 61F(5) Cabinet Decision - Exemption from Call in Agenda Item No Declaration/Conflict of Interests: None ## 15.Air Quality Report 2.1 Cabinet acknowledged the excellent work of Scrutiny Panel 4 in the production of their report Emissions Strategy (Action Plan). 2.2 Cabinet would respond to the recommendations of the Scrutiny report as outlined in the report and confirmed that the Low Emissions Strategy would be brought forward for adoption as soon as possible. 2.3 Cabinet endorsed the establishment of a multi-agency Air Quality Working Group to actively engage all stakeholders in the implementation of the Low Emissions Strategy and to develop further air quality initiatives. 2.4 Cabinet endorsed the extension of the Council's air quality monitoring network on a risk based basis to incorporate locations such as schools and residential areas where significant numbers of sensitive receptors may be exposed to elevated concentrations of air pollution. 2.5 Cabinet, noted that the Council was legally required to take action to address recently identified exceedances of air quality objective for Nitrogen Dioxide around Northgate Bus Station and The Drapery, Abington Square and Wellingborough Road, resolved to declare appropriate air quality management areas (AQMAs). 2.6 Cabinet declared a single air quality management area which encompasses existing areas of exceedance in the town centre and newly identified areas of exceedance. As outlined in Appendix 2 of the report 2.7. Cabinet noted that the work undertaken so far in the development of the Strategy is broadly in line with the requirements for the designation of a Non Charging Clean Air Zone as outlined in the DEFRA / DoT Clean Air Zone Framework and authorised the further development of this work with the aim of the development of a Clean Air Zone for Northampton. Agenda Item No Declaration/Conflict of Interests: None ## 16.Finance Monitoring - Period 4 Cabinet reviewed the contents of the report. Agenda Item No Declaration/Conflict of Interests: None ## 17.Museum Expansion - Commencement Of Formal Tender Process To Appoint Main Construction Contractor 2.14 Cabinet approved the commencement of the formal tender process using the LGSS Procurement Framework (LGSS approved supply chain) and tenders be invited for a main construction contractor to undertake the Museum Expansion and exhibition fit-out. 2.15 Cabinet approved an exemption from the Contract Procedure Rules to appoint Creative Good Ltd to provide exhibition design services for the museum expansion project for reasons pursuant to paragraph 3.2.3 of this report. Agenda Item No Declaration/Conflict of Interests: None ## 18.Temporary Changes To Northampton'S Housing Allocations Scheme Cabinet approved the following temporary changes to the Housing Allocations Scheme (set out in detail in Appendix A of the report) for a fixed period of 9 months, commencing on 1 October 2017 and ending on 30 June 2018: (a) Where the Council accepts a rehousing duty to a household whose homelessness application has taken more than 8 weeks to investigate and determine - including those households whose applications are part of the backlog of outstanding homelessness decisions - the household's 'priority date' in the Emergency Band will be adjusted to a date that is 8 weeks after the date that their homelessness application was received; (b) Where a homeless household is living in temporary accommodation and 6 weeks have elapsed since the Council has accepted a rehousing duty to them, Northampton Partnership Homes will proactively consider them for a 'direct offer' - based on their relative priority - and, after notifying the household, the Council and/or Northampton Partnership Homes may undertake 'proxy bidding', for all suitable properties, on their behalf; and (c) Northampton Partnership Homes will set aside an average of up to 5 properties a fortnight for 'direct offers' to homeless households for whom the Council has accepted a housing duty. ## Agenda Item No Declaration/Conflict of Interests: None ## 19.Improving The Efficiency Of The Homelessness Reviews Service a)Cabinet approved the outsourcing of the homelessness reviews function to a suitably qualified person or organisation on a contracted basis; b)Cabinet delegated to the Borough Secretary, in consultation with the Chief Finance Officer and the Cabinet Member for Housing and Wellbeing, the authority to award the homelessness reviews contract for a period of 2 years with an option for a third year. Agenda Item No Declaration/Conflict of Interests: None ## 20.Disposal Of Open Space At Lancaster Way This item was deferred.
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The National Archives undertook an Information Management Assessment of the Environment Agency in May 2009. A report was published on The National Archives highlighting 31 recommendations. An action plan was subsequently developed by the agency. The National Archives' report rated the Environment Agency as "Good" under five out of 20 headings and "Satisfactory" under a further seven. The report identified eight headings where particular attention was needed and where further work would improve the agency's all-round performance. A formal review of progress against the agency's action plan was held on 2 June 2010, with improvement recognised by The National Archives under four out of 20 headings. Further action plan review meetings were held in February and December 2011 at which the agency's efforts to tackle areas of concern and raise the profile of information management were outlined. Following these, it was mutually agreed that the agency had made sufficient progress for the action plan to be closed. Remaining issues will be taken forward via
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# Department For Work And Pensions Equality Information Update 2012 List of tables.....................................................................................................3 Introduction ......................................................................................................5 Section 1: Information about our policies and services....................................6 Employment related impact indicators..........................................................9 1. Rates of people moving off out of work benefits ...................................9 2. Numbers on key out-of-work benefits .................................................11 3. Proportion of children living in workless households...........................17 4. Young people not in employment or full-time education .....................20 5. Gap between the employment rates for disabled people and the overall population ...............................................................................................22 6. Average age people stop working.......................................................25 Poverty and social mobility related impact indicators .................................27 7. Rate of disability poverty.....................................................................27 8. Rate of pensioner poverty...................................................................31 9. Social mobility in adulthood ................................................................34 Pensions-related impact indicators.............................................................36 10. Number of employees in a pension scheme sponsored by their employer.................................................................................................36 Operational working of the Department related impact indicators ..............38 11. Monetary value of fraud and error in the benefit system...................38 12. Public opinion of DWP service levels................................................39 13. Additional customer data ..................................................................45 Section 2: Information about our employees..................................................47 14. The DWP workforce..........................................................................47 15. Disciplinary procedures.....................................................................52 16. Exits..................................................................................................54 17. Working Patterns ..............................................................................57 18. Grievances........................................................................................59 19. Performance markings......................................................................61 20. Promotion .........................................................................................62 21. Recruitment process.........................................................................64 22. Pay gap.............................................................................................65 23. Training data.....................................................................................69 24. Maternity data...................................................................................70 25. Links to additional information ..........................................................71 ## List Of Tables Employment Table 1.1-1.2: Number and rates of people moving from out-of-work benefits. Table 2.1-2.3: Number of people on key out-of-work benefits by age, ethnicity and gender. Table 3.1-3.3: Percentage of children in each economic activity status of household category by age, gender, and ethnic origin of child. Table 4.1-4.3: Percentage of young people not in full-time education who are workless by disability, ethnicity and gender. Table 5.1-5.4: Gap between employment rates for disabled people and the overall population by age, ethnicity, gender and religion. Table 6.1-6.3: Average age of withdrawal from the labour market by ethnicity and gender, gender overall and by gender and religion or belief. Poverty and social mobility Table 7.1-7.4: Poverty rate for families by presence of disabled members and age, disabled members overall, disabled members and ethnicity and disabled members and gender. Table 8.1-8.4: Poverty rate for pensioners by age, disability, ethnic group of head of household and gender. Table 9.1: Percentage in the bottom income quintile that have progressed in the distribution of earnings. Pensions Table 10.1-10.2: Numbers of employees in a pension scheme sponsored by their employer by age and gender. Operational working of the Department Table 12.1-12.8: Customers' reported overall satisfaction with Jobcentre Plus and the Pension, Disability and Carers Service by age, disability, ethnicity and gender. Additional customer data Table 13.1: Percentage of employment gaps for various protected characteristics. DWP workforce data Table 14.1-14.4: Percentage of DWP workforce by age, disability, ethnicity and gender. Table 15.1-15.4: Percentage of employees disciplined by age, disability, ethnicity and gender. Table 16.1-16.4: Percentage of reason for leaving by age, disability, ethnicity and gender. Table 17.1-17.4: Percentage of employees with a part-time working pattern by age, disability, ethnicity and gender. Table 18.1-18.4: Percentage of employees raising a grievance by age, disability, ethnicity and gender. Table 20.1-20.4: Percentage of employees promoted by age, disability, ethnicity and gender. Table 22.1-22.4: Pay gap by age, disability, ethnicity and gender. Table 24.1-24.4: Percentage of employees returning from maternity leave by age, disability and ethnicity. ## Introduction On 31 January 2012 the Department published its first Equality Information report under the Public Sector Equality Duty. Whilst the legal requirement is an annual publication, the initial report committed to aligning information with the Department's reporting cycle by producing an update in July 2012. This update follows the same format as the original report: Section One shows information and data relating to the Department's policies, practices and service users; and Section Two shows information and data relating to the Department's employees. Future reporting The Department intends to publish a comprehensive Equality Information report in July 2013. This will include an annual data update and also progress made in the detailed areas of the first report about our approach to: - providing information about our policies, practices and services; - providing information relating to our employees; - benchmarking as an employer; - engaging with our employees; - engaging with our service users; - paying due regard; and - equality objectives. Notes to data Changes to the presentation of tables and amendments required following the first report are clearly explained in the commentary next to the relevant tables. Alternative formats If you would like a copy of this update in an alternative format please contact: Diversity and Equality Directorate, Porterbrook House, 7 Pear Street, Sheffield, South Yorkshire, S11 8JF. Email: Adelphi.diversityandequality@dwp.gsi.gov.uk Thank you for taking the time to read this update, we welcome your feedback. Please write to us using the details above. ## Section 1: Information About Our Policies And Services | Number Indicator | Data source | |--------------------------------------------------------------------------|-------------------------------| | 1 | Rates of people moving | | from out-of-work benefits | | | DWP administrative | | | data | | | - | | | | | | Latest data available for claimants that have flowed off Jobseekers | | | Allowance was from January-March 2011 and March 2012. Whereas, | | | latest data for claimants flowing off Employment and Support Allowance | | | was from October-December 2010 and March 2012. | | | 2 | Numbers on key out-of- | | work benefits | | | DWP administrative | | | data | | | - | | | | | | Splits currently available by age and gender, and partly for ethnicity. | | | - | | | | | | Latest data available at July 2012 covered November 2011. | | | - | | | | | | Produced four times a year covering the months of February, May, | | | August and November. Data are available with six months delay. | | | 3 | Proportion of children living | | in workless households | | | Labour Force | | | Survey | | | - | | | | | | Splits currently available by age, ethnicity and gender. | | | - | | | | | | Latest data available at July 2012 covered Quarter 4 2011. | | | - | | | | | | Produced twice a year. Data are available for Quarter 2 and Quarter 4 | | | each year with a delay of around six weeks after the period referred to. | | | 4 | Young people not in | | employment or full-time | | | education | | | Labour Force | | | Survey | | | - | | | | | | Impact indicator covers age. Splits currently available by disability, | | | ethnicity and gender. | | | - | | | | | | Latest data available at July 2012 covered Quarter 1 2012. | | | - | | | | | | Produced monthly approximately six weeks after the period referred to. | | | Three months of data are combined for the indicator. | | | 5 | Gap between employment | | rates for disabled people | | | and the overall population | | | Labour Force | | | Survey | | | - | | | | | | Impact indicator covers disability. Splits currently available by age, | | | ethnicity, gender and religion or belief. | | | - | | | | | | Latest data available at July 2012 covered Quarter 1 2012. | | | - | | | | | | Produced quarterly approximately six weeks after the period referred to. | | | Three months of data are combined for the indicator. | | | Number Indicator | Data source | m | Ti | |------------------------------------------------------------------------------|------------------------------|------------------|------| | 6 | Average age people stop | | | | working | | | | | Labour Force | | | | | Survey | | | | | - | | | | | | | | | | Splits currently available by age, ethnicity, gender and religion or belief. | | | | | - | | | | | | | | | | Latest data available at July 2012 covered Quarter 1 2011 for gender, | | | | | and 4 quarter averages (to increase data reliability for these groups) | | | | | from Quarter 2 2011 to Quarter 1 2012 for ethnicity and religion or | | | | | belief. | | | | | - | | | | | | | | | | Produced quarterly approximately six weeks after the period referred to. | | | | | 7 | Rate of disability poverty | Family Resources | | | Survey | | | | | - | | | | | | | | | | Indicator covers disability. Splits currently available by age, ethnicity | | | | | and gender. Information on religion or belief and sexual orientation has | | | | | been collected from April 2011. Results are expected to be available in | | | | | Spring/Summer 2013. | | | | | - | | | | | | | | | | Latest data available at July 2012 covered 2010/11. | | | | | - | | | | | | | | | | Produced once a year covering a financial year, with a delay of just over | | | | | a year after the end of the period referred to. | | | | | - | | | | | | | | | | Data do not include care home residents due to the sample for the | | | | | survey used consisting of the private household population. | | | | | 8 | Rate of pensioner poverty | Family Resources | | | Survey | | | | | - | | | | | | | | | | Splits currently available by age, disability, ethnicity and gender. | | | | | Information on religion or belief and sexual orientation has been | | | | | collected from April 2011. Results are expected to be available in | | | | | Spring/Summer 2013. | | | | | - | | | | | | | | | | Latest data available at July 2012 covered 2010/11. | | | | | - | | | | | | | | | | Produced once a year covering a financial year, with a delay of just over | | | | | a year after the end of the period referred to. | | | | | - | | | | | | | | | | Data do not include care home residents due to the sample for the | | | | | survey used consisting of the private household population. | | | | | 9 | Social mobility in adulthood | Annual Survey of | | | Hours and | | | | | Earnings | | | | | - | | | | | | | | | | Likelihood of progression of 25-30 year olds by gender. Data for other | | | | | protected characteristics are not currently available. | | | | | - | | | | | | | | | | Latest data available at July 2012 covered 2002-2011. | | | | | | | | | | | | | | | | | | | | | | Page 7 | | Number Indicator Data source m Ti e period and availability 10 Number of employees in a pension scheme sponsored by their employer Annual Survey of Hours and Earnings - Splits currently available by age and gender. This will be supplemented by data from the Family Resources Survey for religion or belief and sexual orientation which has been collected from April 2011. Results are expected to be available in Spring/Summer 2013. - Latest data available at July 2012 covered 2011. 11 Monetary value of fraud and error in the benefit system DWP administrative data - No equality information currently available. We are considering the feasibility of collecting this and will provide an update in the next report. 12 Public opinion of DWP service levels DWP administrative data - Splits currently available by age, disability, ethnicity and gender. - The latest data available at July 2012 covered 2011 for Jobcentre Plus and 2010/11 for the Pension, Disability and Carers Service. Produced once a year. 13 Employment gap Labour Force Survey - Indicator focuses on disabled people, splits are available by age (for young adults and older workers), ethnicity and disability. - Data available approximately six weeks after the end of each quarter. - Data are seasonally unadjusted so only year on year comparisons can be made. Note: Estimates are based on a variety of data sources and are therefore subject to uncertainty. Small differences should be treated with caution as these will be affected by sampling error and variability in the data source. ## Employment Related Impact Indicators 1. Rates Of People Moving Off Out-Of-Work Benefits1 What does this tell us? This indicator reports off-flow rates for cohorts of customers who flow onto each benefit in a given period. For example: across all ages 87.2% of those starting to receive Jobseeker's Allowance between January and March 2011 had stopped receiving the benefit 52 weeks later; 73.6% of 25-49 year olds who claimed Employment and Support Allowance between October and December 2010 had stopped receiving the benefit 65 weeks later. This measure is included because Jobcentre Plus adds value by reducing the time it takes for a customer to move off benefit. The Jobseekers Allowance portion of the measure directly affects the claimant count, and the measure as a whole will provide useful information as to whether the Department's spending review settlement is being implemented. How will an improvement be shown? An increase in the indicator will demonstrate whether an improvement has been achieved. However, the indicator level will be affected by benefit conditionality and operational changes, seasonal variation and the economic cycle. For example, in a recession, even if Jobcentre Plus is performing well, the off-flow rate is likely to fall. Also, as Incapacity Benefit claims are reassessed for Employment and Support Allowance the off-flow rate is likely to fall. Links to other information that you may find useful A one-off Destination Survey was undertaken by the Department in 2011 which provides data on the rate of people moving from key out-of-work benefits into employment. substitute this data so the scope of the indicator has been reduced accordingly. claims received between January-March 20111,2,3,5,7 Age Total on-flow Total off-flow Rate 16-17 5,900 5,460 92.5% 18-24 309,340 279,960 90.5% 25-49 420,170 356,670 84.9% 50+ 101,060 87,660 86.7% Unknown Age6 70 70 100.0% Total 836,530 729,810 87.2% weeks, for claims received between October-December 20101,2,4,5,7 Age Total on-flow Total off-flow Rate 16-17 1,300 650 50.0% 18-24 26,840 20,950 78.1% 25-49 99,150 72,970 73.6% 50+ 48,970 34,730 70.9% Unknown age6 10 10 100.0% Total 176,270 129,310 73.4% All data sourced from: DWP administrative data, Jobseeker's Allowance Processing System (JSAPS). Notes: 1. The on-flow cohort period corresponds to the reporting month beginning on the Saturday after the final Friday of the previous month and ending on the final Friday of the current month. This data covers three on-flow cohort periods. 2. The rate is calculated as the total number of off-flows from an on-flow cohort period, divided by the number of on flows within the on-flow cohort period, multiplied by 100 (to one decimal place). 3. On-flow and off-flow figures rounded to the nearest 10. 4. Off-flow for Jobseeker's Allowance is based on claims ending within 52 weeks of on-flow. 5. Off-flow for Employment and Support Allowance is based on claims ending within 65 weeks of on-flow. 6. There are a small number of cases having an incorrect date of birth recorded on the Administrative Systems (JSAPS). 7. Due to seasonal movements in benefit claiming patterns only year on year comparisons should be made. ## 2. Numbers On Key Out-Of-Work Benefits What Does This Tell Us? This Indicator Looks At The Number Of People On The Following Key Out-Of-Work Benefits: - Jobseeker'S Allowance; - Incapacity Benefits/Employment and Support Allowance; - Lone parents receiving Income Support; and - Others receiving income-related benefits. These are mainly Pension Credit recipients for men aged under state pension age. The remainder are in receipt of Income Support. How will an improvement be shown? This indicator will show an improvement if the number of people in receipt of key out-of-work benefits decreases, reflecting the Department's economic and social objective of helping more people into employment. Links to other information that you may find useful Further information about a variety of benefits and customer groups is available on the DWP tabulation tool. Lone Parents on Income Support Employment and Support Allowance and Incapacity Benefits 5, 7 Age Jobseeker's Allowance (claimant count) (UK seasonally adjusted) 3 5 Jobseeker's Allowance (claimant count) (GB not seasonally adjusted) 4 Other (Income Support, others and Pension Credit) 5,6 Unknown age .. - 0.1 - 0.3 Under 18 .. 3.9 4.7 4.5 10.6 18-24 .. 452.4 153.5 170.0 27.4 25-34 .. 361.9 333.0 249.1 6.7 35-44 .. 302.4 546.8 128.2 4.6 45-49 .. 148.1 380.3 21.1 2.7 50-54 .. 116.9 404.4 6.6 3.0 55-59 .. 89.4 446.6 2.0 3.8 60-64 .. 21.3 306.3 0.2 115.8 | Ethnicity | Jobseeker's | |-------------------------|----------------| | Allowance (claimant | | | count) (UK | | | seasonally adjusted) | | | Jobseeker's | | | Allowance (claimant | | | count) | | | (GB not seasonally | | | adjusted) | | | 4 | | | Employment and | | | Support Allowance | | | and Incapacity | | | Benefits | | | 5, 7 | | | Lone Parents | | | on Income | | | Support | | | 5 | | | Other (Income | | | Support, others | | | and Pension | | | Credit) | | | 5,6 | | | | | | 3 | | | White: British | .. | | White: Irish | .. | | White: Other white | .. | | Mixed: White & Black | | | Caribbean | | | .. | 13.9 | | Mixed: White & Black | | | African | | | .. | 4.0 | | Mixed: White & Asian | .. | | Mixed: Other Mixed | .. | | Asian or Asian British: | | | Indian | | | .. | 24.0 | | Asian or Asian British: | | | Pakistani | | | .. | 34.8 | | Asian or Asian British: | | | Bangladeshi | | | .. | 15.2 | | Asian or Asian British: | | | Other Asian | | | .. | 12.3 | | Black or Black British: | | | Black Caribbean | | | .. | 45.4 | | Black or Black British: | | | Black African | | | .. | 46.0 | | | | | Black or Black British: | .. | | Ethnicity | Jobseeker's | |-----------------------|----------------| | Allowance (claimant | | | count) (UK | | | seasonally adjusted) | | | 3 | | | Jobseeker's | | | Allowance (claimant | | | count) | | | (GB not seasonally | | | adjusted) | | | 4 | | | Other Black | | | Chinese or Other | | | Ethnic Group: Chinese | | | .. | 3.0 | | Chinese or Other | | | Ethnic Group: Other | | | Ethnic Group | | | .. | 27.4 | | Prefer not to say | .. | | Missing/old values/no | | | personal contact | | | .. | 19.5 | | | | | | | | Employment and | | | Support Allowance | | | and Incapacity | | | Benefits | | | 5, 7 | | | Lone Parents | | | on Income | | | Support | | | 5 | | | Other (Income | | | Support, others | | | and Pension | | | Credit) | | | 5,6 | | | | | Lone Parents on Income Support Employment and Support Allowance and Incapacity Benefits 5, 7 Gender Jobseeker's Allowance (claimant count) (UK seasonally adjusted) 3 5 Jobseeker's Allowance (claimant count) (GB not seasonally adjusted) 4 Other (Income Support others and Pension Credit) 5,6 Male 1068.2 997.8 1440.6 16.3 133.0 Female 527.8 501.6 1135.0 565.3 41.9 All data sourced from: DWP Administrative Data; Columns 1 and 2 from the Jobseeker's Allowance (JSA) Claimant Count. Definitions and conventions: "-" Nil or negligible ".." Not available. Caseload figures are rounded to the nearest hundred. Some additional disclosure control has also been applied. Totals may not sum due to rounding. State pension age: The age at which women reach state pension age is gradually increasing from 60 to 65 between April 2010 and April 2016 to November 2018. From December 2018, the state pension age for both men and women will start to increase to reach 66 years old in October 2020. This will introduce a small increase to the number of working-age benefit recipients and a small reduction to the number of pension-age recipients. For more information see http://statistics.dwp.gov.uk/asd/espa.pdf. Notes: 1. This table includes the key out-of-work client group categories, with the exception of carers who are not subject to activation policies in the same way as other groups. 2. Tables present just one JSA series. The United Kingdom (UK) seasonally adjusted series is not broken down by age or ethnicity, but is available by gender. The JSA series in the second column covers Great Britain (GB) and is not seasonally adjusted. This series is presented as it allows comparisons with the other key out-of-work benefits published by DWP which also cover GB and are not seasonally adjusted. GB JSA totals for ethnicity and age are lower than they are for gender, as gender is available on the 1 per cent of clerical cases but ethnicity and age are not. 3. UK figures (seasonally adjusted) published by the ONS. This series is the most reliable and up-to-date source for claimant unemployment. 4. GB figures (not seasonally adjusted) published by the Office for National Statistics. This series is the most reliable and up-to-date source for claimant unemployment. 5. GB figures (not seasonally adjusted). Published by DWP as part of the 100 per cent working-age client group analysis. A consistent series for the UK as a whole is not readily available. 6. Excludes claimants in receipt of Income Support and Carers Allowance. 7. The "Incapacity Benefits group" includes Employment and Support Allowance (ESA). ESA replaced Incapacity Benefit and Income Support paid on the grounds of incapacity for new claims from 27 October 2008. ## 3. Proportion Of Children Living In Workless Households What does this tell us? This indicator looks at the proportion of children living in workless households in the UK. A workless household is a household that includes at least one person aged 16 to 64 where no-one aged 16 or over is in employment. This indicator reflects the Department's core aims around employment and preventing worklessness. How will an improvement be shown? Generally, an improvement would be demonstrated by a fall in the indicator. Such a change would imply a rise in the proportion of children living in a household with at least one working adult. However other factors, for example, changes in household types over time may also influence estimates. Links to other information that you may find useful Further information is available on the Office of National Statistics website. category by age of child, October-December 20111,2 Combined economic activity status of household Workless households All children Age of child Working households Households containing both working and workless members Under 1 54.5 29.5 16.1 6.2 1 50.0 30.7 19.3 6.9 2 51.4 31.4 17.2 6.9 3 51.9 31.0 17.2 6.7 4 50.9 29.6 19.6 6.7 5 51.4 30.1 18.5 6.7 6 51.8 29.9 18.3 6.1 7 53.8 29.3 17.0 6.2 8 52.9 30.8 16.3 5.8 9 53.1 32.2 14.7 5.7 10 53.2 32.9 13.9 6.0 11 52.5 32.8 14.8 5.7 12 53.8 33.0 13.2 5.9 13 49.5 38.0 12.5 5.9 14 48.6 39.6 11.7 6.5 15 48.5 38.4 13.1 6.0 All 51.7 32.4 15.8 100.0 category by gender of child, October-December 20111,2 Combined economic activity status of household Gender of child Working households Workless households All children Households containing both working and workless members Male 51.1 32.5 16.4 51.2 Female 52.3 32.3 15.5 48.8 All 51.7 32.4 15.9 100.0 | | Combined economic activity status of household | |--------------|---------------------------------------------------| | Workless | | | households | | | | All | | children | | | Working | | | households | | | Ethnic | | | origin of | | | child | | | Households | | | containing | | | both | | | working | | | and | | | workless | | | members | | | White | 56.3 | | Mixed | 46.4 | | 24.4 | 60.9 | | Asian | | | British | | | 30.1 | 34.7 | | Black | | | British | | | 29.9 | 46.7 | | Chinese or | | | other ethnic | | | group | | | All | | | 3 | | | | 51.7 | All data sourced from: Labour Force Survey household datasets. Notes: 1. Children refers to children under 16. 2. Households including at least one person aged 16 to 64. 3. Total includes children with unknown ethnic origin. ## 4. Young People Not In Employment Or Full-Time Education What does this tell us? This indicator shows the percentage of young people that are not in employment or full-time education. It is measured by dividing the number of 18- 24 year olds who are not in work or full-time education by the total number of 18-24 year olds. The indicator will measure the Department's success in improving the percentage of young people engaged in a positive activity such as employment, education or training. It recognises the importance of raising participation in education and improving labour market outcomes for young people not in full-time education. How will an improvement be shown? Generally, a decrease in the indicator will demonstrate an improvement in the labour market position of young people. However, economic conditions will also need to be taken into account. Links to other information that you may find useful Further information about the Department's business plan transparency measures is available here. workless by disability, UK, Quarter 1 2012 (January 2012-March 2012)1,2 | Disability status | Percentages | |--------------------------------------------------------------------------|---------------| | Disabled | 57.6 | | Non-disabled | 30.1 | | All | 33.0 | | | | | Table 4.2: Percentage of young people not in full-time education who are | | | workless by ethnicity, UK, quarterly average Quarter 1 2010 to Quarter 4 | | | 2010 (January 2010-December 2010) | | | 1,3,4 | | | | | | | | | Ethnic group of individual | Percentages | | White | 30.8 | | Mixed | 43.5 | | Asian or Asian British | 48.3 | | Black or Black British | 50.1 | | Chinese or other ethnic group | 53.8 | | All | 32.5 | | | | | | | | Gender | Percentages | |-----------|---------------| | Male | 31.4 | | Female | 34.7 | | All | 33 | All data sourced from: Labour Force Survey (LFS). Notes: 1. This data is fully comparable with the overall measure for young people not in employment or full-time education using the ONS seasonally adjusted data 2. As with the overall measure for young people not in employment or full-time education, this measure uses LFS data. However, unlike the overall measure, this data is not seasonally adjusted and only released quarterly. Therefore it is not fully comparable with the overall measure. 3. Disability includes those who are disabled under the Equality Act definition, those who are work-limiting disabled only, and those who are both. It covers the individual rather than the household. 4. Data for young people not in full-time education and who are workless split by ethnicity is currently not available. Therefore, the most recent reliable figures are the same as those reported in the Equality Information 2011 report. ## 5. Gap Between The Employment Rates For Disabled People And The Overall Population What does this tell us? This indicator is measured by comparing the seasonally unadjusted employment rate for disabled people with the unadjusted working-age employment rate for Great Britain. This uses the ONS Headline Rate definition of employment which is for people aged between 16 and 64. These data allow the Department to monitor progress towards employment equality for disabled people. It allows the public to assess how well the Department is performing against its aim of promoting high levels of employment by helping people move into work. How will an improvement be shown? Generally a decrease in the indicator will demonstrate that an improvement has been achieved. However, economic conditions will also need to be taken into account. For example, recent research indicates that employment prospects for disabled people are less sensitive to economic conditions than the overall population.2 This may mean that as the economy improves and overall rates increase, the gap between the disabled and the overall employment rates will increase, which would represent a negative outcome for this indicator. Links to other information that you may find useful A full description of indicators towards disability equality by 2025 is available on the Independent Living and Office for Disability Issues website. overall population by age, Great Britain, Quarter 1 2012 (January 2012- March 2012)1 Age Gap (percentage points) 16-17 6.7 18-24 16.6 25-34 26.3 35-44 26.9 45-54 26.6 55+ 20.9 overall population by ethnicity, Great Britain, Quarter 2 2011 to Quarter 1 2012 (April 2011-March 2012)3,6 Ethnicity Gap (percentage points) White 25.1 Mixed / Multiple ethnic groups 15.7 Indian 24.5 Pakistani 20.1 Bangladeshi 18.6 Chinese * Any other Asian background 20.2 Black / African / Caribbean / Black British 18.9 Other ethnic group 21.0 Table 5.3: Gap between employment rates for disabled people and the overall population by gender, Great Britain, Quarter 1 2012 (January 2012- March 2012) Gender Gap (percentage points) Male 26.4 Female 21.3 | Religion | Gap (percentage points) | |--------------------|---------------------------| | Christian | 24.0 | | Buddhist | 24.7 | | Hindu | 22.5 | | Jewish | 21.4 | | Muslim | * | | Sikh | 20.3 | | Any other religion | 21.7 | | No religion at all | 27.0 | All data sourced from: Labour Force Survey. Notes: 1. Care should be taken when comparing Table 5.1 with last years report due to an error in estimates for the gap between employment rates for disabled people and the overall population by age in Jan-Mar 2011. Comparisons should be made with the correct version which is available here. 2. Data are rounded to the nearest 0.1 percentage point. 3. * denotes sample size is too small to reliably quote estimates. 4. Data are subject to sampling variation and is not seasonally adjusted. 5. Accuracy of data is limited by small sample sizes. 6. Ethnicity is self-reported. 7. Religion or belief is self-reported. ## 6. Average Age People Stop Working3 What does this tell us? This indicator is measured using the 'average age of withdrawal from the labour market-static indicator'. High level figures which are not broken down for equality groups are published by ONS annually in the Pension Trends series. This indicator measures the ages at which people withdraw from the labour market and become inactive; data are not seasonally adjusted. Due to the nature of the indicator, year on year changes tend to be small. The focus should not be on the short-term changes but on the long-term trend. Extending working life is an important part of the response to demographic ageing and ensuring pensions sustainability. Monitoring changes in average age of withdrawal will provide an indication of how the Department's policies are encouraging longer working. How will an improvement be shown? An increase in the age of withdrawal from the labour market would constitute a success. There may be a number of contributing factors including: a continuation of long-term trends; changing attitudes around working longer; and the effect of state pension age changes. Links to other information that you may find useful Further information on the labour market and retirement is available in the ONS report on Pension Trends. Table 6.1: Average age of withdrawal from the labour market by ethnicity and gender, Great Britain, Quarter 2 2011 to Quarter 1 2012 (April 2011- March 2012)3,4 Ethnic group of individual Men Women White 64.5 62.6 Mixed 60.7 58.0 Asian or Asian British 64.3 59.9 Black or Black British 61.2 61.9 White and Asian 62.3 59.4 Table 6.2: Average age of withdrawal from the labour market by gender, Great Britain, Quarter 1 2011 (January- March 2012) Age of withdrawal from labour market Men Women Age 64.6 62.4 Table 6.3: Average age of withdrawal from the labour market by gender and religion or belief, Great Britain, Quarter 2 2011 to Quarter 1 2012 (April 2011-March 2012)5,6,7 Religion Men Women Christian 64.4 62.4 Buddhist 62.1 59.6 Hindu 64.1 59.2 Jewish 63.4 62.4 Muslim 63.4 56.9 Sikh 61.0 58.3 Any other religion 63.0 61.3 No religion 64.6 63.1 All data sourced from: Labour Force Survey (LFS). Notes: 1. Data are rounded to the nearest 0.1 year. 2. Data are subject to sampling variation and is not seasonally adjusted. 3. Ethnicity is self-reported. 4. Changes to the collection of data on ethnicity in the LFS mean that the latest data may not be comparable with previous years. 5. Data covers Great Britain only. 6. Religion or belief is self-reported. 7. Accuracy of data is limited by small sample. ## Poverty And Social Mobility Related Impact Indicators 7. Rate Of Disability Poverty What does this tell us? This indicator measures the percentage of individuals in families containing someone who is disabled with incomes below 60 per cent of equivalised median income4, Before Housing Costs. Tackling disability poverty is a priority as families with a disabled member have a higher rate of relative low-income poverty than average. Using 60 per cent of equivalised median income as a poverty threshold is a historical and international benchmark. These data do not include care home residents due to the sample for the survey used consisting of the private household population. No adjustment is made to disposable household income to take into account any additional costs that may be incurred due to the illness or disability in question, and disability benefits have been included in the equivalised household income used. This means that the position in the income distribution of these groups, as shown here, may have some upward bias. Results based on incomes excluding disability benefits are available on request. How will an improvement be shown? Generally a decrease in the indicator will demonstrate that an improvement has been achieved. However, economic conditions also need to be taken into account. Links to other information that you may find useful For further information, a full description of indicators towards disability equality by 2025 can be found on the Independent Living and Office for Disability Issues website. Further analysis of Households Below Average Income (HBAI) data are shown in the annual HBAI publication. | Group | Age | Poverty rate (%) | |--------------------|--------------------|---------------------| | | | Families with | | a disabled | | | | member | | | | Families with | | | | no disabled | | | | member | | | | Children | 0-4 | 25 | | | 5-10 | 19 | | | 11-15 | 22 | | 23 | 17 | | | children | | | | Working-age adults | 16-19 adults | 33 | | | 20-24 | 24 | | | 25-29 | 26 | | | 30-34 | 23 | | | 35-39 | 20 | | | 40-44 | 20 | | | 45-49 | 21 | | | 50-54 | 20 | | | 55-59 | 23 | | | 60-64 males only | 22 | | Pensioners | 60-64 females only | 16 | | | 65-69 | 14 | | | 70-74 | 14 | | | 75-79 | 18 | | | 80-84 | 18 | | | 85+ | 22 | Poverty rate (%) Families with a disabled member Families with no disabled member Poverty rate 20 15 | Poverty rate (%) | Ethnic group of head | |---------------------------|--------------------------| | (3-year average) | | | | Families with a disabled | | member | | | Families with no | | | disabled member | | | White | 20 | | Mixed | 28 | | Asian or Asian British | 40 | | Indian | 31 | | Pakistani and Bangladeshi | 52 | | Black or Black British | 32 | | Black Caribbean | 26 | | Black Non-Caribbean | 38 | | 36 | 24 | | group | | Poverty rate (%) Families with a disabled member Families with no disabled member Male child 20 15 Female child 24 17 Male working-age adult 22 14 Female working-age adult 21 13 Male pensioner 15 15 Female pensioner 17 20 All data sourced from: Households Below Average Income (HBAI) 2010/11. Notes: 1. This indicator is measured using HBAI statistics sourced from the Family Resources Survey. The indicator measures the percentage of individuals in families containing someone who is disabled with household income below 60 per cent of contemporary equivalised median income, Before Housing Costs. Data are annual with approximately a 12 month time lag after the end of the survey period. 2. All estimates are based on survey data and are therefore subject to uncertainty. Small differences should be treated with caution as these will be affected by sampling error and variability in non-response. 3. Estimates showing ethnic breakdowns are presented as three-year averages because of small sample sizes. However, the figures must still be treated with some caution, as the sample sizes are still small for certain ethnic minority groups. 4. Percentages of individuals in low-income households have been rounded to the nearest percentage point. 5. Disability is defined as having any long-standing illness, disability or impairment that leads to a substantial difficulty with one or more areas of the individual's life. Everyone classified as disabled under this definition would also be classified as disabled under the Equality Act 2010. However, some individuals classified as disabled under the Equality Act 2010 would not be captured by this definition. 6. Results cover the financial year 2010/11, i.e. April 2010 to March 2011. ## 8. Rate Of Pensioner Poverty What does this tell us? The indicator measures the percentage of pensioners in households with incomes below 60 per cent of equivalised median income, after housing costs. The Government wants all pensioners to have a decent and secure income in retirement. Key strategies include the restoration of the earnings link for the basic State Pension and the "triple guarantee" that the basic State Pension will increase by the highest of earnings growth, price increases or 2.5 per cent. In addition, the Government is protecting key benefits for older people, including Winter Fuel Payments, free prescriptions, and free TV licences for those aged 75 and over. Automatic enrolment will be introduced into workplace pensions from 2012 to reinvigorate private pension savings, and it was announced in the Budget 2012 that the Government will reform the State Pensions system to introduce a single tier pension for future pensioners, which will lead to a simpler and fairer system that reduces the need for means testing and supports saving. How will an improvement be shown? Generally, a decrease in this indicator will demonstrate that an improvement has been achieved, but external factors such as wider economic conditions also need to be taken into account. Links to other information that you may find useful Further analysis of Households Below Average Income (HBAI) data are shown in the annual HBAI publication. | Age | Poverty rate (percentage of | |--------------------------|--------------------------------| | pensioners in low income | | | households) | | | 60-64 | 14 | | 65-69 | 12 | | 70-74 | 13 | | 75-79 | 14 | | 80-84 | 16 | | 85+ | 18 | | Disability status | Poverty rate (percentage of | |-------------------------------------------------------------------|------------------------------------| | pensioners in low income | | | households) | | | 14 | Those living in families where no- | | one is disabled | | | 14 | Those living in families where | | someone is disabled | | | | | | Table 8.3: Poverty rate for pensioners by ethnic group of head of | | | household, UK, 2008/09-2010/11 | | | 1,2,3,6,7 | | | | | | | | | Ethnic group of head | | | (3-year average) | | | Poverty rate (percentage of | | | pensioners in low income | | | households) | | | White | 15 | | Mixed | .. | | Asian or Asian British | 32 | | Indian | 31 | | Pakistani and Bangladeshi | 38 | | Black or Black British | 24 | | Black Caribbean | 22 | | Black Non-Caribbean | .. | | Chinese or other ethnic group | 31 | | Gender | Poverty rate (percentage of | |--------------------------|--------------------------------| | pensioners in low income | | | households) | | | Male | 13 | | Female | 15 | All data sourced from: Households Below Average Income (HBAI) 2010/11. Notes: 1. This indicator is measured using HBAI statistics sourced from the Family Resources Survey. The indicator measures the percentage of pensioners with incomes below 60 per cent of contemporary equivalised median income, after housing costs. Data are annual with approximately a 12 month time lag after the end of the survey period. 2. All estimates are based on survey data and are therefore subject to uncertainty. Small differences should be treated with caution as these will be affected by sampling error and variability in non-response. Estimates showing ethnic breakdowns are presented as three-year averages because of small sample sizes. However, the figures must still be treated with some caution, as the sample sizes are still small for certain ethnic minority groups. 3. Percentages of individuals in low-income households have been rounded to the nearest percentage point. 4. Disability is defined as having any long-standing illness, disability or impairment that leads to a substantial difficulty with one or more areas of the individual's life. Everyone classified as disabled under this definition would also be classified as disabled under the Equality Act 2010. However, some individuals classified as disabled under the Equality Act 2010 would not be captured by this definition. 5. No adjustment is made to disposable household income to take into account any additional costs that may be incurred due to the illness or disability in question, and disability benefits have been included in the equivalised household income used. This means that the position in the income distribution of these groups, as shown here, may be somewhat upwardly biased. Results based on incomes excluding disability benefits are available on request. 6. '..' means data are not available due to small sample size. 7. Results cover the financial year 2010/11, i.e. April 2010 to March 2011. ## 9. Social Mobility In Adulthood What does this tell us? This indicator measures the percentage of people aged 25-30 that started out in the bottom quintile of the earnings distribution that have moved up the distribution by twenty or more percentiles in a ten-year period. The Social Mobility Strategy committed DWP to developing an indicator of wage progression, whilst acknowledging that other indicators of labour market success will also form part of a wider suite of indicators of social mobility in adulthood. How will an improvement be shown? An increase in the percentage of the group that progressed in the labour market will demonstrate an improvement in social mobility. However, the percentage with no data available will also need to be taken into account. Links to other information that you may find useful Further information on this indicator is available in the Proportion of lowest earners experiencing wage progression report. Additional indicators of social mobility in adulthood are available from the Cabinet Office website. from the bottom earnings quintile, Great Britain, 2002-20111,2,3,4 Of which (%) All (%) Male Female Progressed5 12 12 12 Did not progress6 41 38 43 No data available7 47 50 45 Total 100 100 100 All data sourced from: DWP analysis of the Office for National Statistics Annual Survey of Hours and Earnings (ASHE). Notes: 1. This indicator is measured using the ASHE. The earnings variable of interest is gross hourly earnings excluding overtime where earnings are not affected by absence. For individuals with more than one job (about 2 per cent of employees in the sample) only their 'main job' is included in the analysis; as defined by the job with the greatest gross weekly pay and then the greatest total hours. ## 2. Ashe Does Not Contain Information On Disability; Gender Reassignment; Pregnancy And Maternity; Race; Religion Or Belief; Sexual Orientation Or Marriage And Civil Partnership. 3. All Estimates Are Based On Survey Data And Are Therefore Subject To Uncertainty. 4. This Indicator Uses Unweighted Data As The Weighting Variables Within The Dataset Are Intended For Cross-Sectional Rather Than Longitudinal Analysis, Consistent With Other Longitudinal Ashe Outputs Within Dwp. This May Bias Estimates As Data Are Not Necessarily Representative Of The Employee Population (Calibrated To The Labour Force Survey) Or Adjusted For Differences In Response Rates Across Firms. 5. Progression Is Defined By A Move Up The Earnings Distribution By 20 Or More Percentiles Between 2002 And 2011. 6. Did Not Experience Progression Is Defined By Not Increasing Along The Earnings Distribution By 20 Or More Percentiles. 7. No Data Available To Judge Progression (In The Bottom Quintile In 2002 But No Earnings Recorded In 2011). Pensions-Related Impact Indicators 10. Number Of Employees In A Pension Scheme Sponsored By Their Employer What does this tell us? This indicator measures the number of employee jobs (including those affected by absence) where the individual is aged at least 22 years of age, under state pension age and earning above the earnings threshold for automatic enrolment who are participating in a pension scheme sponsored by their employer. The indicator excludes the self-employed and it should be noted that an individual may have more than one job. How will an improvement be shown? Generally, an improvement in the indicator will be demonstrated if an increase has been achieved. Links to other information that you may find useful Further information on this indicator is available online. Age Number (millions) | 22-24 | 0.3 | |------------------|-------| | 25-29 | 1 | | 30-34 | 1.3 | | 35-39 | 1.5 | | 40-44 | 1.8 | | 45-49 | 1.9 | | 50-54 | 1.6 | | 55-59 | 1.2 | | 60-64 males only | 0.4 | | Total | 11 | | Gender | Number (millions) | |-----------|---------------------| | Male | 5.8 | | Female | 5.2 | | Total | 11 | All data sourced from: DWP analysis of the Office of National Statistics Annual Survey of Hours and Earnings (ASHE). Notes: 1. This indicator is measured using the ASHE and includes all employee jobs (including those affected by absence) with an employer-sponsored pension where the individual is aged at least 22 and less than state pension age (up to 2011/12 this was 65 for men and 60 for women) and where annual gross earnings is above the earnings threshold of £8,105 in 2012/13 earnings terms. 2. All estimates are based on survey data and are therefore subject to uncertainty. 3. Numbers of employee jobs have been rounded to the nearest 0.1 million. Totals may not sum due to rounding. ## Operational Working Of The Department Related Impact Indicators 11. Monetary Value Of Fraud And Error In The Benefit System What does this tell us? This is the primary Departmental indicator for levels of fraud and error in the benefit system. The Fraud and Error National Statistics published for this indicator include global estimates for fraud and error in the benefit system. In addition there are more detailed estimates for Income Support, Jobseeker's Allowance, Pension Credit and Housing Benefit, and for types of error. This indicator is important for Departmental assurance on the effect of anti-fraud and error activity across the businesses. No equality information is currently available for this indicator. The Department plans to include equality information for this Impact Indicator in the 2011/12 Fraud and Error National Statistics, due to be published in Autumn 2012. How will an improvement be shown? Generally, a decrease in the indicator will demonstrate if an improvement has been achieved but economic conditions and overall expenditure will also need to be taken into account. Links to other information that you may find useful Reports on the monetary value of fraud and error in the benefits system are available online. ## 12. Public Opinion Of Dwp Service Levels What does this tell us? This measure shows the satisfaction levels of people who have had meaningful contact with the Department as a whole in the previous six months. This includes a score for overall satisfaction, with sub-indicator scores for satisfaction against four key drivers of customer satisfaction - On Time, Right Treatment, Right Result, and Easy Access. The indicator demonstrates the Department's service to the public, allowing performance to be reviewed and service improvements to be made accordingly. For this report we have included results from the previous separate Jobcentre Plus and Pension, Disability and Carers Service (PDCS) surveys to give some information on public opinions of DWP Service Levels. The 2011 Jobcentre Plus survey found that 88 per cent of Jobcentre Plus claimants were satisfied overall with the service they received with 10 per cent reporting dissatisfaction. The 2010/2011 PDCS survey found that 91 per cent of customers were satisfied overall with 8 per cent reporting dissatisfaction. How will an improvement be shown? Generally, a higher score will indicate greater customer satisfaction. This will be a baseline measure for the Department. Once the baseline is set, good performance can be agreed and reflected in maintaining or improving the level of satisfaction, depending on the amount of change for the Department at the time. Links to other information that you may find useful Information is available online for the impact indicator, the Jobcentre Plus Customer Survey 2011 and the PDCS annual report of quarterly satisfaction 2010-2011. ## By Age1,5 Customer's reported satisfaction Group Age Percentage of customers who are either 'fairly' or 'very' satisfied Percentage of customers who are either 'fairly' or 'very' dissatisfied 16-24 92 8 Working-age adults 9 25-34 35-49 90 87 12 50+ 86 12 There is a statistically significant difference in level of satisfaction between 16- 24 year olds and 50+. No other two-way comparisons between rows are statistically significant. Data sourced from: DWP Research Report 775 'Jobcentre Plus Customer Satisfaction Survey'. Disability and Carers Service by age2,3,5 | Customer's reported satisfaction | Group | Age | |-------------------------------------|----------|--------| | Percentage of | | | | customers who | | | | are either 'fairly' | | | | or 'very' satisfied | | | | Percentage of | | | | customers who | | | | are either 'fairly' | | | | or 'very' | | | | dissatisfied | | | | 16-24 | 92 | 8 | | adults | | | | 25-44 | 86 | 13 | | 45-59 | 84 | 14 | | 60-64 | 87 | 12 | | Pensioners | 60-65 | 94 | | 66-74 | 92 | 6 | | 75+ | 93 | 5 | There is a statistically significantly different in satisfaction levels between 16- 24 and 45-59 year olds. No other two-way comparisons between rows are statistically significant. Data sourced from: DWP Research Report 789 'Pension, Disability and Carers Service Annual Report Quarterly Satisfaction Monitor'. ## By Disability1,5 Customer's reported satisfaction Group Long-standing illness or disability that limited daily activities or work Percentage of customer's who are either 'fairly' or 'very' satisfied Percentage of customer's who are either 'fairly' or 'very' dissatisfied Yes 84 14 Working-age adults No 91 8 There is a statistically significant difference in satisfaction levels between those who have a long standing illness, health problem or disability and those who do not. Data sourced from: DWP Research Report 775 'Jobcentre Plus Customer Satisfaction Survey'. Table 12.4: Customer's reported overall satisfaction with Pension, Disability and Carers Service by disability2,3,4,5 | Customer's reported satisfaction | Group | Long-standing illness | |-------------------------------------|----------|--------------------------| | or disability that | | | | limited daily activities | | | | or work | | | | Percentage of | | | | customer's who | | | | are either 'fairly' | | | | or 'very' satisfied | | | | Percentage of | | | | customer's who | | | | are either 'fairly' | | | | or 'very' | | | | dissatisfied | | | | Yes | 81 | 18 | | Working-age | | | | adults | | | | No | 91 | 7 | | Yes | 90 | 8 | | No | 96 | 4 | There is a statistically significant difference between those with disability and those without with regards to levels of satisfaction. This is the case for both working age adults and pensioners. Data sourced from: DWP Research Report 789 'Pension, Disability and Carers Service Annual Report Quarterly Satisfaction Monitor'. ## Table 12.5: Customer'S Reported Overall Satisfaction With Jobcentre Plus By Ethnicity1,5 Customer's reported satisfaction Group Ethnicity Percentage of customer's who are either 'fairly' or 'very' satisfied Percentage of customer's who are either 'fairly' or 'very' dissatisfied White 88 10 Working-age adults Asian 94 2 Black 90 10 Mixed/Other 77 23 There is no statistically significant difference in levels of satisfaction by ethnicity. Data sourced from: DWP Research Report 775 'Jobcentre Plus Customer Satisfaction Survey'. Table 12.6: Customer's reported overall satisfaction with Pension, Disability and Carers Service by ethnicity2,3,5 Customer's reported satisfaction Group Ethnicity Percentage of customer's who are either 'fairly' or 'very' satisfied Percentage of customer's who are either 'fairly' or 'very' dissatisfied White 86 13 Working-age adults Asian 87 13 Black 82 18 Mixed/Other 84 15 White 93 5 Pensioners Asian 96 4 Black 91 7 Mixed/Other 95 5 There is no statistically significant difference in levels of satisfaction by ethnicity. Data sourced from: DWP Research Report 789 'Pension, Disability and Carers Service Annual Report Quarterly Satisfaction Monitor'. ## By Gender1,5 Customer's reported satisfaction Group Gender Percentage of customer's who are either 'fairly' or 'very' satisfied Percentage of customer's who are either 'fairly' or 'very' dissatisfied Male 84 14 Working-age adults Female 91 8 There is a statistically significant difference in satisfaction levels between males and females. Data sourced from: DWP Research Report 775 'Jobcentre Plus Customer Satisfaction Survey'. Table 12.8: Customer's reported overall satisfaction with Pension, Disability and Carers Service by gender2,3,5 Customer's reported satisfaction Group Gender Percentage of customer's who are either 'fairly' or 'very' satisfied Percentage of customer's who are either 'fairly' or 'very' dissatisfied Male (Age 16-64) 85 14 Working-age adults Female (Age 16-59) 86 13 Male (Age 65+) 93 5 Pensioners Female (Age 60+) 93 6 No statistically significant differences in level of satisfaction between males and females. Data sourced from: DWP Research Report 789 'Pension, Disability and Carers Service Annual Report Quarterly Satisfaction Monitor'. Notes: 1. The 2011 Jobcentre Plus Customer Satisfaction survey was commissioned to measure overall level of satisfaction and assess differences across different customer groups. 2,803 interviews were completed between January and March 2011 with findings representative of Income Support, Incapacity Benefit, Employment and Support Allowance and Jobseeker's Allowance customers. The questionnaire focused on customers who had both claimed/received benefit and had had contact with JCP within the last six months. 2. The 2010/2011 Pension, Disability and Carers Service Satisfaction survey was commissioned to measure overall level of satisfaction and assess differences across different customer groups. 5,002 interviews were completed through two waves of fieldwork with findings representative of Attendance Allowance, Carers Allowance, Disability Living Allowance, Pension Credit and State pension customers. The questionnaire focused on customers who had both claimed/received benefit or had contacted to report a change in circumstances with Pension, Disability and Carers Service in the three - six months previous to each wave. 3. The Pension, Disability and Carers Service also serves working-age customers, those receiving Disability Living Allowance or Carers Allowance may also be customers of Jobcentre Plus. 4. Disability Living Allowance and Attendance Allowance customers of the Pension, Disability and Carers Service have a disability in order to meet the qualifying criteria however they do not always consider that they have a disability that limits them and consequently do not report it. 5. Tests for statistical significance used the Chi-squared approach and were significant at the 95 per cent confidence level. ## 13. Additional Customer Data Employment Gap Information What Does This Tell Us? The Employment Rate Gap Compares The Overall Employment Rate In Great Britain For 16 To 64 Year Olds With The Employment Rate For 16 To 64 Year Olds With Various Protected Characteristics. A Positive Employment Rate Gap Means That The Overall Great Britain Employment Rate Is Higher Than The Employment Rate For The Group With A Particular Protected Characteristic. How Will An Improvement Be Shown? A Reduction In The Employment Gap Would Generally Show An Improvement. However, Economic Conditions Will Also Need To Be Taken Into Account. Quarter 1 2012 (January - March 2012) | Disadvantaged group | Employment rate gap (percentage points) | |-------------------------------|-------------------------------------------| | Female | 4.9 | | Disabled People | 24 | | Ethnic Minorities | 11.7 | | Young People (aged 18 to 24) | 15 | | Older Workers (aged 50 to 64) | 4.8 | Data sourced from: Labour Force Survey. Notes: 1. Data are rounded to the nearest 0.1 percentage point. 2. Data are subject to sampling variation and is not seasonally adjusted. 3. Data covers GB only, not UK. Links to additional information: DWP Equality Impact Assessments National and Official Statistics **products** - the Department produces a number of National and Official Statistics products. Employment and Support Allowance - Work Capability Assessment and Sanctions Income Related Benefits Estimate of Take-Up - includes details on age, disability, ethnicity and gender. Household's Below Average Income series - includes details on age, disability, ethnicity and gender. Low-Income Dynamics - includes details on age and gender. Pensioners Incomes Series - includes details on age, ethnicity and gender. Family Resources Survey - includes details on age, disability, ethnicity and gender. Access to Work - includes details about the programme that helps fund reasonable adjustments for disabled workers. Lone parents on Jobseekers Allowance - includes details on age, gender, disability and ethnicity. Second tier pension provision - includes details on age and gender. DWP tabulation tool - includes a range of benefit data with details on age and gender and some splits available by disability and ethnicity. Life Opportunities Survey - a detailed survey looking at life opportunities for disabled and non-disabled people. Pre-Work Programme and Get Britain Working Official Statistics - includes details on age, disability and ethnicity. Independent Living and Office for Disability Issues indicators on disability equality by 2025 Please email general.statistics@dwp.gsi.gov.uk if you are interested in any of these data sources or want to enquire about the feasibility of any analysis of DWP data by a protected characteristic that is not included here. ## Section 2: Information About Our Employees 14. The Dwp Workforce As part of our commitment to achieving a workforce representative of the society we serve and providing equality of opportunity, we monitor representation of protected characteristics by grade across the Department. The Civil Service grading structure indicates level of seniority within the organisation and covers a range of roles: Senior Civil Service (SCS): Pay Band 3 Director General Pay Bands 2 and 1 Director and Deputy Director Senior Management: Grade 6/Band G Grade 7/Band F Managerial: SEO/Band E HEO/Band D EO/Band C Administrative: AO/Band B AA/Band A What does this tell us? The data presented here show the Department's employees by grade as percentages against each of the following protected characteristics: age, disability, ethnicity and gender. As at 31 March 2012 we had 99,958 employees [headcount], their declaration rate for ethnicity was 78.1 per cent and 85.2 per cent for disability. Unfortunately, at this time the levels of declaration for sexual orientation and religion or belief are too low for publication. How will an improvement be shown? A higher percentage under each protected characteristic will show we employ a greater proportion of people with that protected characteristic. We have set representation rate targets for staff at senior grades until 2013 for ethnicity, disability and gender. Progress towards these was previously reported in our Equality Schemes update. Some of these targets have already been met. Grade % Band D/HEO and Band E/SEO % Band A/AA to Band C/EO % Band F/ Grade 7 % Band G/ Grade 6 % SCS (All) % Not known Total % by age ONS Age Range 16-24 1.9 0.5 0.0 0.0 0.0 0.0 1.7 25-29 6.3 2.5 1.5 0.0 * 31.6 5.8 30-34 8.7 5.4 10.1 4.1 2.7 * 8.4 35-39 10.4 9.2 9.8 8.4 6.8 * 10.3 40-44 15.0 16.1 16.4 16.4 15.5 * 15.1 45-49 19.3 25.4 24.2 25.2 30.6 * 20.0 50-54 17.9 23.3 22.3 24.8 22.4 0.0 18.5 55-59 12.7 13.1 13.3 17.7 18.7 0.0 12.8 60-64 6.3 4.3 2.3 3.2 * 0.0 6.0 65+ 1.5 0.4 * * 0.0 0.0 1.3 % Headcount by grade 88.0 9.9 1.4 0.6 0.2 0.0 100 1. Percentages shown are the number of employees by age and grade over the total number of employees by grade. 2. Data as at 31 March 2012. 3. * - Level of data too low for publication. Grade % Band D/HEO and Band E/SEO % Band A/AA to Band C/EO % Band F/ Grade 7 % Band G/ Grade 6 % SCS (All) % Not known Total % by age Disability 2013 Target 6.0 5.5 5.2 5.2 5.2 N/A N/A Disabled 6.6 5.8 4.2 3.3 3.6 0.0 6.5 Non-disabled 93.4 94.2 95.8 96.7 96.4 * 93.5 % Indicated by grade 87.0 10.8 1.4 0.6 0.2 * 100 1. Percentages shown are the number of employees by disability and grade over the total number of employees by grade who have chosen to indicate their disability. 2. Data as at 31 March 2012. 3. * - Level of data too low for publication. Grade % Band D/HEO and Band E/SEO % Band A/AA to Band C/EO Total % by ethnicity % Band F/ Grade 7 % Band G/ Grade 6 % SCS (All) % Not known Ethnicity 2013 Target N/A 7.5 5.5 5.5 5.0 N/A N/A Ethnic minority 12.0 7.1 5.8 4.5 3.7 0.0 11.4 White 88.0 92.9 94.2 95.5 96.3 100.0 88.6 % Indicated by grade 87.4 10.5 1.3 0.6 0.2 0.0 100 1. Percentages shown are the number of employees by ethnicity and grade over the total number of employees by grade who have chosen to indicate their ethnicity. 2. Data as at 31 March 2012. Grade % Band D/HEO and Band E/SEO % Band A/AA to Band C/EO Total % by gender % Band F/ Grade 7 % Band G/ Grade 6 % SCS (All) % Not known Gender 2013 Target N/A N/A 47.0 45.0 39.5 N/A N/A Female 69.7 61.1 50.4 44.6 40.2 52.6 68.3 Male 30.3 38.9 49.6 55.4 59.8 47.4 31.7 % Headcount by grade 88.0 9.9 1.4 0.6 0.2 0.0 100 All data sourced from: Resource Management. 1. Percentages shown are the number of employees by gender and grade over the total number of employees by grade. 2. Data as at 31 March 2012. ## 15. Disciplinary Procedures What Does This Tell Us? The Data Presented Here Show The Percentage Of Employees Who Have Been Subject To Formal Disciplinary Procedures Against Their Status In Relation To Each Of The Following Protected Characteristics: Age, Disability, Ethnicity And Gender. | Age | Total percentage | |----------------------------------------------------------------------|--------------------| | 16-24 | 5.8 | | 25-29 | 3.8 | | 30-34 | 2.8 | | 35-39 | 2.1 | | 40-44 | 2.0 | | 45-49 | 1.8 | | 50-54 | 1.7 | | 55-59 | 1.9 | | 60-64 | 2.5 | | 65+ | 2.6 | | Total | 2.2 | | | | | Table 15.2: Percentage of employees by indicated disability who were | | | disciplined | | | 1,2 | | | | | | | | | Disability | Total percentage | | Disabled | 2.8 | | Non-disabled | 2.0 | | Total indicated | 2.0 | | | | | Table 15.3: Percentage of employees by indicated ethnicity who were | | | disciplined | | | 1,2 | | | | | | Ethnicity | Total percentage | | Ethnic minority | 2.5 | | White | 2.0 | | Total indicated | 2.0 | | Gender | Total percentage | |-----------|--------------------| | Female | 1.8 | | Male | 3.1 | | Total | 2.2 | All data sourced from: Resource Management. Notes: 1. Percentages shown are the number of employees disciplined in the period over the total number of employees who have chosen to indicate that protected characteristic. 2. Period - 1 April 2011 to 31 March 2012. ## 16. Exits What Does This Tell Us? The data presented here show the reasons why employees leave the Department against their status in relation to each of the following protected characteristics: age, disability, ethnicity and gender. % Early exits % Resignation % Retirement % Other % of total leavers Age % Dismissal 16-24 6.0 0.6 15.4 0.0 10.9 8.7 25-29 12.0 2.7 20.1 0.0 17.4 13.2 30-34 12.1 3.3 13.1 0.0 11.9 9.4 35-39 12.0 3.6 10.7 * 8.9 7.7 40-44 14.0 6.8 10.8 0.5 11.1 9.2 45-49 14.4 8.6 10.3 0.8 12.9 10.1 50-54 12.7 23.1 7.9 7.8 11.7 11.9 55-59 10.6 30.1 5.9 15.8 10.0 12.6 60-64 6.0 17.8 4.7 52.6 4.6 13.1 65+ * 3.4 1.0 22.3 0.7 4.1 Total % leavers by reason 8.4 13.8 24.2 13.7 40.0 100 % Early exits % Resignation % Retirement % Other % of total leavers Disability % Dismissal Disabled 11.2 7.4 4.3 9.7 9.6 8.3 Non-disabled 88.8 92.6 95.7 90.3 90.4 91.7 Total % leavers by reason 10.9 25.6 18.6 25.4 19.6 100 % Early exits % Resignation % Retirement % Other % of total leavers Ethnicity % Dismissal Ethnic minority 13.4 4.4 10.2 7.0 15.4 9.9 White 86.6 95.6 89.8 93.0 84.6 90.1 Total % leavers by reason 9.9 21.7 20.8 21.9 25.7 100 % Early exits % Resignation % Retirement % Other % of total leavers Gender % Dismissal Female 53.2 58.8 62.9 67.4 54.0 58.6 Male 46.8 41.2 37.1 32.6 46.0 41.4 Total % leavers by reason 8.4 13.8 24.2 13.7 40.0 100 All data sourced from: Resource Management. 1. Percentages shown are the number of leavers who have chosen to indicate that protected characteristic and reason for leaving over the total number of employees by reason for leaving. 2. Data as at 31 March 2012. 3. Dismissal - dismissal and discharged probation. 4. Early exits - approved early retirement, voluntary early release, early retirement, early severance. 5. Other - death in service, transfer to other Government department, transfer of function, retirement at/above minimum age, ill health retirement, end of temporary contract, blank reason for leaving. 6. * - Level of data too low for publication. ## 17. Working Patterns What Does This Tell Us? The Data Presented Here Show The Percentage Of Employees With A Part-Time Working Pattern Against Their Status In Relation To Each Of The Following Protected Characteristics: Age, Disability, Ethnicity And Gender. These Data Show Part-Time Working Rates As At 31 March 2012. | Age | Percentage working part-time | |--------|--------------------------------| | 16-24 | 14.2 | | 25-29 | 21.5 | | 30-34 | 35.4 | | 35-39 | 42.7 | | 40-44 | 43.9 | | 45-49 | 39.6 | | 50-54 | 35.3 | | 55-59 | 33.4 | | 60-64 | 59.3 | | 65+ | 68.3 | | Total | 38.7 | | Disability | Percentage working part-time | |-----------------|--------------------------------| | Disabled | 40.6 | | Non-disabled | 41.7 | | Total indicated | 41.7 | | Ethnicity | Percentage working part-time | |-----------------|--------------------------------| | Ethnic minority | 37.3 | | White | 41.4 | | Total indicated | 40.9 | | Gender | Percentage working part-time | |-----------|--------------------------------| | Female | 50.3 | | Male | 13.7 | | Total | 38.7 | All data sourced from: Resource Management. Notes: 1. Percentages shown are the number of employees working part time over the total number of employees that have chosen to indicate that protected characteristic. ## 18. Grievances What Does This Tell Us? The Data Presented Here Show The Percentage Of Employees Who Have Raised A Grievance Against Their Status In Relation To Each Of The Following Protected Characteristics: Age, Disability, Ethnicity And Gender. | Age | Total percentage | |--------|--------------------| | 16-24 | 1.5 | | 25-29 | 1.3 | | 30-34 | 1.3 | | 35-39 | 1.4 | | 40-44 | 1.1 | | 45-49 | 1 | | 50-54 | 1 | | 55-59 | 1.1 | | 60-64 | 1.1 | | 65+ | 1.2 | | Total | 1.1 | | Disability | Total percentage | |-------------------------------------------------------------------------|--------------------| | Disabled | 2.0 | | Non-disabled | 1.1 | | Total Declared | 1.1 | | | | | Table 18.3: Percentage of employees by indicated ethnicity who raised a | | | grievance | | | 1,2 | | | | | | | | | Ethnicity | Total percentage | | Ethnic minority | 1.3 | | White | 1.1 | | Total indicated | 1.1 | | Gender | Total percentage | |-----------|--------------------| | Female | 1.1 | | Male | 1.2 | | Total | 1.1 | All data sourced from: Resource Management. Notes: 1. Percentages shown are the number of employees raising a grievance in the period over the total number of employees that have chosen to indicate that protected characteristic. 2. Period - 1 April 2011 to 31 March 2012. ## 19. Performance Markings We Are Currently Unable To Provide Updated Data For This Set As These Data Are Analysed Later In The Year. We Will Include This Information As Soon As It Is Available. 20. Promotion What Does This Tell Us? The Data Presented Here Show Employees Promoted Against Their Status In Relation To Each Of The Following Protected Characteristics: Age, Disability, Ethnicity And Gender. | Age | Total % | |--------|-----------| | 16-24 | 1.2 | | 25-29 | 1.2 | | 30-34 | 1.3 | | 35-39 | 0.7 | | 40-44 | 0.6 | | 45-49 | 0.5 | | 50-54 | 0.3 | | 55-59 | 0.3 | | 60-64 | 0.3 | | 65+ | * | | Total | 0.6 | | Disability | Total % | |-----------------|-----------| | Disabled | 0.4 | | Non-disabled | 0.5 | | Total indicated | 0.5 | | Ethnicity | Total % | |-----------------|-----------| | Ethnic minority | 0.9 | | White | 0.5 | | Total indicated | 0.5 | | Gender | Total % | |-----------|-----------| | Female | 0.6 | | Male | 0.6 | | Total | 0.6 | All data sourced from: Resource Management. Notes: 1. Percentages shown are the number of employees promoted in the period over the total number of who have chosen to indicate that protected characteristic. 2. Period - 1 April 2011 to 31 March 2012. 3. * - Level of data too low for publication. ## 21. Recruitment Process We are currently unable to provide updated data about recruitment as we are changing the way we manage our processes to utilise a Civil Service wide model. We will include this information as soon as it is available. ## 22. Pay Gap The Department analyses data to identify any differences in pay on the grounds of gender, race, age and disability. The pay gap is calculated by adding together the pay of all of the members of the potentially disadvantaged group in the Department who are in grades below the Senior Civil Service (SCS) and then working out an average salary. This is then compared to the average salary of the potentially advantaged group. The gap is the difference between the two averages divided by the average pay of the advantaged group. Pay gap = (Pay difference)5 (Pay of the advantaged group) Therefore, in the case of the gender pay gap, the average salary of women in grades below SCS is calculated and then compared to the average salary of men in grades below SCS. The difference is expressed as a percentage and is presented by grade. What does this tell us? The table below shows which group is considered to be advantaged or disadvantaged for the purposes of expressing the pay gap for that protected characteristic. In the case of age, the majority age group (25-54) is shown against both the younger group (16-24) and the older age group (55 and above). Comparison table by protected characteristic for pay gap data Protected characteristic Disadvantaged group Advantaged group Age 16-24 25-54 55 and above 25-54 Disability Disabled Non-disabled Ethnicity Ethnic minority White Gender Female Male How will an improvement be shown? Where the potentially disavantaged group, for example women, have a higher average salary than their male counterparts, it is expressed as a negative percentage (for example -0.5 percent). This analysis informs the Equal Pay Audit, which takes place on a three yearly basis to identify areas for action. ## Table 22.1: Pay Gap By Age1,2,3 Band A/ AA Band B/ AO Band C/ EO Band D/ HEO Band E/ SEO Band F/ Grade 7 Band G/ Grade 6 All grades Age Age 16-24 (mean salary) £14,569 £16,505 £21,514 £26,733 N/A N/A N/A £16,840 Age 25-54 (mean salary) £15,018 £17,792 £23,190 £28,003 N/A N/A N/A £21,473 Pay gap (percent 16-24 to 25-54) 3.0 7.2 7.2 4.5 N/A N/A N/A 21.6 Band A/ AA Band B/ AO Band C/ EO Band D/ HEO Band E/ SEO Band F/ Grade 7 Band G/ Grade 6 All grades Age Age 55 and above (mean salary) £15,075 £18,011 £23,728 £29,214 £35,605 £49,457 £61,233 £21,767 Age 25-54 (mean salary) £15,018 £17,792 £23,190 £28,003 £33,921 £47,018 £59,239 £21,473 Pay gap (percent 55+ to 25-54) -0.4 -1.2 -2.3 -4.3 -5.0 -5.2 -3.4 -1.4 Band A/ AA Band B/ AO Band C/ EO Band D/ HEO Band E/ SEO Band F/ Grade 7 Band G/ Grade 6 All grades Disability Disabled (mean salary) £15,142 £18,192 £23,644 £28,618 £34,570 £47,633 £59,353 £21,968 Non-disabled (mean salary) £15,108 £18,081 £23,419 £28,288 £34,238 £47,416 £59,836 £21,948 Pay gap (percent disabled to nondisabled) -0.2 -0.6 -1.0 -1.2 -1.0 -0.5 0.8 -0.1 Band A/ AA Band B/ AO Band C/ EO Band D/ HEO Band E/ SEO Band F/ Grade 7 Band G/ Grade 6 All grades Ethnicity Ethnic minority (mean salary) £15,059 £18,020 £23,192 £28,039 £33,800 £46,813 £60,917 £20,896 White (mean salary) £15,082 £17,975 £23,415 £28,321 £34,300 £47,451 £59,889 £21,881 Pay gap (percent ethnic minority to white) 0.2 -0.3 1.0 1.0 1.5 1.3 -1.7 4.5 Band A/ AA Band B/ AO Band C/ EO Band D/ HEO Band E/ SEO Band F/ Grade 7 Band G/ Grade 6 All grades Gender Female (mean salary) £15,028 £17,890 £23,331 £28,227 £34,102 £46,980 £59,025 £21,257 Male (mean salary) £15,004 £17,562 £23,214 £28,225 £34,475 £47,976 £60,264 £21,881 Pay gap (percent female to male) -0.2 -1.9 -0.5 0.0 1.1 2.1 2.1 2.9 All data sourced from: Resource Management. 1. Salary totals are total full-time salaries in the pay band, excluding allowances and overtime. However, to prevent skews in diversity analyses due to different pay zones, all salaries here are treated as though they are on DWP National pay scales. That is, salaries on pay scales for inner London, outer London and special location pay zones have been placed on their equivalent position on the National pay scale. ERNIC and employer's superannuation (Civil Service Pension) contributions are excluded from these figures. 2. Mean salary is the total full-time basic salaries for the pay band, divided into the headcount. 3. Records excluded from this analysis include SCS employees and specialists (accountants, lawyers etc) whose salaries are on separate pay scales. Casual and fixed-term appointments are included. The population used in the analysis therefore represents 98.1 percent of DWP employees paid and in post on 31 March 2012. 4. In defining working patterns, all part-year appointments have been categorised as part-time, whether or not part-year attendance is full-time or part-time. 5. Mean salaries only take into account those who have indicated their disability status. 6. Mean salaries only take into account those who have indicated their ethnicity status ## 23. Training Data We are currently unable to provide updated data on training undertaken by our employees as we are transferring to a new Civil Service wide system. We will include this information as soon as it is available. ## 24. Maternity Data What Does This Tell Us? These data shows the number of employees returning from maternity leave against their status in relation to each of the following protected characteristics: age, disability and ethnicity. period by age1,2 Age Total percentage 16-24 3.2 25-29 22.6 30-34 36.9 35-39 25.8 40-44 10.4 45-49 1.1 50-54 0.0 55-59 0.0 60-64 0.0 65+ 0.0 Total 100.0 period by indicated disability1,2 Disability Total percentage Disabled 2.4 Non-disabled 97.6 Total indicated 100.0 Table 24.3: Percentage of employees returning from maternity leave in period by indicated ethnicity1,2 Ethnicity Total percentage Ethnic minority 18.7 White 81.3 Total indicated 100.0 All data sourced from: Resource Management. Notes: 1. Percentages shown are the number of employees returning from maternity leave in the period by indicated protected characteristic over the total number of employees returning from maternity leave. 2. Period - 1 April 2011 to 31 March 2012. 25. Links to additional information 2011 People Survey Results - includes details of the DWP People Survey which is part of the Civil Service People Survey. It contains 57 questions to help determine employee engagement throughout the Civil Service. 2012 Star Performer Network - recognition is due to the work, dedication and commitment of SONG (the DWP national sexual orientation staff network group). This is the first time DWP and SONG have received this recognition. Top 100 Employer - DWP is one of Britain's Top 100 Employers for lesbian, gay and bisexual staff. Performance Related Pay - includes details of non-consolidated performance-related pay by DWP, our agencies and executive Non- Departmental Public Bodies (NDPBs) for the performance year 2010-11. Workforce Management Returns - includes details of the DWP workforce, our agencies and executive NDPBs. Business Plan Quarterly Data Summary provides a quarterly snapshot on how each department is spending its budget, the results it has achieved and how it is deploying its workforce. Equality Impact Assessments help us to make sure the needs of people are taken into account when we develop and implement a new policy or service or when we make a change to a current policy or service. DWP Equality Information 2012 Update Under the Public Sector Equality Duty, part of the Equality Act 2010, as a public body the Department for Work and Pensions has a specific duty to publish relevant proportionate information to demonstrate our compliance. Information showing that we have paid due regard to the aims of the Equality Duty is contained in this report. Diversity and Equality Directorate Porterbrook House, 7 Pear Street, Sheffield, South Yorkshire, S11 8JF. Contact information: adelphi.diversityandequality@dwp.gsi.gov.uk 978-1-78153-058-0 Published by the Department for Work and Pensions 12 July 2012 www.dwp.gov.uk
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## ANNUAL GOVERNANCE STATEMENT Scope of responsibility London Councils (the Committee) is responsible for ensuring that its business is conducted in accordance with the law, and proper standards, and that public money is safeguarded, and properly accounted for, and used economically, efficiently and effectively. The Committee is also responsible for securing continuous improvement in the way its functions are exercised. In discharging this overall responsibility, the Committee is responsible for putting in place proper arrangements for the governance of its affairs, facilitating the effective exercise of its functions, and which includes arrangements for the management of risk. London Councils has approved and adopted a code of corporate governance in the form of a framework, which is consistent with the principles of the CIPFA/SOLACE Framework Delivering Good Governance in Local Government. A copy of London Councils Corporate Governance Framework can be obtained from the Director of Corporate Governance at 59½ Southwark Street, London SE1 0AL. This statement explains how London Councils has applied this code and also meets the requirements of regulation 4(3) of the Accounts and Audit Regulations 2011. The purpose of the governance framework The governance framework comprises the systems, and processes, and culture and values, by which the Committee is directed and controlled and its such activities through which it accounts to, and engages with, its stakeholders. It enables the organisation to monitor the achievement of its strategic objectives and to consider whether those objectives have led to the delivery of appropriate, cost-effective services. The system of internal control is a significant part of that framework and is designed to manage risk to a reasonable level. It cannot eliminate all risks of failure to achieve policies, aims and objectives and can, therefore, only provide reasonable and not absolute assurance of effectiveness. The system of internal control is based on an ongoing process designed to identify and prioritise the risks to the achievement of the Committee's policies, aims and objectives, to evaluate the likelihood of those risks being realised, and the impact should they be realised, and to manage them efficiently, effectively and economically. The governance framework has been in place at London Councils for the year ended 31 March 2013 2014 and up to the date of approval of the statement of accounts. The governance framework The key elements of the Committee's governance framework include:  Identifying and communicating the Committee's vision of its purpose - The Committee produces an annual Corporate Business Plan which sets out the organisation's priorities for the year. This is informed by on-going liaison with key borough stakeholders and specifically by a programme of meetings between the Chair and all Executive portfolio holders. The Corporate Business Plan is submitted to the Leaders' Committee. There are a number of ways in which the Committee communicates with relevant stakeholders which include member briefings, committee and forum other meetings and events such as the London Councils' Summit.  Reviewing the Committee's vision - The Committee produces an Annual Review at the end of each financial year. The review provides a summary of the key activities over the last year and highlights the key achievements.  Measuring the quality of services - Data collected during the year feeds into the production of a key achievements report at the year end. London Councils Corporate Management Board (CMB), the London Councils Executive and the Grants and Transport and EnvironmentC Committees receive regular financial management reports that monitor actual income and expenditure trends against approved budgets. London Councils operates a complaints procedure which provides an opportunity to put things right if an error is made and assists in the search to improve the quality of services to member authorities and to Londoners. There are also a number of internal management mechanisms, such as 1:1 review meetings and a fully embedded performance appraisal framework which monitor on-going progress against objectives.  Defining and documenting roles and responsibilities - The London Councils Agreement sets out the main functions and obligations of London Councils and its member authorities. The Agreement includes the standing orders and financial regulations which provide details of the delegation arrangements in place. There is a scheme of delegation in place which was last reviewed, updated and approved by the Leaders' Committee at their its Annual General Meeting on 114 June 20113. There is an established protocol which provides guidance on the working relationships between elected members and officers. Additional information on the roles and responsibilities of London Councils Executive, Leaders, Grants and TEC CommitteesLeaders' Committee, Executive, Grants Committee and Transport and Environment Committee are documented in their individual Terms of Reference. All London Councils officers are issued with a job description which confirms their duties within the organisation.  Developing, communicating and embedding codes of conduct - All London Councils Staff have been made aware of the staff handbook which is located on the intranet site. The staff handbook sign posts staff to London Councils policies and procedures which are on the intranet, specifically mentioning financial regulations and the code of conduct. All staff are encouraged to refer to the intranet when they require guidance on London Councils policies and procedures. Reference to Tthe staff handbook is also included in the induction training of all new staff joining London Councils with their attention specifically drawn to the financial regulations, the code of conduct, data protection and London Councils whistle blowing policy..  Reviewing the effectiveness of the Committee's decision-making framework - The standing orders and financial regulations are included within the London Councils Agreement. The standing orders were last reviewed in June 2011 and the changes were approved by Leaders' Committee on 19 October | 2012 | . The financial regulations were reviewed and the changes approved by the | |-------------------------------------------------------------------------------------|------------------------------------------------------------------------------| | Executive in February 2009. Minutes of Committee meetings are posted on | | | London Councils | internetweb | | made. | | | | | | | | |  | | | | | | Identifying and managing risks | | | - London Councils Risk Management Strategy | | | and Framework was reviewed and updated in 2011/12 and approved by the Audit | | | Committee in March 2012. London Councils Corporate Risk Register is primarily | | | compiled from the Risk Registers for each of London Councils three Directorates. | | | The Corporate Risk Register is reviewed in accordance with London Councils | | | Risk Management Framework which includes an annual review by the Audit | | | Committee and was last reviewed in September | 20122013 | | Registers are reviewed by the Audit Committee each financial year. London | | | Councils' Corporate Management Board ensures that the risk registers, both | | | Directorate and Corporate, continue to support London Councils' corporate | | | priorities, which provides members with assurance on how the risks identified are | | | being managed. An internal audit review of London Councils risk management | | | arrangements was carried out during 2011/12. The review established that risk | | | management is an embedded governance control and there were no | | | recommended improvements to the arrangements. | | | | | |  | | | | | | Anti-fraud and anti-corruption arrangements | | | - London Councils is committed | | | to | having | | promote standards of honest and fair conduct, prevent fraud and corruption, | | | detect and investigate fraud and corruption , prosecute offenders, recover losses | | | and maintain strong systems of internal control. There are two separate policies | | | in place | London Councils Whistle Blowing Policy which was last updated in | | November 2013 and London Councils Policy to Combat Fraud, Bribery and | | | Corruption, which was agreed by London Councils Audit Committee in March | | | 2014 - both which | are available on London Councils' | | | | |  | | | | | | Effective management of change and transformation | | | - London Councils has | | | a framework for managing organisational change which is available to all staff on | | | the intranet. The framework provides guidance on the statutory elements of | | | managing change and issues that should be considered when implementing | | | changes. | | | | | |  | | | | | | Financial management arrangements | | | - London Councils' financial | | | management arrangements conform with the governance requirements of the | | | CIPFA statement on the Role of the Chief Financial Officer in Local Government. | | | | | |  | | | | | | Assurance arrangements | | | - London Councils' internal audit function is carried | | | out by the City of London's internal audit team under a service level agreement | | | for financial support services. These arrangements conform with the governance | | | requirements of the CIPFA statement on the Role of the Head of Internal Audit in | | | public service organisations. | | | | | |  | | | | | | Discharge of the monitoring officer function - | | | The City of London's | | | Comptroller & City Solicitors Department (Public and Corporate Law) undertakes | | | the monitoring officer function under a service level agreement for legal services. | | London Councils' Director of Corporate Governance is charged with ensuring that any monitoring officer duty is commissioned from the City of London. . As with all Committee officers, the Director of Corporate Governance is issued with a job description which confirms her duties within the organisation. She is subject to London Councils appraisal arrangements which assess her performance against agreed objectives.  Discharge of the head of paid service function - London Councils' Chief Executive is the head of paid service. As with all Committee officers, the Chief Executive is issued with a job description which confirms his duties within the organisation. He is subject to appraisal arrangements with Group Leaders who assess his performance against agreed objectives.  Audit Committee - London Councils' Audit Committee has its own comprehensive Terms of Reference. The Terms of Reference were reviewed by the Audit Committee on 24 September 2010. The Audit Committee meets three times a year and is chaired by a leading member from a borough who is notcan be a member of the Leaders' Committee Executive. The members of the Audit Committee will normally, but not necessarily, be members of London Councils Leaders' Committee and with the exception of its chair, are not members of the Executive.  Compliance with relevant laws and regulations - London Councils has comprehensive financial regulations and a comprehensive set of human resources policies and procedures, which are reviewed on a regular basis. These arrangements ensure compliance with all applicable statutes, regulations and other relevant statements of best practice in order to ensure that public funds are properly safeguarded and are used economically, efficiently and effectively and in accordance with the statutory and other authorities that govern their use.  Whistle-blowing - London Councils has a whistle-blowing policy which is available to all staff on the intranet. The policy aims to encourage staff and others to feel confident in raising serious concerns by providing clear avenues through which those concerns can be raised and reassuring staff who raise concerns that they will not be victimised if they have a reasonable belief and the disclosure was made in good faith. It is also on the website and staff are encouraged to bring this policy and the policy to combat fraud, bribery and corruption to the attention of contractors and third parties.  Identifying the development needs of members and officers - London Councils has access to a programme of training and development, which is available to all staff and can be found on the intranet. The aim of the programme is to assist in the achievement of the organisation's aims and objectives by providing opportunities for staff to gain the necessary skills and knowledge required to perform their tasks and duties effectively. London Councils also has a performance appraisal scheme which provides all staff with regular assessments of their performance and development needs in relation to their work objectives. Members have access to training in their own authorities. There is a member only section on London Councils' website which provides them with useful | information | , regular briefings | | |--------------------------------------------------------------------------------------|---------------------------------------------|-------------------------------------| | exchange. | | | | | | | |  | | | | | | | | Establishing clear channels of communication | | | | - London Councils actively | | | | engages with relevant stakeholders when developing its vision and strategies. All | | | | Committee meetings are open to the public and consultations are undertaken | | | | where relevant. London Councils issues member briefings and arranges a | | | | number of events, conferences and seminars that also provide opportunities for | | | | stakeholder engagement. London Councils produces an Annual Review which | | | | provides a summary of the key achievements over the last year and annual | | | | statutory financial statements. Information on consultations, minutes of | | | | committee meetings and publications are posted on London Councils | internet | | | web | site www.londoncouncils.gov.uk. | London Councils consults with Chief | | Officer groupings across boroughs in the development of its work. | | | | | | | |  | | | | | | | | Enhancing the accountability for service delivery and effectiveness of | | | | public service providers | | | | - All working arrangements with public service | | | | providers are subject to signed agreements/contracts which set out the terms of | | | | the service provided. All agreements/contracts are reviewed to ensure that the | | | | roles and responsibilities of the parties involved are clearly defined and the terms | | | | are beneficial to London Councils and its member authorities. Key performance | | | | indicators are incorporated into agreements where appropriate and monitored | | | | regularly. Nominated officers are responsible for managing the outcomes of the | | | | service and establishing clear lines of communication with providers. | | | | | | | |  | | | | | | | | Partnership arrangements | | | | - London Councils has a set protocol for staff to | | | | follow when working in partnership with outside bodies. A checklist is | to be | | | completed for each new partnership or project. Partnership arrangements are | | | | also subject to signed agreements which include objectives, roles and | | | | responsibilities. The performance of partnerships are monitored in the same | | | | manner as other service providers. | London Councils does not currently have any | | | material partnership arrangements. | | | Review of effectiveness London Councils has responsibility for conducting at least annually, a review of the effectiveness of its governance framework including the system of internal control. The review of effectiveness is informed by the work of London Councils Corporate Management Board which has responsibility for the development and maintenance of the governance environment, the internal audit annual report and also by comments made by the external auditors in their annual audit letter and other reports. The review of the effectiveness of the governance framework includes:  The work of Internal Audit, undertaken by the City of London under a Service Level Agreement, and the annual opinion of the Head of Audit & Risk Management at the City of London. Internal Audit plays a central role in providing the required assurance on internal controls through its comprehensive risk-based audit of all auditable areas within a five-year planning cycle, - with key areas being reviewed annually. This is reinforced by consultation with London Councils Corporate Management Board and London Councils' Audit Committee on perceived risk and by a rigorous follow-up audit regime. The Internal Audit Section of the City of London operates, in all aspects, in accordance with the CIPFA Code of Practice. An internal audit review of governance arrangements was carried out during 2012/13 with the outcome reported to the Audit Committee in March 2013.  The Audit Committee's review of the governance arrangements in place during 2012/132013/14.  London Councils Corporate Management Board considers an annual report on Corporate Governance, which includes work completed during the current year and highlights work planned for the following year. Areas for development during 2013/142014/15 The review of the effectiveness of London Councils governance arrangements has revealed the following areas for development during 2013/142014/15: Grants An internal audit review of the Grants programme was undertaken in 2013/14. The audit reviewed the management controls which ensure that grants are issued in accordance with established priorities and the adequacy of due diligence checks, monitoring procedures and payment processes. The review also measured the extent to which the recommendations of the 2012 grant investigation had been implemented. The review established that "there is a sound control environment with risks to system objectives being reasonably managed. Any deficiencies identified are not cause for major concern". There was one recommendation for the introduction of additional reference checks on organisations which have never been funded by London Councils or receive annual funding in excess of £1 million. The recommendation was implemented from April 2014. ICT Strategy, Security & Operational Control Information Security A review of the Committee's information securityICT strategy, security and operational control was undertaken during 2009/102013/14 by the Internal Audit Team. The review revealed that whilst an adequate control framework was in place, there were a number of areas that required addressing such as updating the overall ICT strategy and the business continuity and disaster recovery plans. There were also recommendations on improvements to system security, hardware infrastructure, performance monitoring and staff data security awareness. The report acknowledged that management was already taking action to address a number of the issues that were raised. The outstanding recommendations will be implemented during 2014/15. The main areas of development recommended by the review relate to seeking assurances on the adequacy of information security of partners/contractors, the classification of information held by the Committee, the transfer of data to and from partners/contractors, enhancing ICT security arrangements and the introduction of an information management policy. The delivery of London Councils' ICT function was transferred to the City of London in August 2011. As a result there have been significant changes to the operation of the ICT function which has affected key positions referred to in draft policy documents as well as security arrangements. Whilst good progress had been made towards implementing the ## Formatted: Font: Bold Formatted: Font: Bold recommendations of the original review, it is necessary to review these recommendations and draft policy again in the context of the new arrangements. A review of the strategy, security and operations of the ICT function will be carried out in 2013/14 and any additional recommendations identified during this review will be considered for implementation. Inventory An internal audit spot check of petty cash, creditor payments, safe contents and inventory lists was carried out during 2013/14. The check included an examination of procedures over the petty cash imprest, safe access and security, inventory and a creditor depth test for a sample of transactions. The review revealed that the inventory list for furniture and equipment had not been updated on a regular basis. The recommendation included in the spot check report will be implemented during 2014/15. London Lorry Controls Scheme An internal audit review of the London Lorry Control IT System was undertaken in 2013/14. The audit reviewed controls in relation to system strategy, management responsibility, configuration, security, operational procedures and resilience. The review provided assurance on the data integrity of the whole system. The recommendations included in the report relate to the incorporation of the debt registration functionality, performance monitoring reports, segregation of duties and system security protocols. A number of the recommendatins have already been implemented with the remainder being implemented during 2014/15. Parking and Traffic A follow up review of the Parking and Traffic Division was carried out during 2011/12. The original review examined the controls in place to ensure that all charges are accurately identified and recharged to the relevant organisation, that payments to the main contractor and Parking Adjudicators are accurate and reflect services provided and the adequacy of procedures and systems for monitoring performance. The follow up review revealed that some of the recommendations had not been implemented due to prohibitive implementation costs. There are still some improvements to be made on operational procedure notes which have been delayed as a result of a change in the business object software used to compile management information. These improvements that will be implemented during 2013/142014/15. Taxicard Scheme A follow up review of London Councils' Taxicard Scheme was completed in 2011/12. The original audit reviewed the management arrangements for the scheme as well as establishing and examining arrangements in place to monitor the contract held with Computer Cab. The follow up review revealed that there had been a delay in implementing a recommendation regarding the regular updating of procedure manuals. There has been progress made on the update of procedure manuals during 2013/14 but the exercise has not yet been completed as recent and proposed changes will have to be incorporated in the final version. These improvements will be completed during 2014/15.The implementation had been delayed due to the procurement and outsourcing of elements of the scheme. A revised target implementation date of December 2013 has been set for the update of the procedural guidance once new working practices have had time to embed. Freedom Pass An internal audit review of the Freedom Pass concessionary fares scheme was carried out in 2012/13. The audit assessed controls in relation to the processing of applications, issuing of cards, verification and payment of claims submitted by transport companies and the adequacy of systems for budgeting and budgetary control. The review also considered the robustness of the process to agree settlements with transport companies. It was established that there is a sound control environment with risks to system objectives being reasonably managed. The recommendations included in the review relate to the need to obtain additional assurance from member boroughs, that do not use the Post Office service, that sufficient controls exist to check the identity and entitlement of applicants and progress the introduction of independent National Fraud Initiative data matching for freedom pass holder details. The recommendations will be implemented during 2013/14. Governance Arrangements An internal audit review of London Councils' governance arrangements was carried out in 2012/13. It established that there is a sound control environment with risks to system objectives reasonably managed. The Chairs of London Councils' committees provided suggestions on ways to improve reporting and the committee decision making processes. All the suggestions have been implemented. Recruitment and Payroll Adjustments An internal audit spot check of recruitment and payroll adjustments was carried out in 2012/13. The audit reviewed the controls in relation to the recruitment of new staff, the certification of payroll adjustments in respect of sickness absences and compliance with government guidelines on Statutory Sick Pay. It established that the controls were generally operating satisfactorily but there were some areas of development identified in relation to document retention. The recommendations made in the report will be implemented in 2013/14. London Councils will take adequate steps over the coming year to address the above matters in order to further enhance its governance arrangements. London Councils is satisfied that these steps will address the improvement needs identified in the effectiveness review. London Councils will monitor their implementation and operation as part of our next annual review. Significant governance issues Grants In July 2012 the Grants Committee considered a report which raised significant concerns about a grant commissioned to a particular organisation. An internal audit investigation was commenced and a report presented back to the Committee in November 2012. The internal audit report made seven recommendations to improve controls on the monitoring of projects, retention and archiving of records, management oversight, ## prompt response to projects with issues and protocols for notifying the Grants Committee, relevant senior officers and third parties where concerns exist. As the internal audit report raised some serious issues and highlighted a potential breakdown in internal controls regarding the payments of grant to this particular organisation, London Councils Chief Executive commissioned a further, independent review to ascertain the circumstances as to why these events occurred and to form a view as to whether or not the responses to the recommendations of the internal audit report were sufficiently robust to provide a reliable system of internal control into the future. This review made further recommendations regarding:  the review of the operation of commissioning arrangements;  the priority to be afforded to securing outcomes and safeguarding public funds;  monitoring processes involving officers and members:  the triggers for warning senior managers and members;  revisions to Financial Regulations; and  protocols for referrals to the Metropolitan Police. London Councils Chief Executive, Corporate Director of Services and Director of Corporate Resources fully accepted the conclusions and recommendations included in the report as well as those highlighted in the internal audit investigation. This was reported to both the Audit Committee and Grants Committee. A framework has been developed which incorporates the recommendations from both reviews. The procedures incorporated in the framework have been applied to all commissions since 1 April 2013. There are no significant governance issues. John O'Brien September 20132014 Chief Executive Mayor Jules Pipe September 2013 2014 Chair of London Councils
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# Applying For A Consent To Investigate a groundwater source Water Resources Act 1991 Section 32, Environment Act 1995, The Natural Resources Body for Wales (Functions) Order 2012 Content: Click links to jump to the relevant section of this document. Groundwater Investigation consent process How to complete form WRC Water features survey The Groundwater Investigation Consent Process Groundwater is a vital natural resource. Natural Resources Wales has a duty to protect and manage it. We issue licences to control abstraction from underground sources. Applying for an abstraction licence may be a long and expensive process, so the law allows you to carry out investigation work without having a full abstraction licence. This allows you to find out what water may be available, and whether it is suitable for your needs. For these investigations, we issue consents (under Section 32 of the Water Resources Act 1991) which limit abstraction and restrict the work carried out to: - find out if there is a groundwater source - check the quantity of groundwater and - discover what effect abstracting groundwater would have on other nearby water sources. You do not need an abstraction licence if you will be abstracting less than 20 cubic metres of water a day. For abstractions below this limit, you do not need a consent to investigate the groundwater source. If you want to abstract 20 cubic metres or more a day, you must obtain a consent giving you permission to drill or excavate a borehole, well, catchpit or a seepagefed lagoon, and complete pumping tests. It is against the law to undertake these works without a consent. If you are convicted of this offence, you could be fined, imprisoned or both. You should note that the consent is no guarantee of success. Drilling a borehole, developing a well, excavating a catchpit or seepage-fed lagoon does not guarantee that you will find a source of groundwater. Also, if you do find groundwater, there may not be enough for your intended purpose, or the quality of the water may not be suitable. Even if the source provides enough water, this does not mean we will automatically grant you an abstraction licence. For example, the pumping test may show that abstraction will have unacceptable effects on other local water local water sources or environmental features. Also, due to water shortages, there may be general restrictions on granting licences in the area. If this is the case, we will tell you this as soon as possible, to save you unnecessary expense. You can also find information about local water sources by looking at the local Catchment Abstraction Management Strategy for your area. These are available from us. Once we have received a satisfactory application form we will normally issue a consent for you to carry out your investigation. We will usually grant the consent to you, the applicant for a period of six months. The consent will contain several conditions which specify the terms of the consent. Whoever we grant the consent to will be legally responsible for keeping to the conditions set out in it. If you do not fully keep to the conditions, we may withdraw the consent. We may also withdraw or change the conditions if the work has effects which we had not anticipated, or if it is otherwise reasonable for us to do so. We will need you to carry out pumping tests to find out whether the source can produce a water supply that will meet your needs, and to see how the water level will react to a given rate of pumping. This information will also help you to choose the best abstraction method, such as the correct type of pump and the depth to set it at. Major developments, and developments close to environmentally sensitive sites, will need to be tested over a long period to see the effect abstraction will have on existing wells, boreholes, springs, streams and other environmental features in the area. You will also need to produce a groundwater impact assessment report. We will tell you what measurements you will have to take during the assessment and what you need to include in the report. We may also need to consult other organisations about your proposals. Testing water samples during the pumping tests will also show whether the water is of suitable chemical or bacteriological quality for your intended use, or whether it will need to be treated. You are responsible for making sure that the water abstracted is fit for your particular purpose. The consent will specify the following: - The maximum dimensions of the borehole, well, catchpit or seepage-fed lagoon - Construction (such as casing and grouting) - If appropriate, the need for sinking monitoring boreholes - Where water should be discharged when carrying out pumping tests - Other special conditions, such as testing only during the summer - Requirements to prevent pollution from the proposed work - Requirements to keep us informed at all stages in your work programme - Requirements to contact other relevant organisations, including the British Geological Survey (www.bgs.ac.uk), the Health and Safety Executive (www.hse.gov.uk) and the Coal Authority (www.coal.gov.uk), before starting to drill any well or borehole - Your responsibility for all aspects of the work, including any damage that may be caused - Your responsibility to keep clear and accurate records, including of the dimensions of boreholes and wells, and to supply both us and the British Geological Survey with this information - The access needed to the site so we can inspect the work as and when necessary Quality of work and presenting results You must be sure that any borehole or well is drilled with the correct materials, as recognised by the well-drilling industry. You can get guidance notes for constructing boreholes for water supply from the Well Drillers' Association (www.welldrillers.org.uk, phone: 07885 979 583). Technical information is also available in the publication 'Well Construction Specification for the Water Industry'. You can get copies of this from WRc Plc (www.wrcplc.co.uk, phone: 01793 865 000). After you have finished the pumping test, you will have to send us a report giving details of the pumping and the effects it had on water levels. We will tell you what to include in your report. We will expect you to carry out the pumping tests in line with British Standard ISO 14686 (2003) 'Hydrometric determinations - Pumping tests for water wells - Considerations and guidelines for design, performance and use'. You can get copies of this from the British Standards Institute (www.bsigroup.com, phone: 020 8996 9001). After the pumping test has been completed, you will have to send us a groundwater impact assessment report, which must provide details of the results of the pumping test and an assessment of the effect your proposed abstraction would have on the local environment. We will tell you what to include in your report. A professional advisor or consultant should be able to do this for you. We will be able to process any future licence application more quickly if you provide a satisfactory groundwater impact assessment report. In some cases, before we issue a consent we may ask you to provide a preliminary report on specific concerns about the effect of drilling or testing the borehole. Take advice before construction, development or drilling Drilling a borehole or well is expensive. A professional advisor can suggest where best to develop a source, or whether it is worth doing at all. Unless you are fully competent to complete your own plans, we suggest you get professional advice. Contacts can be sought from the Geologists Directory and the Well Drillers Association. Private water supplies If you are developing the groundwater source to provide a private supply of drinking water (and you are not a public water-supply company), you should tell the Environmental Health Officer at your local council. The Private Water Supply Regulations will apply to your abstraction and the Environmental Health Officer should be able to give you advice on this. You can get more information from the Drinking Water Inspectorate (www.dwi.gov.uk, phone: 030 0068 6400). How long does the consenting process take? Once we have received your completed application form, assuming all of the details are correct, we aim to provide you with your consent within 45 working days. However, these timescales may be significantly longer if your proposal is close to sensitive conservation sites, as we will have to consult comprehensively. The whole process, from you submitting your application and completing your pumping test and producing your report, will usually take several months, and it can take up to a year. Where to send your completed form(s) For an improved service, we encourage you to submit your application(s) electronically. Please send your completed application form and any supporting information by email to permitreceiptcentre@naturalresourceswales.gov.uk or by post to: Permit Receipt Centre Natural Resources Wales Cambria House 29 Newport Road Cardiff CF24 0TP Application fees You do not have to pay a fee to apply for a consent to investigate a groundwater source. The abstraction licence application does have a fee which is advertised on our website. Next steps Following completion of the groundwater investigation consent process, if your development is successful and you want to continue to abstract more than 20 cubic metres of water a day, you will need to apply for an abstraction licence. Although the pumping test will not usually have a significant effect on the environment, your proposed abstraction may have environmental effects which we must consider before we can grant a licence. The groundwater impact assessment report, which we may request to support any subsequent application for an abstraction licence, will help us to assess this. We aim to issue abstraction licences within four months of receiving your licence application, but it can take longer than this for more complex applications. Questions and more information If you have any questions, phone our National Customer Care Centre on 0300 065 3000 (Monday to Friday, 8am to 6pm). Data Protection Act 1998 The information provided by you will be processed by Natural Resources Wales in line with the Data Protection Principles to enable us to process your application, to monitor compliance with the licence/registration conditions, to process renewals, and for maintaining the relevant public register. We may process and/or disclose the information in connection with the following: - Consultation with third parties who are relevant and responsible for responding to consultation requests from NRW to enable us to process your application. - Providing *public register information for enquiries - Prevent and investigate possible breaches of environmental law and taking any resulting action - Responding to requests for information under the Freedom of Information Act 2000 and the Environmental Information Regulations 2004, where the Data Protection Act allows - Carrying out statistical analysis, research and development on environmental issues ## Guidance On Completing Form Wrc Application For A Consent To Investigate A Groundwater Source: Section 1 - Type Of Consent Tick The Appropriate Box To Tell Us Whether You Are Applying To Investigate A New Source Of Groundwater, Or To Extend Or Alter Existing Works. For Existing Works, Provide The Licence Serial Number Which This Application Relates To. Section 2 - Applicant details As the person completing the forms give your details, and, if different, the details of the legal entity who will hold the consent issued. Correspondence will be with the applicant unless you indicate otherwise. When we issue a consent it will specify the name of the person or company we have given permission to (referred to as 'the consent holder'). This consent holder will be responsible for keeping to the conditions set out in it. You, as the applicant, will usually be the consent holder unless you ask otherwise. If you have an agent or someone else who has agreed to be specified as the consent holder, you must provide an additional letter of authorisation. Please provide contact phone numbers and an email address where possible. Section 3 - Previous NRW discussions If you have previously discussed your proposal with someone in NRW please use this section to provide names or reference numbers. Section 4 - Remediation work The Restoring Sustainable Abstraction programme has identified abstractions that need to be stopped or altered in order to prevent further environmental damage. If you are making this application as a result of investigations carried out under this or other remediation programmes, please tick the 'Yes' box and provide details. Section 5 - Outline proposal You must provide an outline of your proposal. The amount of information given will depend on the complexity of your proposal and the sensitivity of the site. Information given here should allow us to clearly understand your proposal, the site location and surrounding area. Information given could include (but not be limited to):  A description of the proposed installation, pumping test and abstraction regime  Why this location has been chosen  A description of any measures proposed to mitigate any potential adverse effects on the water environment  Any data which would be of use to NRW to assess the main effects which the proposal may have on the water environment  An indication of the main reasons for the proposal, taking into account possible environmental effects ## Section 6 - Details Of The Proposed Investigation Indicate What The Proposed Means Of Groundwater Abstraction Will Comprise/Specify What Type Of Sources You Intend To Investigate. Section 7 - **Site Details** 7.1 Provide Details Of All Proposed Abstraction Locations. Provide A 12 Digit National Grid Reference (Ngr) And Name/Reference For All Points Of Abstraction Or Investigation. Ngrs Given Must Correspond With Maps Submitted. 7.2 State if the site had a historical use which may have caused contamination and if so please provide further details. Section 8 - Abstraction details Tell us how much water you are looking to abstract every second, hour, day and year. Give the maximum amounts, not averages. Make sure that the quantities you specify accurately reflect your needs. If you later apply for an abstraction licence, you will have to tell us how you calculated the quantities you are applying for. When you apply for an abstraction licence, if you request a higher rate of abstraction than that tested as part of the groundwater investigation consent, it is likely that you will have to go through the groundwater consent process again, which will take more time and cost you more money. Provide the purpose, period and volumes you propose to abstract for each abstraction point. If water is to be used for multiple purposes, provide a breakdown of the abstraction quantities for each different use. You need to give the instantaneous/peak abstraction rate (in litres per second) and the hourly (cubic metres/hour), daily (cubic metres/day) and annual quantities (cubic metres/year) you require for each purpose. ## Section 9 - Proposed Construction Details Complete The Table To Give Details Of The Proposed Borehole (Or Other Installation) Construction. Section 10 - Construction method (borehole/well) There is more than one way to drill a borehole or well. Companies that do this usually need to use a drilling flush to make the drilling process effective, and to reduce the risk of damaging their drilling equipment. We need the details of your proposed construction methods to understand the potential risks to the local area. You should also specify how you will dispose of waste products. If you are having a well or borehole professionally drilled, the drilling company should give you this information. ## Section 11 - **Post-Construction Development (Borehole/Well)** There Are Various Methods That Drilling Companies Can Use To Help Improve The Amounts Of Water That A Borehole Or Well Can Provide. Please Provide Details Of Any Post-Construction Development And How You Will Dispose Of Waste Products. The Drilling Company Should Give You This Information. Section 12 - Discharge Location (Pumping Test) If You Need To Carry Out Any Pumping Test, You Will Need To Discharge The Pumped Water Somewhere. We Need Details Of Where You Plan To Discharge This Water. If More Than One Location Is Proposed This Should Be Indicated. Section 13 - Discharge details (pumping test) We need to consider this information to make sure the discharge does not pose a risk to others, or the environment, from flooding or reduced water quality. Please mark the discharge points clearly on the map you provide with your application, and label them so they are not confused with the abstraction points. You will need to give us the 12 digit NGR of each point. If there are more than four discharge points, give details of the other points on a separate sheet of paper. You may need to get an Environmental Consent to Discharge Water from us before you are allowed to discharge water from the pumping test. We will tell you if this is necessary, and if so, what you will need to do. This permit application can take up to four months to determine, so you should contact us as early as possible. If you already have an Environmental Permit/Exemption to Discharge Water for any of these points, please give the reference number. Section 14 - Water Features Survey The Water Features Survey is an important part of your application, and we can only proceed with your application if a satisfactory survey is received. These notes explain more about the Water Features Survey and how you must monitor and measure those features when you carry out pumping tests. You must read British Standards ISO 14686 (2003), 'Hydrometric determinations - pumping tests for water wells - considerations and guidelines for design, performance and use'. This is the standard you must work to. You can get a copy from: Website: www.bsigroup.com Email: cservices@bsigroup.com Phone: 0845 086 9001 ## The Water Features Survey Before we can issue a consent to proceed with your application, you must carry out a detailed, accurate survey of all the water features in the area around your proposal. By 'water features' can include:  boreholes and wells, even if they are disused or filled in  adits (passages for drainage to or from a mine)  springs  general seepage or wetland areas  ponds and lakes, even if filled in  watercourses and  seepage lagoons and catch-pits You can get information which may help you identify water features from well catalogues, water company databases, and local authority registers (set up under the Private Water Supplies Regulations). Some sources of abstraction (whether licensed or not) may be (or may appear to be) unused. The area your survey should cover depends on the quantity of water you wish to abstract. The table below shows the minimum area your survey should cover. Daily abstraction quantity you require: Minimum radius of survey area annual quantity / 365 (metres) (cubic metres) 20 to 100 250 100 - 500 500 500 -1,000 1,000 1,000 - 3,000 1,500 3,000 - 5,000 2,000 Over 5,000 4,000 Survey results should be presented in Tables 14.1 and 14.2 or in an additional report (please indicate that you have done this). If more room is needed please print off additional tables 14.1 and 14.2 and indicate that you have done this. Example surveys are provided below as an indication of the level of information which is expected. Water feature Use (borehole, Alternative well, pond, (e.g. supplies Survey sheet number Diameter spring, adit, agricultural, available seepage, 1 of 1 drinking (millimetres) (e.g. mains wetland, lake, water, water) watercourse, disused) or other) National Grid Reference 12 digit: ST 24946 81528 Distance from source (metres): Borehole Domestic and pig rearing No 250 31 17.34 19.65 50 Site reference 1 Licence serial number: WA/090/0999/099 National Grid Reference 12 digit: ST 24952 81489 Distance from source (metres): Pond Nature pond No n/a see table 14.2 - - - 100 Licence serial number: Not licenced National Grid Reference 12 digit: ST 24922 81583 Distance from source (metres): Spring with catch pit Domestic Yes n/a see table 14.2 - - - 125 Licence serial number: Not licenced (>20 cubic metres per day) | Depth to | Name, address | |---------------|------------------| | Depth to | | | pumped | and telephone | | Depth to | | | rest | | | bottom | water | | water level | | | (metres) | level | | (metres) | | | (metres) | owner. | | | | | | | | | | | Owner: | | | Mr A Other | | | Home Farm | | | Long Lane | | | St Mellons | | | 02920 xxx xxx | | | | | | Owner: | | | Mr A Other | | | Home Farm | | | Long Lane | | | St Mellons | | | 02920 xxx xxx | | | | | | Owner: | | | Mrs Smith | | | Home House | | | Long Lane | | | St Mellons | | | 02920 xxx xxx | | | Site reference 1 | |------------------------------------------------| | Construction details of the borehole are | | uncertain, but it is thought that the bottom 5 | | metres of the borehole are slotted. Sketch | | below shows datum point. | | | | Pond appears to have no inflow or outflow | | and is in a waterlogged corner of the field. | | Land owner states that the pond is unlined | | and has never been stocked with fish. It is | | used for nature conservation. Please see | | photo below: | | | Catchpit at surface is sealed and was not able to observe. Abstraction is directly from catchpit. Householder stated that the spring has provided a steady clean supply of water since the house was bought in 1963. Access: Open / Sealed / Permission Refused Access: Open / Sealed / Permission Refused Access: Open / Sealed / Permission Refused Access You must get permission from the owner or occupier of any land before you carry out survey work. We can provide a letter to help you to ask for permission. Contact us on 0300 065 3000 for assistance. Survey quality You must carry out the survey to a high standard. If it is incomplete, inaccurate or otherwise unsatisfactory, we will ask you to repeat it. We cannot proceed with your application until we are completely satisfied with the survey. Effects on existing users If the survey indicates that the work is likely to significantly affect other water users, we will not allow you to proceed further unless you can show us you have reached a satisfactory agreement with those other users. That could, for example, include providing alternative supplies. Follow-up monitoring Any consent to pumping test issued as a result of your application may state that before, during and after pumping test, you must monitor specified water and wetland features. We will tell you what monitoring is needed once we have had an opportunity to assess your application and survey results. There may also be conservation sites which are not actually within the area the survey covers but are close enough to need monitoring when carrying out pumping tests. We will let you know if this is the case. We may need you to sink extra boreholes purely for monitoring purposes. ## Finalising The Programme Of Pumping Tests Before the programme of pumping tests starts, we must be satisfied that:  Appropriate measuring devices are in place  Measurements will be accurately made and recorded For large or sensitive developments we may have a site meeting with you or your staff and, where appropriate, representatives of other concerned organisations to make sure that the test has been properly set up. That meeting will normally take place about two weeks before the pumping test begins. ## Section 15 - Supporting Documents Complete Checklist Section 16 - Declaration This Section Must Be Signed By The Consent Holder. If You Have An Agent Or Someone Else Has Agreed To Be Specified As The Consent Holder You Must Provide An Additional Letter Of Authorisation. Who Can Apply For A Consent And Sign The Forms? Each Individual (Or Individual Trustee) Who Is Applying For Their Name To Appear On The Consent Must Complete This Declaration. Type of Consent Holder: Signature needed: | Individual / sole trader | *The Consent Holder | |-------------------------------------------------|---------------------------------------| | Registered company | Company director or company secretary | | The chairman, treasurer, secretary or other | | | person authorised to represent the organisation | | | Organisation of individuals | | | (other than partnerships, trusts | | | and charities) | | | Partnership | One or more of the partners | Trust All trustees or the chairman, treasurer or secretary Charity A person authorised to sign documents on behalf of the charity Public body (i.e. a local authority) A person authorised to sign on behalf of the organisation * If an agent is to sign on behalf of the Consent Holder, a letter of authorisation from the Consent Holder is required. On the application form, you need to provide us with the following details, depending on the type of applicant you are. | If the applicant is… | | |-----------------------------------------------------|-----------------| | An individual | their full name | | A company | | | the address of the Registered Office and a | | | company registration number, in line with | | | Companies House records | | | - full names and addresses of all partners | | | - the trading name | | | - the trading address | | | An organisation of individuals | | | (other than partnerships, trusts | | | secretary or other person and | | | charities - see below) | | | A club or charity | | | - give the full names and addresses of all trustees | | | - give the name and address of the person | | | authorised to receive the licence on their behalf | |
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Protocol on the handling of 'so-called' Honour Based Violence/Abuse and Forced Marriage Offences between the National Police Chiefs' Council and the Crown Prosecution Service This protocol has been approved and authorised by: ………………………….. Chief Police Officer [insert Police Area] ………………………….. Chief Crown Prosecutor [insert CPS Area] Contents Page SECTION 1 - PARTIES SECTION 2 - INTRODUCTION AND SCOPE OF THE PROTOCOL SECTION 3 - BACKGROUND SECTION 4 - INVESTIGATION AND RISK ASSESSMENTS SECTION 5 - PROTECTION ORDERS AND RESTRAINING ORDERS SECTION 6 - REFERRAL AND CHARGING SECTION 7 - CASE PREPARATION SECTION 8 - VICTIMS AND WITNESSES SECTION 9 - TRIAL SECTION 10 - SHARING LESSONS LEARNT SECTION 11 - SIGNATORIES ## 1. Section 1 - Parties 1.1 The Parties To This Protocol Are Xxxx Police And The Xxxx Crown Prosecution Service (Cps). 1.2 The successful prosecution of these cases and safeguarding of those victims involved; relies on strong and collaborative partnership working between the police and prosecutors. The police will be proactive in collating all relevant evidence and the CPS will be clear and informative about what (if any) further evidence is needed. 2. SECTION 2 - INTRODUCTION AND SCOPE OF THE PROTOCOL Please note that due to the differing terminology used by the police to the CPS and the Home Office i.e. 'so-called' Honour Based Abuse and Honour Based Violence, the rest of this document will refer to the term as 'so-called' Honour Based Violence/Honour Based Abuse (HBV/A). There is no statutory definition of 'so-called' HBV/A. 2.1 The commitment to end 'so-called' HBV/A and Forced Marriage (FM) is embedded in the cross-government Ending Violence against Women and Girls (VAWG) Strategy: 2016 to 2020. The strategy is underpinned by effective partnership working at both a local and national level. 2.2 The VAWG approach recognises that victims of 'so-called' HBV/A and FM crimes are disproportionally female. The approach acknowledges VAWG as a fundamental abuse of human rights and women's rights1. The UK government has signed and ratified the United Nations call to all states to prevent and respond to violence against women2. However the police and CPS are committed to all victims of crimes grouped together as 'VAWG' and to that end, are inclusive in their approach. All VAWG policies are applied fairly and equitably to all perpetrators and victims of crime - irrespective of their gender. 2.3 Chief Constables who are members of the National Police Chiefs' Council (NPCC) have overall responsibility for the investigation of alleged criminal activity in their individual force area. The NPCC published its revised strategy on Honour Based Abuse (HBA), FM and Female Genital Mutilation (FGM) for 2016-18 in December 2015. The strategy states that the police service's vision remains nothing less than the total eradication of HBA (which includes Violence), FM and FGM. 2.4 The CPS is the principal prosecuting authority dealing with criminal prosecutions in England and Wales. The CPS is fully committed to prosecuting fairly and effectively all those who harm others in the name of so-called 'honour'. All CPS polices are gender neutral and all victims receive the same access to protection and legal redress. 2.5 This document sets out the principles governing the investigation and prosecution of any 'so-called' HBV/A and FM offences. The objectives of this protocol are: - To achieve improved and consistent performance in the investigation and prosecution of 'so-called' HBV/A and FM; - To improve the service to victims of 'so-called' HBV/A and FM; - Increase public confidence in the Police Service and CPS response to 'so-called' HBV/A and FM and; - To reflect NPCC and CPS policy. 3. SECTION 3 - BACKGROUND 3.1 The definitions of HBA3 and FM4 adopted by the NPCC can be found within their revised strategy on HBA, FM and FGM for 2016-18. The Home Office requires the police service to record all incidents of domestic abuse, which includes 'so-called' HBV/A and FM. Individual forces should have their own flagging processes in place for these cases and should ensure they follow local procedure. 3.2 The HBV and FM definitions followed by the CPS can be found within CPS HBV and FM Legal Guidance. Prosecutors should also familiarise themselves with CPS HBV and FM: Guidance on Identifying and Flagging cases and ensure that they flag all cases of HBV and FM onto the CPS Case Management System (CMS). Prosecutors can also access the 'Forced Marriage and Honour Based Violence' e-learning module that can be accessed via the prosecution college. 3.3 It is important to remember that a number of offences can be committed in the context of 'so-called' HBV/A and FM e.g. common assault, GBH, harassment, kidnap, rape, threats to kill and murder. 'so-called' HBV/A and FM should also be considered in the context of the wider definition of Violence Against Women and Girls and domestic abuse5. Police should familiarise themselves with the College of Policing's Authorised Professional Practice on Domestic Abuse and prosecutors should reference the CPS Domestic Abuse Guidelines for Prosecutors. 3.4 Whilst there are many similarities between 'so-called' HBV/A and FM with domestic abuse there are also some stark differences given the collective nature of the offending, which includes the perpetration of crimes by offenders who fall outside the inter-familial relationships. 3.5 The specific offence of FM (s.121 of the Anti-Social Behaviour, Crime and Policing Act 2014) came into force in June 2014. A breach of a Forced Marriage Protection Order (FMPO) became a criminal offence under the same Act6. 3.6 The evidence of previous cases tells us that 'so-called' HBV/A and FM crimes are usually perpetrated by the victims' families, extended families and members of their community. Instances of 'so-called' HBV/A and FM can also lead to conspiracy between the families, extended families and communities of the perpetrator in order to protect them as opposed to the victim. Police and prosecutors should also remember that 'so-called' HBV/A and FM offences are also being committed increasingly in an online environment, e.g. through social media platforms. 3.7 Other useful information: Police: officers should liaise with their force area 'so-called' HBV/A and FM lead who can advise on relevant guidance and toolkits that may also assist when handling these cases. CPS: Toolkit for Prosecutors on Violence Against Women and Girls Cases Involving Vulnerable Victims, Guidelines on prosecuting cases involving communications sent via social media, Achieving Best Evidence in criminal proceedings Police and prosecutors must also be alert to the fact that in cases of 'so-called' HBV/A and FM, FGM may also be a factor too. See the Police / CPS joint Investigation and Prosecution Protocol into FGM and the College of Policing's Authorised Professional Practice regarding FGM. 4. SECTION 4 - INVESTIGATION AND RISK ASSESSMENTS 4.1 There must be early consultation between the police and CPS, the timing of which will be determined by the circumstances of each case. This will focus on building strong cases for prosecution from the outset. The Joint NPCC and CPS Domestic Abuse Evidence Checklist will also be relevant in 'so-called' HBV/A and FM cases and should be referred to. 4.2 The police should explore the role and behaviour of the suspect/defendant in order to ensure a balanced consideration of the accounts provided ensuring that all available evidence is gathered: - How plausible and consistent is the suspect's/defendant's account? What counter allegations, if any, have been made? - Were there any signs of injury to the suspect/defendant upon arrest (see domestic abuse guidelines on dealing with self-defence and/or counter-allegations)? - Were there any allegations made of any other non-violent behaviour that fall within the definition of domestic abuse7? - Are there any contradictions in the suspect's/defendant's account? - Has the suspect/defendant made no comment during interview from which an adverse inference can be drawn? 4.3 The range of offending behaviour, with particular reference to other crimes, needs to be considered, such as enforced sexual activity including rape8. Ultimately, prosecutors should be alert to the fact that an offender will follow a course of conduct which is used to control, coerce, dominate or exploit a complainant. Identification of the triggers for abuse will assist in understanding the context of the offending. These issues should be considered as risk factors, rather than as causal links to the offending behaviour, and will assist prosecutors in their consideration of the public interest. This will also assist when considering factors to be taken into account for bail applications and/or terms for restraining orders at later stages of the prosecution process. - CPS Domestic Abuse Legal Guidance for advice on avoiding assumptions in relation to terminology used and on the dynamics of domestic abuse - CPS Rape and Sexual Offences Legal Guidance. - College of Policing Authorised Professional Practice on Domestic Abuse - Protocol between the Police Service and Crown Prosecution Service in the Investigation and Prosecution of Rape 4.4 A clear and coherent account from the victim is reliant upon their powers of recall/concentration, their cognition of the events and their ability to communicate. A number of issues can impact on the precision or the detail of the account provided e.g. drug and alcohol use, mental health and physical disabilities. Police and prosecutors should refer to the Toolkit for Prosecutors on Violence Against Women and Girls Cases Involving Vulnerable Victims. 4.5 The safety of victims is paramount. A victim's family and/or members of their community may go to great lengths to discover their whereabouts once a crime has been reported. The risks to the victim from her/his entire family, the offender's family and the community should be considered in such cases; not just the direct risk of the immediate perpetrator(s) on the victim. There is evidence that the risks to the victim increase after they have engaged with the police service. In addition the risks also extend to others who may have assisted or otherwise supported the victim and these need to be considered by the police e.g. siblings or undisclosed partner. 4.6 In most cases the police will establish whether a witness is in fear and should inform the prosecutor. Ideally, a discussion about the type of 'protection' that should be applied for will take place between the police and the prosecutor at the pre charge stage. In some very serious cases witness protection will be necessary. Prosecutors should refer to the Witness Protection and Anonymity Legal Guidance. 4.7 The police will ensure that the Domestic Abuse, Stalking and HBV risk assessment (DASH)9 is used to assess the risk to the victim and inform the development of safeguarding plans in relation to the victim10. First response staff and their supervisor should identify risk factors, who is at risk and decide what level of intervention is required. Question 20 in the DASH outlines further questioning required in 'so-called' HBV/A and FM cases such as exploration into 'house arrest', being 'policed at home' and fear of being forced into engagement/marriage11. 4.8 Police must ensure they ask the victim about the abusers behaviour in all cases of 'socalled' HBV/A and FM. The risk identification process must remain on-going. Events and circumstances may undergo rapid and frequent change hence resulting in increases to the risk of the victim. The assessment must be kept under constant review. High risk cases may well require a multi-agency response and should be considered for referral to the relevant risk management panel i.e. the Multi-Agency Risk Assessment Conference (MARAC) and/or Multi-Agency Public Protection Panel (MAPPA). 4.9 Police and prosecutors should be aware that perpetrators may take victims of 'so-called' HBV/A and FM abroad to commit these crimes, they may be aware that the police and prosecutorial response is weak or non-existent in these other countries. Given the international nature of these crimes, early discussions with the extradition team at CPS Headquarters may assist. Information on the CPS extradition unit can be found on the internal CPS casework and knowledge hub. 5. SECTION 5 - PROTECTION ORDERS AND RESTRAINING ORDERS 5.1 Restraining orders will often be essential to ensure the on-going safety and security of victims of 'so-called' HBV/A and FM. The police will explain to victims that restraining orders can be applied for on conviction and upon acquittal. Prosecutors will ensure that the police have sought the victim's views, and provided accurate information to support the application for a restraining order. 5.2 Prosecutors will inform the police if a restraining order is granted by the court. The police will promptly inform the victim of the full details of any restraining order and where appropriate also share these with the IDVA/other specialist agency and the probation service. 5.3 A FMPO is a civil remedy issued under the FM (Civil Protection) Act 2007. It offers protection to a victim from all civil or religious ceremonies, by forbidding the respondent(s) themselves, or by encouraging or agreeing with any person whatsoever, from entering into any agreements in relation to the engagement or matrimony. Breach of a FMPO is now a criminal offence under s120 of the Anti-Social Behaviour, Crime and Policing Act 2014 which came into force on 16 June 2014. 5.4 Police should consider applying for a FMPO at the outset of an investigation12. Applications for FMPOs will be dealt with by the civil court; a crime does not have to be reported to start this process. Where a crime is reported and a FMPO is applied for both a civil and criminal proceeding will be taken forward. 5.5 Breach of a FMPO can be dealt with either in a criminal court or in a civil court. If the breach has been heard in a civil court then it is not possible to prosecute the same breach through the Criminal Justice System (CJS). When the breach is dealt with in the criminal court, breach of the FMPO should be treated in the same way as a prosecution of any other breach of an order for example, a breach of a non-molestation order. 6. SECTION 6 - REFERRAL AND CHARGING 6.1 To facilitate effective referral and charging practices between the police and the CPS, all police forces, and all CPS areas will appoint Single Points of Contact (SPOCs) for 'so-called' HBV/A and FM cases. A list of SPOCs will be contained as a separate annex for police forces and the CPS which will be held with the CPS and NPCC, 'so-called' HBV/A and FM Policy Leads. The police and prosecutor SPOCs should make contact monthly to discuss: reporting, referrals, charging and; prosecutions, in relation to 'so-called' HBV/A and FM within their area. Agencies should work together to identify opportunities in awareness raising and improving the support to victims and witnesses. 6.2 Police and prosecutors should refer to the Domestic Abuse Charging Advice Sheet which outlines existing requirements and considerations around charging decisions in domestic abuse cases as outlined in the 5th Edition of the Director's Guidance on Charging (and any subsequent editions). It should be read alongside this Charging Guidance and relevant Legal Guidance and policies developed to support effective investigations and prosecutions. 6.3 The CPS will make the ultimate decision as to whether an offence, which fits the definition of domestic abuse, is charged. When considering the appropriateness of the charge, prosecutors should consider the totality of the perpetrators offending. However the assessment of the evidence on the basis of the Threshold Test *must only* be made by a police decision maker when the suspect is *not suitable for bail* and *not all the evidence* is available at the time when they must be released from custody unless charged. 6.4 In all cases other than those where it is intended to remand the suspect into custody the supervising officer must assess the available evidence to determine if the Full Code Test can be met. In cases where the evidential stage is met, but the police consider that it is not in the public interest to prosecute, the case must still be referred to the CPS to make the ultimate decision. Therefore, police decision makers must be satisfied that there is sufficient evidence for a realistic prospect of conviction before referring a case for a charging decision. 6.5 When submitting a case for a charging decision based on the Full Code Test only files that have been confirmed as meeting the required standard by an appropriate accredited supervisor will be accepted by the CPS. All cases not meeting this standard will be owned by the police who will be responsible for any decision to take no further action. 6.6 The CPS will review all police charged cases prior to the first hearing in accordance with their duty under the Code for Crown Prosecutors. Where it appears that the police have charged a case not permitted by the Director's Guidance on Charging, the reviewing prosecutor must consider whether the evidence and material available at that time fully meets the Threshold Test or Full Code Test relevant to the circumstances of the case. 6.7 Where a decision is taken not to charge, the police should inform the victim directly or indirectly through an interpreter/an appointed person e.g. an Independent Domestic Violence Advisor (IDVA), to explain the issues surrounding the decision. 6.8 Prosecutors will ensure: - The DASH has been applied by the police, and used to inform decisions regarding bail or remand as well as to inform safeguarding plans in relation to the victim. - The domestic abuse Joint NPCC and CPS Evidence Gathering Checklist has been completed. - The MG3s contains a full record of the decisions taken with reasons for those decisions. - Every MG3 contains an Action Plan (unless there is no additional or outstanding work required from the police). Dates will be agreed between the police and the CPS on the Action Plan. 6.9 With the exception of charging decisions taken by CPS Direct, charging decisions in 'socalled' HBV/A and FM cases in which rape has been perpetrated will always need to be made by Area-based prosecutors in Rape and Serious Sexual Offence Units. Where a charging decision is made by CPS Direct, any MG3 must contain an action that the police contact the local rape specialist within three working days to make an appointment for a consultation. 6.10 The police should refer to the cautions section within the College of Policing Domestic Abuse Authorised Professional Practice (APP). 6.11 Simple cautions can be offered only in exceptional circumstances, because of the interpersonal nature of these crimes, this is subject to a number of provisions outlined within the APP (see link above). When the evidential stage of the Full Code Test is passed, it will rarely be appropriate to deal with a 'so-called' HBV/A and/or FM case by way of a simple caution. 6.12 Part 3 of the Criminal Justice Act 2003 makes provisions for offenders to be diverted from the courts by issuing them with a conditional caution. As stated clearly in the DPP's Guidance on Adult Conditional Cautions, domestic abuse cases must not be considered for conditional cautioning13. 7. SECTION 7 - CASE PREPARATION 7.1 Prosecutors should work closely with the police and other specialist agencies to ensure that the best evidence is gathered and presented to the court. The case should have a clear narrative pre-empting and challenging any assumptions/associated myths and stereotypes. A strong, coordinated prosecution team is required to proactively build and manage a case. 7.2. If the suspect/defendant pleads not guilty, the full evidential file sent by the police will include: - Completed MG2, as necessary (which indicates whether or not the police considers the victim might benefit from special measures) - MG3/3A** - Report/further report to the prosecutors - MG4/4A - Charge sheet and bail/variation or MG4D/DPG/E-postal/written charge (where Digital Case File (DCF) not in use) - MG5 (DCF where in use) - Case summary including Common Law Certification on Disclosure - MG6** - Case File Evidence and Information - MG9** - List of Witnesses - MG10** - Witness non-availability - MG11(s) - All key witness summons and the VPS14 - MG12 - Exhibits List - MG16*- Bad character/Dangerous Offender - Streamlined Disclosure Certificate - A completed Joint NPCC and CPS Domestic Abuse Evidence Checklist - DASH to inform decision regarding bail or remand - The victim's views on an application for a FMPO or restraining order; and - Confirmation that the police have discussed the proposed terms of a FMPO and/or a restraining order with victim and a draft FMPO/restraining order setting out proposed conditions tailored to victim's needs and addressing the specific circumstances of the behaviour 7.3 When a victim asks the police not to proceed or withdraws their support for a prosecution the police will take a written statement that will: - Explain the reasons for withdrawing support; - Set out whether the victim has been pressurised to withdraw their complaint by any person and; - Confirm whether the victim is pursuing any civil action. 7.4 In addition, the police will provide a report that will: - Set out the investigator's views about the case, in particular the reasons for withdrawal and its impact on the case; - Confirm if the victim is supported by any specialist support service or an IDVA and, where they are, include the views of the IDVA or supporter on how the victim might react if required to attend court and whether they have been put under pressure not to support the prosecution; - Assess the risks to the victim and any other persons' safety and; - Assess how the victim might react if required to attend court. 7.5 If it is suspected that the victim has been pressurised or is frightened, the police will investigate further and assess any support that has been offered and whether the intervention of a local specialist support service could make a difference. The prosecutor will, if appropriate, ask the court to delay any hearing to enable this to be done. 7.6 If the victim confirms that the complaint is true but still wants to withdraw, the police and CPS will consider the feasibility of continuing without the victim's evidence and whether to do so against the victim's wishes. 7.7 The issue of a witness summons is a last resort; full consideration should be given to the specific facts of the case and impact on the complainant's safety and wellbeing15. Where a complainant is reluctant to attend court and it is decided the case can only continue with the complainant's evidence to prove the case, Section 169 of the Serious Organised Crime and Police Act 2005 allows the court to issue a witness summons if it considers it to be in the interests of justice to do so. 7.8 Before the decision to apply for a witness summons is taken, prosecutors must make enquiries to satisfy themselves that the safety of the victim, any children and/or other dependants will not be endangered. This information could be sourced from the police, and other sources such as any support organisations involved with assisting the complainant. 7.9 Prosecutors should familiarise themselves with the section on witness summons within the CPS Domestic Abuse Guidelines for Prosecutors. 7.10 A prosecution can be supported by the provision of expert evidence from those who have an understanding not only of 'so-called' HBV/A and FM, but specifically of the communities within which they commonly occur. Expert evidence can assist juries and magistrates' in areas with which they are not familiar. Prosecutors should familiarise themselves with the guidance on expert evidence. 8. SECTION 8 - VICTIMS AND WITNESSES 8.1 It is important for police and prosecutors to remember that these cases may involve some of our most vulnerable victims and witnesses who may have the least confidence in the criminal justice process. Victims often feel a loyalty to their family/community and this might make them particularly reluctant to support a prosecution They may also need support mechanisms not just during the prosecution process, but also after the case is concluded. Victims of 'so-called' HBV/A and FM are entitled to an enhanced service under The Code of Practice for Victims of Crime: CPS Legal Guidance (Victim's Code). The police and CPS will comply with their responsibilities as set out in the Victim's Code. 8.2 The police are responsible for ensuring that all 'so-called' HBV/A and FM victims are assisted appropriately according to their specific needs (age, maturity, disability, minority ethnic background, religion, gender/gender identity etc.) and that they are referred to local specialist support services at the start of an investigation including, IDVA support, BME specialist organisations, or their equivalent, where available. A list of support agencies and corresponding help lines can be found within CPS HBV and FM Legal Guidance Annex D. 8.3 In every 'so-called' HBV/A and/or FM case the police will obtain the victim's agreement on who is to be their SPOC and their preferred means of contact (telephone, text, email or other). The identity of the SPOC should be shared with the CPS and the Witness Care Unit so that it is clear who is responsible for communicating with the victim and recording any actions arising. Thought should be given to succession planning in preparation for when a SPOC moves on or has any absence from work. 8.4 Police officers will explain to victims and their supporters the available special measures and their advantages and disadvantages, including any potential impact on the proceedings. They will obtain victim's informed views and pass them to the CPS to inform any special measures application. This should include the name of any supporter, including any IDVA that the victim wishes to accompany them in court or a live link room. The CPS should make applications for special measures, bad character and hearsay evidence at the earliest possible opportunity. Police and prosecutors should remind victims of the services offered by the Witness Service such as pre-trial familiarisation visits. 8.5 Where the CPS decision is not to charge or ends all proceedings in relation to the victim, the victim should be informed of their right to have the case re-reviewed as part of the Victim's Right to Review (VRR) scheme. 8.6 Police and prosecutors should familiarise themselves with Table 3 of the Toolkit for prosecutors on VAWG cases involving vulnerable victims, which outlines the support that should be given to vulnerable victims throughout the CJS. 8.7 The police will ensure that in every case the victim has the opportunity to provide a Victim Personal Statement (VPS). In all cases, the VPS and the information about the victim's preference will be relayed to the court at the first hearing by the CPS advocate. The VPS can be read aloud in court by the victim or someone on the victim's behalf; this decision is at the discretion of the court. 8.8 When selecting interpreters, care must be taken to ensure that they have an understanding of the culture, speak the same language/dialect and where possible are sensitised to issues of gender based violence in BME communities. Experience has led to concerns about interpreters and translators who are not on the approved list and who may often be part of the family or linked to the group suspected of carrying out the crime. The selection of the right interpreter is essential given the potential risks for the details of the victim's account to be inappropriately disclosed to the perpetrators and/or other community members or for the victim to be threatened or intimidated by the interpreter. Police and prosecutors should consult CPS guidance on the use of interpreters. 8.9 The immigration status of the victim may need to be considered. Victims with an insecure immigration status are particularly vulnerable as their rights to settlement or public funds, such as social security benefits and public housing, may be limited. They may be reluctant to come forward to seek help as they may fear deportation and/or destitution. 8.10 Investigators, prosecutors and Witness Care Units need to know what support agencies are available for victims within their local area, nationally, and internationally. Victims must always be afforded the opportunity to be referred to specialist VAWG services and not subject to automatic referral without their consent. The police must endeavour to ensure the victim is provided with access to such support16. Police and prosecutors should refer to the Domestic Abuse Guidelines for Prosecutors and the UK Border Agency (UKBA) Website. 9. SECTION 9 - TRIAL 9.1 Prosecutors should familiarise themselves with the CPS Speaking to Witnesses at Court guidance which emphasises the need to ensure witnesses are properly assisted and know more about what to expect before they give their evidence. It sets out what is expected of prosecution advocates, outlining what they can and cannot say to witnesses and explaining the difference between assisting a witness to be better able to deal with the rigors of giving evidence and witness coaching. 9.2 Also agreed, as part of its implementation, is a roles and responsibilities document which sets out the roles and responsibilities of all agencies which support victims and witnesses at court. Each CPS Area should have discussed this document with local CJS partners as part of national implementation of the CPS guidance. The document may have been tailored to suit local practices, as such please ensure the local Roles and Responsibilities document is referred to. 9.3 The prosecuting advocate will introduce themselves to the victim at court prior to the commencement of the trial. This is especially important if a special measures meeting with the victim has not taken place17. Prosecutors should be aware of the potential for the witness to feel further victimised and/or traumatised and, to minimise this, should ensure that witnesses feel valued and involved in the court process. Particular care needs to be taken to make sure they understand what will happen in court. 9.4 Witnesses should be reassured that the prosecution can object to intrusive/irrelevant cross-examination and the judge will decide whether the questions need be answered. The witness should be advised that the judge's decision must be followed. 9.5 If a decision is taken at court to offer no evidence or accept a lesser plea the views of the victim will be taken into account before a final decision is reached and the advocate will speak to the victim directly or indirectly through an interpreter/an appointed person e.g. an IDVA, to explain the issues surrounding the decision. 10. SECTION 10 - SHARING LESSONS LEARNT 10.1 Both the local police and CPS will monitor these cases and provide feedback about good practice and areas for improvement through an agreed frequency of meetings between the police and the CPS lead. This information will then be passed quarterly to the CPS 'socalled' HBV/A and FM Operational Policy lead, the NPCC lead on 'so-called' HBV/A and FM and the College of Policing so that national lessons can be learnt. 10.2 Where appropriate lessons learnt should also be shared with local specialist support agencies either through existing forums or by arranging ad-hoc meetings. 11. SECTION 11 - SIGNATORIES 11.1 This protocol will take effect in respect of all 'so-called' HBV/A and FM investigations and prosecutions commencing on or after XXXX.
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## Shock-Responsive Social Protection Systems Toolkit Appraising the use of social protection in addressing large-scale shocks Clare O'Brien, Rebecca Holmes and Zoë Scott, with Valentina Barca January 2018 Ja January 2018 ## About The Project The Shock-Responsive Social Protection Systems study is a research programme (2015 to 2018) led by Oxford Policy Management (OPM), in consortium with the Overseas Development Institute (ODI), the Cash Learning Partnership (CaLP) and INASP. Its aim is to strengthen the evidence base as to when and how social protection systems can better respond to shocks in low-income countries and fragile and conflict-affected states, thus minimising negative shock impacts and reducing the need for separate humanitarian responses. The research is funded by UK Aid from the UK government, as part of the Department for International Development's (DFID's) Humanitarian Innovation and Evidence Programme (HIEP), an initiative to improve the quality, quantity and use of evidence in humanitarian programming. Six case studies form the core of the analysis of the features of a social protection system that facilitate its use to respond to shocks, and of the ways in which social protection, humanitarian assistance and disaster risk management systems can best work together for a more effective response. The three in-depth case studies—of Mozambique, Mali and Pakistan—explore the issue across a wide range of shocks, and reviewing a number of social protection interventions. Two light-touch case studies, of the Philippines and Lesotho, focus on a single shock. Finally, a light study of the Sahel region reviews regionwide mechanisms for responding to food security crises. ## About This Toolkit Drawing on both the research methods used in the six case studies, and on their findings, this toolkit brings together information on key concepts, diagnostic tools and guidance for determining whether shock-responsive social protection is appropriate in a given context, and the factors that might influence its effectiveness. It is aimed at social protection, humanitarian and disaster risk management professionals who are interested in pursuing better responses to emergencies, including in fragile and conflict-affected settings. This toolkit will help readers to:  Understand what is meant by 'shock-responsive social protection' and other key terms  Assess the feasibility of different options for shock-responsive social protection in your context  Take steps to strengthen the systems underlying shock-responsive social protection  Learn from other countries' experience with shock-responsive social protection  Access other useful resources. scale shocks', Oxford Policy Management, Oxford, UK. ## Acknowledgements We warmly appreciate the time and insights shared by all our respondents—from national and local governments, as well as numerous multilateral and bilateral development partners, NGOs, private sector organisations and research firms—not only in the case studies but also during numerous workshops and consultations meetings over the research period. DFID—and in particular the project lead, Heather Kindness—has provided valuable guidance throughout. The research design and its outputs have benefited from peer review from an independent Research Advisory Group, for whose advice we are most grateful. The team for the overall project, whose contributions form the foundation both of this report and of all other outputs of the research, is: Sarah Bailey, Valentina Barca, Simon Brook, Joanna Buckley, Francesca Bastagli, Cécile Cherrier, Nathalie Cissokho, Jenny Congrave, Lourdes Fidalgo, Rebecca Holmes, Andrew Kardan, Naffet Keïta, Simon Levine, Tanya Lone, Emmanuel Luna, Marta Marzi, Malefetsane Masasa, Clare O'Brien, Muhammed Usman Qazi, Faisal Rashid, Clara Richards, Zoë Scott, Kay Sharp, Gabrielle Smith, Rebecca Vo, and Carol Watson. We extend our thanks to Heather Kindness, Lara Karat, Simon Narbeth and Nicola Ranger for their comments and inputs to this toolkit. The views expressed are those of the authors and do not necessarily reflect the UK government's official policies. ## Contents | List of figures, tables and boxes | v | |--------------------------------------------------------------------|-----| | | | | Abbreviations | vi | | | | | Overview | vii | | | | | S | | | ECTION | | | A | | | | | | H | | | OW TO USE THIS TOOLKIT | | | | 1 | | | | | A1 | | | | | | Why this toolkit? | 1 | | | | | A2 | | | | | | Learning objectives | 2 | | | | | A3 | | | | | | What's in the toolkit? | 3 | | | | | S | | | ECTION | | | B | | | | | | L | | | EARNING | | | | 4 | | | | | B1 | | | | | | Key definitions | 5 | | | | | B2 | | | | | | What is 'shock-responsive social protection'? | 7 | | | | | B3 | | | | | | Options for using social protection to respond to shocks | 8 | | | | | B4 | | | | | | When might shock-responsive social protection be appropriate? | 13 | | | | | S | | | ECTION | | | C | | | | | | D | | | IAGNOSIS | | | | 15 | | | | | C1 | | | | | | Questions: Shocks and crises | 16 | | | | | C2 | | | | | | Questions: Poverty and vulnerability | 17 | | | | | C3 | | | | | | Questions: The institutional environment | 18 | | | | | C4 | | | | | | Questions: The potential contribution of specific programmes | 21 | | | | | C5 | | | | | | Questions: The potential contribution of specific delivery systems | 23 | | | | | C6 | | | | | | Questions: The financial / budgetary context | 24 | | | | | C7 | | | | | | How to interpret your diagnosis | 25 | | | | | S | | | ECTION | | | D | | | | | | F | | | ACTORS GUIDING A RESPONSE | | | | 27 | | | | | D1 | | | | | | Finance | 28 | | | | | D2 | | | | | | Targeting | 30 | | | | | D3 | | | | | | Data management | 33 | | | | | D4 | | | | | | Transfer values | 37 | | | | | D5 | | | | | | Payment / distribution modality | 39 | | | | | D6 | | | | | | Coordination | 43 | | | | | D7 | | | | | | Communication | 47 | | | | | D8 | | | | | | M&E | 48 | | | | | S | | | ECTION | | | E | | | | | | E | | | XPERIENCE | | | | 52 | | | | | S | | | ECTION | | | F | | | | | | O | | | THER RESOURCES | | | | 60 | | | | | S | | | ECTION | | | G | | | | | | G | | | LOSSARY | | | | 73 | | | | | | | ## List Of Figures, Tables And Boxes Figure 1 Our typology of social protection .............................................................................. 5 Figure 2 Typology of options for shock-responsive adaptation ............................................... 8 Figure 3 Options for reaching households through social protection databases ................... 33 Figure 4 Analytical frameworks for DRM and social protection ............................................. 43 Table 1 Summary of typology of options for shock-responsive adaptation 11 Table 2 Analytical frameworks for evaluating and assessing value for money of an emergency response: OECD and DFID 14 Table 3 Questions to map design and implementation features of current social protection programmes 22 Table 4 Options for using a beneficiary database in a shock 34 Table 5 Options for using data on non-beneficiaries in a shock 34 Table 6 Five dimensions by which to assess if a social protection* database is useful 36 Table 7 Considerations in ensuring *accessibility, robustness, integration* and cost-efficiency of the distribution mechanism 40 Table 8 Opportunities for collaboration between DRM and social protection 46 Table 9 Types of indicator 49 Table 2 Example of topics that might be covered by shock-responsive social protection indicators 50 Table 11 Main outputs of the global study 60 Table 12 Other outputs from the Global Study 61 Table 13 Global study webinars 62 Table 14 Outputs from OPM and WFP's regional study on shock responsive social protection in Latin America and the Caribbean 62 Table 15 Other resources and toolkits 63 Box 1 Example: Adapting the payment modality after a typhoon in the Philippines .......... 42 Box 2 Considerations when selecting social protection indicators .................................... 51 ## Abbreviations | ARC | Africa Risk capacity | |---------|------------------------------------------------------------| | ATM | Automatic Teller Machine | | CaLP | Cash Learning Partnership | | Cat DDO | Catastrophe Deferred Drawdown Options (World Bank) | | CCT | Conditional Cash Transfer | | CGP | Child Grant Programme, Lesotho | | CRS | Cristian Relief Services | | DFID | Department for International Development | | DRM | disaster risk management | | DSWD | Department for Social Welfare and Development, Philippines | | ECHO | European Civil Protection and Humanitarian Aid Operations | | FAO | Food and Agriculture Organisation | | HSNP | Hunger safety Net Programme, Kenya | | ISPA | Interagency Social Protection Assessment | | M&E | Monitoring and evaluation | | NADRA | National Database and Registration Authority, Pakistan | | NGO | Non Governmental Organisation | | NISSA | National Information System for Social Assistance, Lesotho | | NSER | National Socio Economic Registry, Pakistan | | OECD | Organisation for Economic Co-operation and Development | | ODI | Overseas Development Institute | | OPM | Oxford Policy Management | | PMT | Proxy means Test | | PSNP | Productive Safety Net Programme, Ethiopia | | PSSB | Basic Social Subsidy Programme, Mozambique | | RFP | Risk Financing Mechanism | | WFP | World Food Programme | | | | ## Shock Responsive Social Protection: Toolkit Overview Section A: How To Use This Toolkit? A1 Why this toolkit? A2 Learning objectives A3 What's in the toolkit ## Section C: Diagnosis C1 Questions: Shocks and crises C2 Questions: Poverty and vulnerability C3 Questions: The institutional environment C4 Questions: The potential contribution of specific programmes C5 Questions: The potential contribution of specific delivery systems ## Section D: Factors Guiding A Response D4 Transfer values D5 Payment / distribution modality D6 Coordination D1 Finance D2 Targeting D3 Data management ## Section E: Country Experience | E1 | Design tweaks | |------|----------------------| | E4 | Horizontal expansion | | E5 | Alignment | | E2 | Piggybacking | E3 Vertical expansion ## Section B: Learning B1 Key definitions B2 What is 'shock-responsive social protection'? B3 Options for using social protection to respond to shocks B4 When might shock-responsive social protection be appropriate? C6 Questions: The financial / budgetary context C7 How to interpret your diagnosis D7 Communication D8 Monitoring and Evaluation ## Section F: Other Resources Section G: Glossary F1 Global study on shock responsive social protection (DFID) F2 Latin America and Caribbean regional study (WFP) F3 Other resources and toolkits In partnership with: ## Section A How To Use This Toolkit This section covers:  Why we have developed this toolkit  Who it is aimed at, and what you can expect to get out of it  The different sections of the toolkit, and how to navigate it ## A1 Why This Toolkit? Large-scale shocks are becoming more numerous, frequent and long-term. Disaster risk management (DRM) and humanitarian practitioners commonly play a vital role already in addressing them. Can social protection programmes and systems also contribute to responding to shocks, either before or after the crisis arises? This toolkit provides guidance on how to think through the issues. Globally, the frequency, size and duration of disasters and crises—be they the consequence of natural phenomena or economic or political shocks—are on the rise. The cost of responding to these disasters has been increasing, too. Many shocks are predictable and protracted, and often slow-onset. Governments are already likely to have a mandate to address such shocks: the field of disaster risk management (DRM) is intended both to reduce the likelihood of these adverse events and to present a way for them to be addressed if they arise. While national governments bear the main responsibility for mitigating the risk of shocks and responding to them, the international humanitarian community may provide assistance if the scale of the crisis is beyond the capacity of the government to deal with it, or where the government is not in a position to respond. However, the demands placed on both governments and the international humanitarian community to provide assistance continue to grow. The value of international humanitarian assistance keeps hitting record highs—the last three years have each seen the highest ever levels of assistance provided—yet the gap compared with what is needed continues to widen. Often humanitarian assistance is being provided to the same country, for the same crisis, for years at a time. Governments and international agencies alike are therefore committed to finding a way forward that responds more efficiently and effectively to shocks. They aim to 'use existing resources and capabilities better to shrink humanitarian needs over the long term', in the words of the Grand Bargain made by the humanitarian and development communities at the World Humanitarian Summit ('Grand Bargain', 2016). This may include doing more before a crisis (preparedness) and in the early stage of a crisis, rather than reactively. Many actors are now asking whether and how long-term social protection systems can play a greater role, since these are already intended to meet the needs of the poorest households, to build resilience and to respond to crises. This toolkit responds to the demand from policymakers and programme implementers for practical guidance that can clarify key concepts, suggest approaches for assessing the suitability of shockresponsive social protection and highlight major issues for consideration in its implementation. ## A2 Learning Objectives This toolkit is for policymakers and programme implementers, both government and nongovernment, working in DRM, humanitarian assistance or social protection. Its purpose is to provoke ideas that will equip you to better understand whether and how your activities might contribute to improved outcomes for households faced with large-scale crises. It is also intended to enable you to interact with people working in related sectors, on the basis of a common understanding of shock-responsive social protection. This toolkit is aimed at DRM, humanitarian and social protection professionals who are interested in pursuing better responses to emergencies, including in fragile and conflict-affected settings. This includes people working for governments, their development and humanitarian partners, and NGOs. Drawing on both the research methods used in the six case studies, and on case study and literature review findings, this toolkit brings together information on key concepts, diagnostic tools and guidance for determining whether shock-responsive social protection is appropriate in a given context, and the factors that might influence its effectiveness. This toolkit will help you to:  Understand what is meant by 'shock-responsive social protection' and other key terms  Assess the feasibility of different options for shock-responsive social protection in your context  Take steps to strengthen the systems underlying shock-responsive social protection  Learn from other countries' experience with shock-responsive social protection  Access other useful resources. Note that this toolkit does not—and cannot—provide you with a simplistic flowchart that says, 'If you are in context A, then you should do X, Y and Z to adjust your social protection programme'. We wish that it could! Each context is, of course, highly specific. As with any other policy the options you choose will depends on the nature of the crisis and the number and characteristics of people affected, as well as on political will, budgetary constraints, relationships between agencies, the set of alternative possibilities and many other factors. The relative maturity of the DRM and social protection sectors also plays a big part. Our aim is therefore rather to guide you to ask the right questions and think through potential risks and challenges of different courses of option, to enable you be confident in your subjective decision of how to act and the trade-offs. ## A3 What'S In The Toolkit? This toolkit contains guidance for both retrospective analysis and forward planning of systems and interventions that address large-scale shocks, as well as an explanation of key concepts and terms. The toolkit is structured as follows: | Section | Name | |----------------------------------------------------------------------------|--------------------------------------------------------| | A | | | How to use this | | | toolkit | | | Overview of rationale, learning objectives and structure | | | The main conceptual frameworks: | | |  | | | | What is shock-responsive social protection | | B | | | Learning | | |  | | | | What forms might it take | |  | | | | How might you determine whether it is 'better' than an | | alternative approach | | | C | | | Diagnosis | | | Recommended questions to help you assess the suitability of shock- | | | responsive social protection in your context. Identifies the current | | | situation. Questions on shocks and crises; poverty and vulnerability; the | | | institutional environment (roles, responsibilities, policies, partnerships | | | etc.); the contribution of DRM, humanitarian and social protection | | | programmes / delivery systems; and financing. | | | Also some thoughts on how to interpret the information once you have | | | gathered it | | | D | | | Factors guiding a | | | response | | | A more forward-looking section on things to consider if you are intending | | | to design and implement a 'shock-responsive' element in your social | | | protection programme or system. Covers topics such as targeting, | | | coordination, data management | | | E | | | Experience | | | References to recent examples and case studies worldwide | | | F | | | Other resources | | | Links to further project materials, other toolkits, guidance notes and | | | studies | | | G | | | Glossary | | | Glossary of key terms | | Read section B at any time, alongside the related resources listed in section F, to familiarise yourself with the topic of shock-responsive social protection. Use section C to guide you when you want to analyse the context in which you are operating. There is no need to wait until a crisis before using these questions, as many of them can and should be answered even in the absence of a shock, as part of a preparedness exercise. Use section D if you are actively thinking about introducing a shock-responsive social protection element and need a reference to the key issues for design and implementation. Use sections E and F for inspiration! ## Terms That Are Explained In The Glossary Are Hyperlinked To The Glossary Text In Their First Use From Section B Onwards. ## Section B Learning This section introduces you to the main concepts of shock-responsive social protection. By the end of this section you will understand:  The definition we are using for Social Protection, Humanitarian Assistance and Disaster Risk Management  What we mean by 'shock-responsive social protection'  Options for making social protection programmes and systems more responsive to shocks  A framework for deciding whether shock-responsive social protection is appropriate in a given context ## Why Is This Section Important? Even A Term Such As 'Social Protection', And Certainly 'Shock-Responsive Social Protection', Is Interpreted Differently By Different Actors. Countries May Have Their Own Definition Of Social Protection, Perhaps In A National Social Protection Policy Or Strategy. This Section Therefore Sets Out A Common Framework Of Terms And Principles To Facilitate Engagement On The Topic Across Sectors. B1 Key Definitions What Counts As Social Protection? Social protection can be defined as the set of public actions that address both the deprivation and vulnerabilities of the poorest, and the need of the currently non-poor for security in the face of shocks. This 'public' response may be governmental or non-governmental (Norton *et al.*, 2001). It has also been broadly defined as policies and actions which enhance the capacity of poor and vulnerable people to escape from poverty and better manage risks and shocks. Social protection encompasses a wide range of instruments, with varying objectives and financing mechanisms (Figure 1). We make a distinction between those that are 'non-contributory' (where the beneficiary does not have to pay directly into a scheme in order to receive something back) and those that are 'contributory' (where only those who pay into the scheme, or on whose behalf a payment is made, can receive something back). Source: OPM (2017). Notes: (1) 'Non-contributory' schemes are defined by the International Labour Organisation (ILO) entitlement to receive benefits' (ILO, 2017). Public works programmes are usually counted as 'non-contributory' even though the recipient contributes labour. (2) Social transfers may be conditional or unconditional. A conditional transfer requires the recipient to meet certain behaviours (such as ensuring school attendance) to receive the benefit. Beyond this, interventions can be classified broadly as 'social assistance', 'social care', 'social insurance' and 'labour market policies'. Our focus in this toolkit—and, indeed, among many policymakers considering shock-responsive social protection—is mainly on social assistance interventions. These include:  Conditional and unconditional cash transfers  Vouchers (e.g. for food, or for medicines for livestock)  In-kind transfers (such as agricultural inputs or food, including school feeding programmes);  Public works programmes (cash-for-work or food-for-work)  Education- and health-specific measures (fee waivers, health insurance, etc.)  Subsidies (e.g. on food / agricultural inputs / fuel) Other types of social protection also play a crucial role. For example, the provision of psychosocial support by social workers, which would fall under the 'social care' classification, can be vital to minimise trauma after a disaster. ## What Counts As Humanitarian Assistance? Humanitarian assistance is defined as the resources used to fund actions that are designed to, 'save lives, alleviate suffering and maintain human dignity during and in the aftermath of manmade crises and natural disasters, as well as to prevent and strengthen preparedness for the occurrence of such situations' (Principles and Good Practice of Good Humanitarian Donorship, 2003). Humanitarian assistance may take many forms. It may include reconstruction and rehabilitation (e.g. restoring infrastructure and community assets such as water supplies), emergency food or cash assistance, services such as the provision of shelter, health, nutrition and education, and measures to protect the safety of the population. Some argue that it extends also to DRM activities, early warning systems and contingency planning (Global Humanitarian Assistance, 2014). The mix depends on the particular needs of a crisis and the priorities of the actors involved. In some circumstances the UN coordinates assistance in thematic clusters in line with sectoral objectives (food security, shelter etc.). The precise boundaries of humanitarian activities and expenditures with development ones are debated and often blurred. Only a few of these relate directly to social protection. There is a clear overlap in relation to the provision of material support to households in need of assistance and to enable populations to restore their livelihoods after an emergency. The crises to which this assistance responds may be called 'humanitarian crises', though some use that term more narrowly to refer only to crises that exceed the government's capacity to respond. In this Toolkit we consider that governments can respond to a humanitarian crisis. ## What Counts As Disaster Risk Management? DRM activities are all the processes that aim to reduce the likelihood of a disaster, lessen the impact of hazards and improve people's ability to cope if a disaster occurs. DRM is defined as, 'the application of disaster risk reduction policies and strategies to prevent new disaster risk, reduce existing disaster risk and manage residual risk' (UNISDR). It is often viewed as having five focal areas: prevention, mitigation, preparedness, response and recovery. These are similar in concept to the functions of social protection of protection, prevention, promotion and transformation. The types of mechanism that are often run by DRM actors but that might be relevant to people working in social protection include:  early warning systems, that give early alerts of potential threats such as droughts or cyclones, or even small variations in weather patterns (these alerts can be used to trigger interventions that can help avert or mitigate the threat);  risk assessments and vulnerability assessments, that can help identify locations and populations likely to be in greatest need of assistance;  contingency plans, that set out what will be done in different types of emergency, and that might include a role for social protection in the planned response;  local disaster response teams that may coordinate the targeting and distribution of support to communities after a shock; and  Disaster risk financing mechanisms that can release funds for emergency measures which might include social protection. ## B2 What Is 'Shock-Responsive Social Protection'? There is no single definition of 'shock-responsive social protection'. All social protection interventions are in some sense shock-responsive, in that they deal ex-ante or *ex-post* with chronic or sudden events that negatively affect households' livelihoods. However, most social protection is designed to support households experiencing shocks as a result of life cycle events such as a loss of jobs, illness or death (*idiosyncratic shocks*). 'Shock-responsive social protection' instead focuses on shocks that affect a large proportion of the population simultaneously (*covariate shocks*). It encompasses the adaptation of routine social protection programmes and systems to cope with changes in context and demand following largescale shocks. This can be *ex-ante* by building shock-responsive systems, plans and partnerships in advance of a shock to better prepare for emergency response; or *ex-post*, to support households once the shock has occurred. In this way, social protection can complement and support other emergency response interventions. See the glossary for details of related terms such as 'adaptive social protection'. ## B3 Options For Using Social Protection To Respond To Shocks There are five main options for adapting social protection programmes to make them better at responding to shocks (Figure 2). These are 1. '**Design tweaks**': making small adjustments to the design of routine social protection interventions. 2. '**Piggybacking**': using elements of an existing social protection programme or system while delivering a separate emergency response. 3. '**Vertical expansion**': temporarily increasing the value or duration of benefits for existing beneficiaries. 4. '**Horizontal expansion**': temporarily increasing the number of recipients in an existing social protection programme. 5. '**Alignment**': aligning social protection and/or humanitarian interventions with one another. Source: OPM. ## Definition Of A 'Design Tweak' The design of social protection programmes and systems can be adjusted in a way that takes into consideration the crises that a country typically faces. These 'design tweaks' can serve one of two purposes. First, they can introduce flexibility into a social protection programme so as to maintain the provision of the regular service for its usual beneficiaries in the event of a shock. This may be particularly relevant in areas prone to rapid-onset disasters such as earthquakes or cyclones, where infrastructure may be damaged, or in areas affected by conflict where access to services may be disrupted. Examples might include developing protocols that allow people to receive a cash transfer over the counter if a usual electronic payment system is no longer functioning, or that waive conditionalities (such as school attendance) if these cannot be fulfilled as a result of the crisis. Second, changes to a programme's design can be introduced that can improve its coverage, timeliness or predictability in the event of a crisis, even without requiring the programme to flex at the moment of the shock itself. This can be explored even when shock-responsiveness is not the primary focus of the intervention. It is a variant on strengthening the core social protection system—which is in any case likely to be of some value in a large-scale crisis, given that social protection is intended to improve households' capacity to deal with the shocks they face. ## Definition Of Piggybacking1 'Piggybacking' occurs when an emergency response, delivered by either government or its partners, uses part of an established social protection system or programme while delivering something new. Exactly which and how many elements of the overall system or programme are borrowed will vary; it could be e.g. a specific programme's beneficiary list, its staff, a national database and/or a particular payment mechanism. This response option has three key features. First, by definition there has to be an existing programme or delivery system to piggyback on, since the idea is to take advantage of something that is already there rather than starting from scratch. Second, policymakers can piggyback on either a programme or its underlying delivery systems (that may support multiple programmes): this distinguishes it from the temporary scale-up of a specific programme (vertical or horizontal expansion—see below). Third, it can be delivered by different actors to the core system or programme, working within their own political mandates and administrative structures. Humanitarian actors can piggyback on government programmes and systems, or vice versa. ## Definition Of Vertical Expansion Social protection programmes can be 'vertically expanded' following a shock: this means the benefit value or duration of the programme is temporarily increased for some or all existing recipients (top-ups) This can be done via an adjustment of transfer amounts or values, or through the introduction of extraordinary payments or transfers. It is unlikely that all programme beneficiaries would have been affected by the disaster in the same way or to the same extent, so these temporary top-ups may be further targeted within the current beneficiary group. In some cases vertical expansion of a programme may look similar to piggybacking on its beneficiary list. The difference is that, with a vertically expanded programme, the extra support is not separate but rather is an integral part of the existing intervention. It is likely to use the same implementers and delivery systems and the same name. Note that the emphasis is on scaling up a specific *programme*, not just borrowing an element of a delivery system. ## Definition Of Horizontal Expansion The 'horizontal expansion' of a social protection programme refers to the temporary inclusion of new beneficiaries from disasteraffected communities. This could be done in three ways: extending the programme's geographical coverage; enrolling additional beneficiaries in geographical areas already covered, who meet the programme's usual criteria (i.e. an extraordinary enrolment campaign) or bringing in additional beneficiaries by modifying the eligibility criteria. In the successful examples that emerged during fieldwork, preparations for horizontal expansion had been factored into the design of the programme rather than being added following a disaster. The ease with which the temporary expansion is done depends partly on whether the extra beneficiaries come from a pool of households pre-selected to be the first recipients in the event of an emergency, or whether they are identified only at the moment of the crisis. ## Definition Of Alignment 'Alignment' means the development of one or more elements of a parallel humanitarian response that align as best as possible with those used in a current or possible future social protection programme or DRM system. For example, this could be an alignment of objectives, targeting method, transfer value or delivery mechanism. This is distinct from piggybacking on elements of a system as it uses a parallel infrastructure rather than the same system. Alignment may arise for two reasons. First, an existing social protection intervention may be replicated because it is not operational as needed in a crisis, e.g. because it operates in geographical areas other than the crisis-affected area, because it is not reaching all the required caseload, or because it has ceased to function as a result of the crisis itself. Second, a relevant social protection intervention may not yet exist, but it is possible to perceive what one might look like. An emergency response that is designed deliberately to align with another (actual or emerging) programme or system may facilitate future integration of the two. This has the potential for increasing impact by contributing to sustainability, and may eventually relieve pressure on the international humanitarian system if alternative funding sources are found. It may also have real-time benefits, such as alleviating concerns about receipt of varying levels or types of support among different groups. ## Opportunities And Constraints Of The Different Options Table 1 below sets out some of the different conditions required for each adaptation to be most effective, and highlights some of the risks and challenges to take into account. Carefully reading through the information in the table should help you to determine whether a particular type of shock-responsive adaptation is feasible and likely to be beneficial in your context. Section E gives selected examples of countries' experiences with implementing or thinking about these options. | Type | Prerequisites | |----------------------------------------|-----------------------------------------| |  | | | | Some social protection | | programme must exist | | | D | | | ESIGN | | | TWEAKS | | | | | |  | | | | Approach can be considered | | anywhere (though what is feasible will | | | vary) | | |  | | | | Resources and capacity | | required depends on | | | nature of the tweak | | | to social | | | protection | | | programmes | | |  | | | | Opportunity to be a gentle introduction | | of shock-responsiveness into | | | programmes and systems | | |  | | | | Data needed to identify | | appropriate design tweak | | |  | | | | Can select strongest components for | | piggybacking without inheriting weak | | | elements or capacity constraints | | |  | | | | No requirement for a | | mature single programme | | | with robust systems, as | | | can pick and choose | | | which elements to use | | |  | | | | May be more politically acceptable | | than some alternatives as the use of a | | | separate system may avoid diluting | | | the 'brand' of a specific programme | | | P | | | IGGYBACKIN | | | G | | | on existing | | | programmes | | | or systems | | |  | | | | Potential for time-savings and | | improved cost-effectiveness | | |  | | | | But need some elements | | of a programme or | | | system to piggyback on | | |  | | | | Works well in situations where | | implementers already have a | | | relationship with a programme | | |  | | | | Potential to be quick and cost- | | effective | | |  | | | | Strong social protection | | programme with good | | | coverage of disaster- | | | affected areas, and of the | | | neediest households. | | | V | | | ERTICAL | | | EXPANSION | | | | | |  | | | | Coverage—existing social protection | | programme may reach a substantial | | | proportion of the disaster-affected | | | caseload | | |  | | | | Understanding of who is | | affected by the shock | | | (top-ups to | | | existing | | | beneficiaries) | | |  | | | | Understanding of | | relevance of top-up | | | support for beneficiaries | | |  | | | | Programme infrastructure already in | | place (provided it withstands the | | | shock and has capacity to absorb | | | extra workload) | | |  | | | | Existing relationships between | | partners | | |  | | | | Adequate administrative | | systems, able to | | | withstand the shock | |  Different shocks may call for different tweaks—need to decide which to prioritise  Ex-ante, so may be hard to get political buy-in  Risk of overloading programmes with concerns unrelated to core objective  Policymakers may face competing demands to adjust programmes to meet other agendas  Design tweaks to enhance shock-responsiveness may close off others that have alternative benefits  Major challenges of working in crisis and conflict contexts may not be resolvable by small adjustments to programme design  Challenge to identify which system components to piggyback on  Systems being piggybacked on risk being overwhelmed.  Weaknesses of the underlying system may be transferred to the emergency programme (timeliness, staff capacity etc.)  If coordination is poor, multiple agencies may decide to piggyback on the same programme  Need to secure agreement of the implementers of the core programme  Piggybacking on programmes can lead to misunderstanding of programme objectives  Increased coordination with multiple organisations and agencies required.  Coordination with other actors implementing emergency responses  Determining the size of the top-up (many different ways could be justified)  Key risk is not reaching significant % of those affected, since non-beneficiaries are not covered.  Additional resource requirements  Risk of duplicating support or missing some individuals as difficult to align with other actors providing complementary responses.  Some features of the social protection programme may be inconvenient for the emergency component (eg. timing of payouts)  Risk of negative impact on people's perceptions of the generosity of the underlying programme  Considerable effort on communication to explain why beneficiaries are getting even more assistance while non-beneficiaries receive nothing | Type | Prerequisites | |------------------------------------------|----------------------------------------| |  | | | | A mature social protection | | programme with strong | | | administrative and | | | delivery systems | | | H | | | ORIZONTAL | | | EXPANSION | | | | | |  | | | | Potential to reach a higher percentage | | of those affected by the disaster than | | | is likely through vertical expansion | | | alone, as the worst affected areas and | | | communities can be specifically | | | targeted | | |  | | | | Potential for more timely response | |  | | | | Accurate data for the | | identification of new | | | beneficiaries when the | | | programme is expanded | | | (temporary | | | extension of | | | social | | | protection | | | programme to | | | new | | | beneficiaries) | | | | | |  | | | | May work well in relation to means- | | tested social protection programmes | | | with on-demand registration during | | | economic shocks, where people fall | | | temporarily within the eligibility | | | threshold | | |  | | | | Temporary additional caseload may | | serve as a foundation for the eventual | | | expansion of the core programme | | |  | | | | Sometimes, | | complementary system | | | components that are only | | | indirectly connected with | | | the core social protection | | | intervention may be | | | needed (eg. teachers and | | | buildings, for a school | | | feeding programme). | | |  | | | | In short term can lead to efficiency | | savings if reduces duplication of | | | delivery systems | | | A | | | LIGNMENT | | | | | | between | | | different | | | programmes | | | or systems | | |  | | | | No prerequisite for strong | | programmes or systems, | | | can be applied in fragile | | | contexts with weak social | | | protection infrastructure | | |  | | | | In longer term, opportunity for a more | | sustainable approach to emergency | | | response, with greater predictability of | | | funding, possibly leading to long-term | | | government ownership and freeing up | | | humanitarian actors from responding | | | to predictable, recurrent crises. | | |  | | | | Opportunity for government to | | upgrade their approaches based on | | | humanitarian innovations. | | Source: OPM. Note: All details are presented in sections 6–10 of the synthesis report.  Difficult to conceive what the benefit should cover and why a non-beneficiary in crisis times should receive the same as a beneficiary gets in non-crisis times  Challenge in deciding who should receive the extra benefit and how they should be selected, including trade-off between prepositioned data and data that more accurately reflects the emergency  If programme extended to people who are not normally eligible, underlying programme's core objectives may be diluted or obscured  Timely inclusion of households can be problematic, especially if not pre-enrolled  Additional resource requirements, including for verifying and enrolling new beneficiaries and extending delivery mechanisms.  May create confusion amongst beneficiaries about objectives and about implementation arrangements, and perhaps undermine the programme's 'brand'  Some features of the social protection programme may be inconvenient for the emergency component (eg. timing of payouts)  Considerable effort required for communication  Difficult to choose which elements to align with  Will need to work with other programmes and organisations, and maintain those relationships over the long-term given that full transition likely to take many years  While alignment between programmes may have positive impact on organisational capacity it risks having less direct impact on beneficiaries, if the support is less tailored to their needs ## B4 When Might Shock-Responsive Social Protection Be Appropriate? Just because it is feasible to adapt a programme, this does not mean that it is necessarily advisable. To determine this, you will need to compare options with other previous and planned emergency responses. If social protection programmes are to be useful for shock response, they need to offer a solution that improves on alternatives. The final step in assessing options for shock responsive social protection is therefore to assess whether and how the identified options will improve on alternative emergency responses in relation to:  Meeting needs: does the intervention deliver an equal or greater impact than its alternatives? Is it better targeted to address needs? Does it provide a more adequate level of support? Does it provide support of a more appropriate nature?  Coverage: Will it lead to more of those in need receiving assistance? Will it reduce the number of those who need support?  Timeliness: Will it lead to quicker support to households? Will it contribute to early response?  Predictability: Will the funding be more predictable? Will it result in more predictable assistance for households?  Duplication: Will it reduce duplication of programme delivery systems and processes? Will it increase coordination between programme implementers? Will it harmonise aspects of programme delivery?  Sustainability: Will it lead to strengthened organisational capacity? Will it be more embedded in government-led systems? Is it more sustainable over the long-term? It is very unlikely that any programme adapted for shock response will be able to improve all six of these dimensions in comparison to alternative emergency response. There is likely to be a tradeoff and you will need to make a subjective decision as to which is the priority and therefore which option or options are ultimately best to take forward. The decision as to what will work better against these six criteria will vary depending on which aspects of efficiency and effectiveness are believed to be the priority. This may be affected by:  the **type of crisis** (eg. whether it is rapid- or slow-onset, which may determine the extent to which the speed of response affects household well-being);  the **regularity and size of the crisis**, which may affect whether it should be treated as a oneoff exceptional event—perhaps requiring the enactment of a contingency plan—or whether governments should plan to integrate a response to the shock into their routine activities;  whether the intervention is taking place in a **conflict context**, and whether the government is a party to the conflict, which may have implications for the alignment with government systems.  the **capacity of agencies**, including access to financing and infrastructure, which may influence whether the use of an existing system will overwhelm it or can be absorbed. Beyond the six factors discussed above, others may also be relevant. Useful frameworks are the Organisation for Economic Cooperation and Development's (OECD's) guidance for evaluating humanitarian assistance, and DFID's '4E's approach for assessing value for money. These are summarised in Table 2 below. ## Oecd Humanitarian Assistance Evaluation Criteria Relevance / appropriateness: Extent to which the intervention is in line with local needs and priorities (as well as donor policy) and is tailored to local needs, increasing ownership, accountability and cost-effectiveness Connectedness: Ensuring that activities of a short-term emergency nature are carried out in a context that takes long-term and interconnected problems into account Coherence: Extent to which policies of different actors are complementary or contradictory— including humanitarian, development, security, trade and military policies Coverage: The need to reach major population groups facing life-threatening risk wherever they are Efficiency: How economically inputs are converted to outputs Effectiveness: Extent to which an activity achieves its purpose, including timeliness and coordination Impact: Longer-term consequences of achieving or not achieving objectives ## Dfid Value For Money Metrics Economy: Purchase Of Inputs Of The Appropriate Quality At The Right Price Efficiency: How well are inputs converted into outputs ("Spending well") Effectiveness: How well are outputs achieving the desired outcomes and ultimately impact. Impact has three distinct elements: the direct impact on the intended beneficiaries; impact on policy design; and impact through the strengthening of organisational capacity ("Spending wisely") Equity: Degree to which benefits are fairly distributed ("Spending fairly") Source: ALNAP (2006) and DFID (2011). ## Section C Diagnosis This section provides you with the analytical tools to assess the context in which you work, so that you can gather information that will later help you make decisions about the suitability of shock-responsive social protection. It offers a set of guiding questions for understanding:  The nature of shocks and crises that are present in your context  The nature of poverty and vulnerability  The institutional environment  The potential contribution of specific programmes  The potential contribution of specific delivery systems  The financial / budgetary context  How to interpret your diagnosis WHY IS THIS SECTION IMPORTANT? Shock-responsive social protection has become a 'hot topic' in development and humanitarian circles. While there are many instances when adaptations to social protection programmes can make a valuable contribution to reducing the impact of shocks and crises, there is a risk that they may be assumed to be a good idea even in contexts where their suitability has not been thoroughly investigated. Policymakers and programme implementers should therefore carefully consider whether social protection is an appropriate mechanism to use in response to a shock, and if so, how social protection can best provide shock response. This section provides you with the analytical tools to gather the information to make that judgment. Having explored these questions it may become apparent that adapting social protection systems to provide shock-response may be appropriate, or may not be the best option for improving responses to shocks. In some contexts, a better starting point may be to consider strengthening routine social protection first. We would emphasise that the diagnosis of the context is best done before a shock occurs. It is a crucial aspect of *preparedness*. The analytical tools mainly capture what exists, and help you to understand why it is this way (enabling factors and bottlenecks). At the time of a crisis this knowledge can then be complemented with a rapid appraisal of the changes in the context provoked by the crisis itself. Working on this analysis before a shock will allow time for other preparations in readiness for the potential shock, such as developing relevant policies and regulations, setting up partnership agreements etc. It also increases awareness of options available: even in a country where the overall social protection system is relatively immature it may be possible to identify one or two programmes that can offer a significant contribution. This understanding, in turn, is likely to facilitate appropriate actions in response to the shock when it arises. Answering these questions will require social protection, humanitarian and DRM actors, policy makers and practitioners, to work together. ## C1 Questions: Shocks And Crises The fact that you are considering shock-responsive social protection means there is a shock (or shocks) that occur in the context where you work, and that you feel could benefit from improvements to the way it is handled. Your first task is to understand the nature of the problem itself. Without this, you cannot determine the most appropriate response. Be clear what type(s) of shock you are aiming to address. You may be considering building on social protection programmes to respond to a single incident or emergency, a frequently occurring or cyclical / seasonal shock, or many different types of shock. Base your analysis on past shocks to better understand what may be expected in the future. 1. What are the characteristics of the shock(s) that you are aiming to address? Think in terms of: - Speed of onset. This might be rapid-onset, such as an earthquake; or slow-onset, such as drought. - Geographical distribution. Are some geographical areas more affected by the shock? - Numbers and proportion of population affected. Are some groups disproportionately affected? 2. What is the frequency and duration of each type of shock? Is it a one-off, short-term shock, or does it have longer-lasting impacts into the medium term, for example an economic downturn? Is it a protracted crisis? Does it occur every year, such as an annual lean season before a harvest? 3. Is this a complex shock, with multiple dimensions (such as a drought in a conflict area)? HELP TO FIND THE ANSWER Besides key informant interviews or workshops to get the perceptions of multiple stakeholders, you may be able to obtain quantitative and qualitative data that is routinely collected and updated on the nature of shocks. This includes historical time-series data on previous shocks, and current risk assessments of the probability of future shocks. FOR THOUGHT The geographical location where a shock initially hits may not be the location most heavily affected by its impacts. For example, a crisis in one part of a country may lead to mass displacement of the population to other parts. Are you aiming to address the shock in its original location, in other affected areas or in both? Some common sources include the EM-DAT database, annual Humanitarian Response Plans, contingency plans, the Famine Early Warning Systems Network data and Reliefweb data. See also Section F. ## C2 Questions: Poverty And Vulnerability Understanding a country's underlying poverty trends and the nature of vulnerability, including how these relate to vulnerability to shocks, is critically important. It can determine the extent to which the people likely to be adversely affected by a shock are also likely to be beneficiaries of one or more social protection programmes: many are intended to reduce poverty—and vulnerability to poverty—but may be aimed at the chronically poor rather than those temporarily affected by a shock. Efforts to understand the factors that affect a household's vulnerability to poverty—that is, the likelihood that a household will become poor (or poorer) in the future—must consider both the household's exposure to risk and its ability to cope with that risk. An assessment of poverty and vulnerability may also give you a sense of the extent to which poverty is dynamic (with some households moving in and out of poverty while others remain in chronic poverty over generations) and vulnerabilities are linked to life-cycle circumstances. 1. What are the latest poverty figures and trends (including disaggregation by geographical area and population subgroup)? 2. What are the demographic / livelihoods characteristics of those most likely to be in, or at risk of, poverty? Think in terms of: - Household characteristics, e.g. household demography (such as number of children), dependency ratios, ownership of assets and access to resources, livelihood strategies households engaging in agricultural activities. - Individual characteristics, e.g. gender, age 3. Who do stakeholders consider to be vulnerable and in most need of assistance? This complementary qualitative assessment may be more nuanced than purely quantitative data, and perceptions may differ across social protection, humanitarian and DRM actors. 4. How does vulnerability to shocks relate to poverty? Do shocks tend to affect areas / subgroups characterised by higher poverty rates? Compare your answers to this section with those in section C1 on shocks and crises. FOR THOUGHT Is it possible to distinguish shock-affected from chronically poor people, and even if so, does this distinction matter? HELP TO FIND THE ANSWER There is likely to be a body of knowledge on poverty and vulnerability in your country, e.g. in national household surveys, though the data may be several years old. Work together with your Statistics Agency! A good external starting point is the World Bank's Microdata library and its Poverty and Equity data portal. For example, if two households have similar levels of well-being—one because it has lost income as a result of a shock, and the other because it is chronically poor—does it make sense to support one and not the other? These types of question can have a big impact on the design of any eventual emergency response programme and on its target caseload. It is also worth taking multi-dimensional poverty indicators into account if available. See for example, the Multidimensional Poverty Index and the Organisation for Economic Cooperation and Development's (OECD's) Social Institutions and Gender Index. ## C3 Questions: The Institutional Environment This section provides questions to understand the organisations and agencies working in DRM, social protection and humanitarian response, their relationships, interests and capacity. It also looks at the laws, regulations and policies that govern them. The mandates of the organisations, the power dynamics and political environment all affect how initiatives do or don't happen. Pay particular attention to governance arrangements, especially the division of responsibilities between national and subnational authorities. ## Mapping Institutions: Roles, Responsibilities, Laws And Policies 1. Thinking about responsibility for the design, implementation and coordination of DRM / emergency response policies: - Who are the actors responsible? What are their different roles (on paper and in practice)? - What are the key national and local plans, laws, regulations and policies that govern their activities (eg. a DRM framework, a humanitarian action policy etc.)? What priorities do these signal for eg. reducing vulnerability to shocks, increasing resilience etc.? - To what extent do national and local governments lead on the various aspects of policy design, implementation and coordination? - Once in place, are laws, regulations and policies being implemented as intended? If not, what is blocking them? - Are there strengths and weaknesses in the current disaster preparedness and emergency response model? What are they? 2. Next consider **social protection** policies and ask the same questions about the actors involved, their roles, the relevant laws, regulations and policies and their implementation, and the involvement of national and local governments. 3. Does—or could—the social protection system offer a solution, institutionally, to any of the shortcomings of the current method for emergency response (such as filling capacity gaps)? 4. Is there a consistent approach to interpreting the nature of crises and how they should be addressed, between the DRM, humanitarian and social protection sectors? Is there scope for greater policy coordination? 5. Is there competition over resources and authority associated with DRM, humanitarian and social protection between line ministries? What are the power dynamics and the key points of contention? FOR THOUGHT There will probably already be a system in your country for responding to disasters. Do you know how it works? This should guide your assessment of whether social protection can offer an alternative or complement. HELP TO FIND THE ANSWER You will find it useful to obtain and review documentation from all three sectors—DRM, social protection and humanitarian response. For example, does the DRM policy or strategy endorse the extension of social protection to new beneficiaries in a crisis? This should be complemented with key informant interviews or qualitative research at both national and subnational level. For example, if disaster response is the remit of district-level authorities, and you are supporting a national-level social protection programme which you think might be useful in a crisis, have you thought how you would engage with the district authorities to see whether they feel it has added value? ## Quick Exercise: How Mature Are The Drm And Social Protection Systems In Your Context? The Maturity Of A Country'S Social Protection And Drm Systems Has Considerable Consequences For Their Ability To Be Effective In A Shock. This Is Not A Fixed State And Will Change Over Time. However, It Is Useful To Start By Considering The Maturity In The Context In Which You Are Working In Order To Plan Approaches That Are Most Likely To Succeed. You may feel that your country does not yet have a coherent social protection system. While it may not have a set of programmes offering seamless support to all people in need across the lifecycle, avoiding gaps and duplication, and articulated in a well-funded strategy, it will have some kind of assistance in place, even if delivered *ad-hoc* by non-state actors. You can assess this assistance to determine how useful it would be to support response to a shock, relative to alternative emergency responses. As a rapid exercise, take a moment to consider the maturity of the social protection system in your context. The table below sets out a typology of system maturity: ## | Category of maturity | |-----------------------------------------------------------------------| | 1 | | Non-existent | | No state interest in developing long-term social protection, and | | only ad-hoc humanitarian interventions by development partners | | 2 | | Internationally led | | No clear progress in state policy, but emerging interventions by | | development partners shaping up to a system with elements of | | harmonisation or coordination between state and its partners | | 3 | | State-led interest | | Some state interest to expand social protection to the vulnerable, | | including elements such as the outline of what could become a | | national programme | | 4 | | State-led commitment | | Commitment to expand social protection articulated in e.g. a | | strategy, with some flagship initiatives for the poor (co-)funded by | | the state | | 5 | | State-led expanding | | Clear state policies and a growing set of social protection | | programmes | | 6 | | State-led mature | | Well established system with high coverage of populations and | | needs, strong state role in delivery, capacity building and financing | Source: OPM (2015). You can do a similar exercise to consider the maturity of the DRM system. You may decide that the maturity of a system is better assessed on a programme-by-programme basis rather than at a system-wide level. For example, perhaps the government is highly committed to expanding public works programmes, but not at all interested in cash transfers. Or perhaps the overarching social protection system is non-existent, but a donor is funding a sophisticated programme that is expected to be in place for the long term. Bearing this in mind, and comparing it with other contexts, may help you decide whether a scheme that you see elsewhere might also be transferable to your own context, and what you might need to address to improve its probability of being effective. For instance, an initiative that might work well in Kenya might not be sustainable in a country with a less mature social protection system, though elements might be transferable. ## Mapping Institutions: Relationships, Partnerships And Coalitions 1. Thinking about **political economy**: what are the interests and levels of power / influence of the stakeholders—at local, national and international level—in reforming the current system for emergency response and in considering closer links with social protection? How has this affected the design and implementation of shock-responsive policies until now? 2. Is there a **window of opportunity for reform**, if reform is needed, such as through the presence of a sector 'champion' in government, the support of a particular political party, or the drafting of relevant legislation? 3. What is the **degree of decentralisation** in the provision and financing of, and authority over, social protection, humanitarian response and DRM? What implications does this have in practice? Is there competition and/or different levels of prioritisation of these sectors at different levels of government? 4. How, and how well, do **development partners** work with the government, **private sector** and communities on humanitarian assistance and social protection provision? How has previous support in response to shocks been perceived? Do agencies have competing visions / objectives? 5. What **scale and size of private sector or community participation** is involved in designing and implementing social protection and humanitarian interventions, and in contributing to policy debates about future reforms? 6. How do different stakeholders organise themselves in terms of coordination and partnerships? How well have they previously coordinated and collaborated amongst themselves in the event of shocks? ## C4 Questions: The Potential Contribution Of Specific Programmes An important first step in assessing the appropriateness and feasibility of shock-responsive social protection in a given context is to review the design and implementation of existing DRM and humanitarian responses. These can be compared with social protection programmes, and how they have been or might be adapted to respond to shocks, to see how well they offer an appropriate alternative or complement. ## Mapping Recent Drm And Humanitarian Response Programmes 1. What DRM and humanitarian response interventions have been implemented recently to address large-scale crises? These might be by local or national government, or international actors, or both. Consider interventions that provide support to households or individuals. 2. Thinking of each of these programmes in turn, what have been their key design features? You can use the list of features presented in Table 3 below to think through these. 3. How did these recent responses perform with respect to meeting people's needs at the time? What worked well, and what are the shortcomings? Were they harmonised and coordinated? What evaluations have been conducted and what are their findings? You can use the dimensions of economy, efficiency, effectiveness and equity outlined in section B4 to make this assessment. Also use any available monitoring / evaluation reports. ## Mapping Social Protection Programmes 1. What social protection interventions are in place? These might be implemented by local or national government, or international actors, or both. Use the typology of social protection interventions in Section B1 *to help compile the list. It may include:* - social assistance (e.g. cash and in-kind transfers, public works, fee waivers, subsidies) - social care services (e.g. support from social workers) - social insurance (e.g. contributory schemes to insure against unemployment, disability etc.) 2. Thinking of each programme in turn, what are their key design and implementation features? How resilient are these to a crisis? *Use the list in Table 3 to help you think through these.* FOR THOUGHT The principle of shock-responsive social protection is to consider whether social protection programmes can improve on the emergency response provided by other mechanisms, and if so, how. HELP TO FIND THE ANSWER If the social protection sector is well established it may have an annual sector review process coordinated across the government and its agencies, which may generate analytical reports. This is why it is important not just to think in isolation about the value of the social protection programmes, but to compare them with the DRM and humanitarian / emergency responses that already exist. Without this it is difficult to know whether the use of the system would represent an improvement. Programmes are likely to have their own design documents and progress reports, and perhaps also an independent M&E process. Further resources include: the Social Assistance in Developing Countries Database, the World Bank Atlas of Social Protection, the ILO World Social Protection Report data and the Inter- Agency Social Protection Assessment tools. | Design feature | |-------------------------------------------------------------------------------------| | Objectives | | What is the programme trying to achieve? | | Target group | | and coverage | | Who is eligible for the programme and how is this decided? How often does | | selection of beneficiaries take place? How are they registered? How often do | | people leave the programme? What is the overall coverage? To what extent are | | those targeted by the programme likely to overlap with those who are most | | vulnerable to shocks? | | Nature of | | support | | What does the programme provide (e.g. cash or in-kind transfer, livelihood | | support, psychosocial support)? What is the frequency and duration of support? If | | it is a transfer, what is the value? | | Delivery | | system | | How is the support delivered (for example, if a cash transfer, how does money | | reach the beneficiary—through direct bank transfer, mobile phone payment, over | | the counter of a post office, manual distribution by programme staff etc.)? | | Capacity and | | resources | | How is the programme staffed? Does it use government employees, external | | contractors or independent organisations? How many staff are there, how are they | | distributed, and what is the potential for recruiting more if needed, on a long- or | | short-term basis? What other resources does the programme have (e.g. local | | offices, vehicles), and what is the potential for increasing these resources? | | What are the mechanisms for communicating with beneficiaries and for handling | | updates and appeals and complaints? | | Case | | management | | M&E | | How is the programme monitored and evaluated? What are its key indicators of | | success? | | Does the programme already link up to other complementary initiatives, e.g. health | | / education / agriculture programmes? How could these be leveraged? | | Links to other | | programmes | Note: These questions focus on the descriptive mapping of existing social protection programmes. The discussion of what might be needed from these programme elements in order to improve responses to shocks is the focus of section D. Questions on programme financing are also relevant, and are presented in section C6 below. Similar questions could be adapted to analyse existing DRM and humanitarian programmes. 3. How are these programmes judged to have performed with respect to meeting the needs of their target population? What are the strengths and weaknesses of the programmes? What evaluations have been conducted and what are their findings? 4. What flexibility is there in the programme's existing design and operations to increase its caseload / change the level of support to its beneficiaries / share its delivery systems with other interventions in the event of an emergency? What prospects might there be to introduce this flexibility? 5. Have any of the programmes already been used flexibly in an emergency, and if so how? Have any of them undergone adjustments in their design to make their beneficiaries better prepared for an emergency or more resilient to crises? What was the experience of this? ## C5 Questions: The Potential Contribution Of Specific Delivery Systems The DRM, humanitarian and social protection sectors also contain elements that are not exclusive to any single programme, but that contribute to the functioning of multiple programmes or to coordinating and harmonising the sector as a whole. Examples are processes for contingency planning, early warning and market analysis, vulnerability assessments, and databases such as the 'social registries' that are becoming popular. What is the role that these might play? ## Mapping Systems Used In Drm / Humanitarian Interventions 1. What are the current methods by which the organisations mandated to deliver DRM / humanitarian response carry out the following functions? - Risk and vulnerability assessments - Early warning systems - Contingency planning - Coordination of emergency response - Keeping track of beneficiaries reached by different interventions - Market assessments - Monitoring and evaluating the performance of an overall emergency response 2. How well do these systems and processes perform with respect to meeting people's needs at the time? What worked well, and what are the shortcomings? Use the dimensions of economy, efficiency, effectiveness and equity outlined in section B4 *to make this assessment.* ## Mapping Systems Used In Social Protection Interventions 1. What systems and processes exist in the social protection sector that serve, or might serve, a similar function to those cited above in relation to DRM / humanitarian interventions? For example, what information systems and related databases are in place? What tools are used for contingency planning or early warning? 2. Thinking of each of these elements, to what extent do they improve on, or offer an alternative to, the systems already in place for DRM / humanitarian response? Use the dimensions of economy, efficiency, effectiveness and equity outlined in section B4 *to make this assessment.* ## FOR THOUGHT Humanitarian systems may be set up so as to maximise the possibility that implementers can meet the humanitarian principles of humanity, impartiality, neutrality and independence. HELP TO FIND THE ANSWER You may find that there are no single common systems for undertaking these processes in your context. Sometimes groups of NGOs may work together to try to develop a harmonised system for these processes, which may or may not be connected to the government's own system(s). Think how this manifests itself in the current design of systems for emergency response (eg. are some systems intentionally kept separately from the government? Who leads the processes?). How would this be affected if a social protection system was used instead? A great resource to learn more about tools used by humanitarian actors when delivering cash transfers is CaLP's Learning Hub, searchable Library and tools sections. ## C6 Questions: The Financial / Budgetary Context The way emergency responses are currently funded should be understood and assessed, in order to be able to make a comparison of funding through different mechanisms. An important element of whether a social protection system can be more responsive to shocks relates to how it is financed, to what extent, and the scope for allocating additional funds towards it for a response to shocks. Consider also the potential challenges of any transition from one system of funding to the other. Thinking of the DRM, humanitarian and social protection sectors in turn, assess the following: 1. What has been the value of national and local government funding to the sector in recent years (e.g. the last three), and what are the projections for the next three years? 2. To what extent is this funding from domestic or external (international) sources? What are the different sources? How, and from whom, are externally sourced funds raised? Looking across the sectors as a whole: 1. What are the overall prospects for the macro-economy in the years ahead? 2. How are national and local government budgets determined and allocated annually? 3. What are the prospects for increasing funding towards disaster risk reduction / preventive activities, rather than *post-hoc* response to disasters? 4. Is there a space for funding shock-response through other sectors, such as education, health or agriculture? 5. Does the government have a contingency fund that it can draw on in emergencies? Does it contain any funds? How is it replenished? For what can it be used, and how is it triggered? 6. Are other risk financing mechanisms being implemented or considered? How do they work? 7. What has been the size of estimated funding requirements in recent emergencies? How much was received and spent? 8. Is there a shift towards multiyear funding of humanitarian assistance? To what extent is this resolving any funding constraints? 9. Are there any implications for future sustainability of funding, if interventions that are currently deemed 'humanitarian assistance' were moved to a social protection programme? ## Help To Find The Answer Some of this information may be available in national budget documents, if public. Other relevant documentary sources may include medium-term expenditure frameworks, public expenditure reviews, IMF Article IV reports and humanitarian response plans. FOR THOUGHT There is often a large discrepancy between planned and actual expenditure across these sectors. Consider how implementation constraints are likely to affect the availability of funds for a response (lengthy procurement or approval processes, lack of procedures governing the top-up of contingency funds etc.) Government documents do not always contain information about development partner spending, which may be either 'on-budget' or 'off-budget'. You may need to collect additional information from individual agencies. ## C7 How To Interpret Your Diagnosis As we noted in section A2, the answers to these questions do not lead automatically through a flowchart to a prescribed solution. Here we suggest how you might handle your results, and point you to other parts of the toolkit that may help you reach your conclusion. The primary issue to remember while asking these questions is, of course… Why are you asking them? What is the policy challenge that you are aiming to resolve? It is not enough to look at a social protection programme or system in isolation and decide whether it could be made more shock-responsive. Instead you should look at a set of alternative policy options and select the most appropriate one. This may be a move towards shock-responsive social protection, or it may not. Here is a three-step process to help you interpret your diagnosis: ## Step 1. Understand The Problem Reviewing your answers in relation to all three sectors, consider where the main bottlenecks lie in reducing and addressing households' vulnerability to shocks. Are they mainly challenges of policy design, or of implementation? Is the problem mostly one of a lack of planning and preparedness— such as an absence of rigorous contingency planning or of protocols and agreements with service providers—or do policymakers clearly see the problem but lack the resources to address it? How much are these bottlenecks symptomatic of the state of maturity of the sectors (see section C3 above), and to what extent is it likely that they can be overcome in the short or medium term? ## Step 2. Assess The Options Once you have collected information about the current DRM / humanitarian programmes and systems and their benefits and challenges, and the same for social protection, you should compare answers between the two. Does the use of a social protection system resolve some issues inherent in the current system for reducing and addressing vulnerability to shocks? What new challenges will it create? What will be lost (for example, will a social protection intervention be able to adhere to the humanitarian principles)? Is this an acceptable trade-off? Could these challenges be resolved equally well (or even better) by simply improving the DRM / humanitarian systems? ## Step 3. Consider Unintended Consequences Looking beyond the current status of the social protection programmes you have reviewed, consider also whether there are any risks in using them that may undermine the effectiveness of the underlying programme or divert it from its core objectives (e.g. by introducing new beneficiaries whose circumstances do not match those of the intended target of the core programme). The task of assessing the options refers not just to whether it is appropriate to use social protection systems at all for shock response, but considering which programmes could best be adapted and in which ways. For this, the typology of options listed in Figure 1 will be relevant. You can assess the feasibility of tweaking the design of each, if any could move to greater alignment, if any elements would be suitable for piggybacking, and whether there is scope for vertical or horizontal expansion - or a combination, including alongside parallel (and aligned) humanitarian responses. The Table 1 in section B provides a detailed reflection on the prerequisites and the relative merits and risks of each of these options, which will play out differently according to the scenario and context. This information is based on what we know from the country case studies and literature review, yet there is still a lot to learn. For example:  If you do not have a strong social protection programme or underlying social protection system, and you do not expect it to be able to take on the delivery of interventions that are currently provided by humanitarian actors, you might wish to start by simply strengthening the routine social protection intervention; and perhaps introducing **design tweaks** to improve its use in a shock. For this you would need to have data that permits an understanding of priority needs to ensure effective design adjustments. You might also encourage **alignment** of interventions among different actors, including the government, which may help a move towards an eventual strong social protection programme.  If you do not have a comprehensive system or a highly relevant social protection programme that reaches the right target households, but you do have strong programme systems such as good data or strong delivery mechanisms, you might consider **piggybacking** on elements of the system.  If you have a programme with good coverage of the geographical areas affected by the disaster, and the beneficiaries of which closely match at least some of the affected group, and you have good data and robust administrative and delivery systems—you may wish to consider vertical expansion of the programme. A good assessment of needs is also required to understand whether it is useful for beneficiaries to receive more of what they already get.  If you have a programme with robust, accurate data for the identification of new beneficiaries when the programme is expanded and strong administrative and delivery systems that can cope with scale-up and preparation in advance, and if the inclusion of new beneficiaries will not be detrimental to the existing programme or its beneficiaries, consider **horizontal expansion**. If there is no spare capacity to scale out then 'surge capacity' will need to be available and will require institutional coordination, for example by bringing in staff from other geographical areas or other programmes.  Also consider adapting **several programmes at once**: each should be considered on its own merits, but it will be important to think about the interplay. Different types of response may be relevant at different points in time (e.g. early response versus longer-term recovery). ## Section D Factors Guiding A Response This section highlights key points you may wish to take into account in the design of any shock-responsive social protection intervention. Drawing on the main components of a social assistance programme, it covers:  Finance—Exploring whether and how the intervention might be funded  Targeting—Considering who the intervention is designed to reach  Data management—The merits and challenges of using ready-made databases  Transfer values—Determining how much support to provide  Payment / distribution mechanisms—How the support will reach the target recipients  Coordination—Linking all relevant actors  Communication—Discussing the intervention with communities  M&E—Measuring whether the intervention is having its intended effect ## WHY IS THIS SECTION IMPORTANT? Interventions that aim to support households in an emergency are generally designed on the basis of a fairly consistent set of questions about the processes and systems needed to achieve impact. While the *questions* remain fairly similar for all interventions, the *answers* will be vastly different depending on the context. Broadly, the questions cover: Who needs assistance? What support do they need? What and how much can we provide, and how do we get it to those that need it? How will they know about it? How will we keep track of what we're doing, whether it works, and what others are doing? In technical terms this translates into decisions about targeting, delivery mechanisms, communication, data management, M&E and so forth. The same questions apply to the delivery of long-term social protection assistance, though again with a range of answers. This similarity in the set of processes and systems is one of the things that has led to the present debate about whether and how social protection systems can complement or substitute for other emergency response mechanisms. The critical difference is that programme objectives, and the underlying assumptions about what is considered best practice, can vary hugely between programmes that are perceived as 'humanitarian' and those considered as 'development' interventions or part of routine service delivery. For example, in setting the value of a cash or in-kind transfer, a 'humanitarian' response might aim to meet the full consumption needs of a household, while a social protection response might have an objective of contributing enough to meet, say, 25% of the need. This section therefore highlights some of the key issues to consider, and likely points of contention, in the design and delivery of the different elements of a shock-responsive social protection intervention, from the perspective of humanitarian and DRM as well as social protection implementers. A fuller examination of all these issues is provided in the synthesis report for this research. ## D1 Finance Using the answers to the diagnostic questions in section C6, you should have an understanding of the fiscal space for shock-response, including the current channels through which they are disbursed, and you will be aware of whether government and external funding is likely to be available to sustain extensions or adaptations to long-term government-led social protection programmes. The two factors that will then assist you in determining your choice of funding option are, first, your anticipation of potential funding requirements; and second, your assessment of the challenges and opportunities of the alternative sources of finance. ## Anticipating Potential Funding Requirements Effective programming requires robust processes for anticipating the size of funding needed. Before you can secure timely and predictable financing for shock-responsive social protection, it is important to establish or strengthen systems for needs analysis and funding requirements. This might be a regular process involving government, humanitarian and development partners, such as Mali's annual National Response Plan for Food Security. Information on likely need could be presented in a plan with funding sources agreed and detailed. The process will be different for slow- and rapid-onset crises. For both, reliable early warning data will be advantageous - this was not often the case in our case study countries. ## Assessing Alternative Sources And Channels Of Finance Struggles to obtain sufficient funding to respond to emergencies, and to disburse it in a timely manner, have been one of the main impetus for consideration of shock-responsive social protection programming. If you work for a humanitarian agency that has been responding to a protracted crisis over a number of years, the fact that humanitarian funding is often guaranteed for only one year at a time may have been a source of concern. The integration of a response into a long-term social protection programme or system may look like a way of resolving the short-term funding problem. However, you must consider the following:  Would the switch to funding a response through a social protection programme entail channelling funds through government systems? Do the requirements of the current funder (if not the government) permit this; and if not, can other funders be found, or will the government itself take on the expenditure?  A switch to disbursement through a government budget may increase national ownership and perhaps improve the sustainability of the overall system. However, governments face considerable demands on their resources, and may meet constraints in their ability to release funds quickly. **Administrative delays** in releasing emergency funds can have a serious impact on the effectiveness of the response. How can any delays and/or cuts be minimised? The answer depends also on the disbursement mechanism for the specific programme that is used in the response to the crisis (eg. whether it can release payments on an ad-hoc basis or only quarterly. See also section D5 below).  A difficulty with some funding arrangements is that the amount of money needed can vary hugely from one year to the next. Some mechanisms require unspent money to be returned at the end of a financial year, and this may also have an impact on the size of the budget proposed for subsequent years. How will this scenario be avoided? To help address these challenges, important **disaster risk financing principles** to consider, irrespective of whether emergency response is through shock-responsive social protection or other channels, are:  Financing should be in place before the event of a crisis, so that it can be rapidly mobilised and disbursed when needed, and  Effective disaster risk financing strategies include multiple financial instruments. Mobilising sufficient finance to meet the level of funding required is often challenging. Layers of risk financing including budgetary instruments, contingent financing, market-based instruments, topped up by humanitarian appeals where required, will be necessary (e.g. see World Bank and Asian Development Bank, 2017). Selected options that governments can consider for rapid financing include:  Contingency funds: Funds that can be called upon in an emergency must be accompanied by the clear allocation of responsibility for ensuring that they are adequately resourced and for disbursing their contents in a time-sensitive manner. In some countries, contingency funds are set up but ultimately remain empty. If used for shock-responsive social protection, such funds may require additional financing so that the essential response activities that were originally expected to be funded through these mechanisms can still go ahead.  Contingent credit lines: The release of emergency credit can provide immediate liquidity to countries in the aftermath of a disaster, though this has the drawback of adding to debt. World Bank Catastrophe Deferred Drawdown Options (Cat DDOs) for example, can be accessed by pre-selected countries upon declaration of a state of emergency. Essentially, the Cat DDO serves as bridge financing while funds from other sources (e.g. aid, reconstruction loans or concessional funding) are mobilised.  Disaster insurance: Insurance is one way in which governments can smooth the cost of responding to disasters and reduce reliance on emergency appeals. Insurance payouts can be linked directly to social protection programmes - for example, governments joining the African Risk Capacity (ARC) have to develop a contingency plan showing how they will use the money if they receive a payout following a drought. However, insurance mechanisms are designed to respond to exceptional events, not annual food insecurity, meaning that while they may be one part of a portfolio of funding mechanisms for use in a crisis, they cannot be the only one. Ultimately, it is widely agreed that it is more cost-effective to spend money on averting disasters and building resilience than to wait for a crisis and then respond2. ## HELP TO FIND THE ANSWER For a more comprehensive overview of ex-ante versus ex-post disaster risk finance instruments, as well as learning more about how to estimate funding gaps, you can read the World Bank and ADB 'Guidance Note on Conducting a Disaster Risk Finance Diagnostic'. Other useful tools include: the BOOST databases, which facilitates user-friendly access to budget data in about 40 countries as of mid-2016 and Climate Public Expenditure and Institutional Reviews (CPEIRs). ## D2 Targeting A core principle of an effective shock-response is to be clear about who needs assistance and what support they require. This means making good use of vulnerability assessments and needs assessments. Authorities responsible for emergency response have processes for deciding where to go and whom to support. An important question, then, is whether the social protection sector can contribute an effective alternative or complement to these processes from its experience with supporting chronically poor or vulnerable households; and what the advantages and challenges might be in different contexts. Many tools exist for conducting vulnerability assessments and needs assessments3. These range from annual vulnerability assessments, conducted independently of any specific emergency, to needs assessments conducted in the immediate aftermath of a rapid-onset crisis such as an earthquake. In many of our case study countries, annual vulnerability assessments are conducted jointly by government agencies and development and humanitarian partners in relation to slowonset food security crises, to determine the severity of food insecurity by geographical area, and to estimate roughly how many households need assistance in each area. Besides generating information on the nature of support required, these assessments can be used to assist *targeting* of an emergency response. Targeting typically requires agreement on two factors: (1) The identification of priority geographical areas for support (perhaps with the exception of a generalised economic shock, where a response may be countrywide) (2) The identification of specific households or individuals for support in those areas. A wide variety of approaches are used by humanitarian and DRM actors to do this in emergency contexts, many involving some form of rapid assessment (e.g. to establish extent of 'damage') and community-based targeting. Social protection programmes may be able to make a relevant contribution to reaching an agreement on these factors from two perspectives. First, they may have a useful *method* for identifying needy areas, households and individuals - depending on the underlying policy decisions on eligibility criteria for specific programmes. Programmes may select households through methods ranging from defining eligible categories, e.g. people of certain age groups or people with a disability ('categorical targeting') to consultation with communities about who they believe to be the most vulnerable ('community-based targeting'), to collecting socio-economic data to estimate how poor the household is (poverty targeting, e.g. through means testing or 'proxy means testing', PMT), or a combination. Some types of programmes implicitly define their target group, based on their operations: some public works programmes use self-targeting of those willing to accept the set wage, while universal school feeding programmes target all of those who are in school. Second, they may hold useful *data* generated from the processes of registration (e.g. on all potentially eligible individuals/households) and subsequent enrolment (e.g. on beneficiary individuals/households) for specific programmes (see D3). To decide whether a social protection programme can make either of these contributions, consider the following: 1. **What are the objectives of your emergency response**: what kind of needs are you trying to meet, for whom, and what impact do you wish to have? What targeting method is likely to maximise the impact achieved? 2. What targeting approach is acceptable and appropriate, both politically and for communities? It is important to be sensitive to the cultural norms of communities in relation to the sharing and distribution of assistance. Other factors that might determine the political acceptability of a targeting method include its transparency, its accountability to the recipient population, and the costs to households of participating. Conflict must also be factored in. 3. **What targeting approach is appropriate for the type of shock, and stage of the response** (initial stage versus recovery stage)? For example, for longer-term protracted crises more precision may be needed, while for short-term response a blanket approach may be more appropriate (e.g. allowing for 'inclusion errors'). 4. **What is affordable**, in terms of the method for targeting and also the scale of support that can be accommodated? 5. **What approach will guarantee a timely response**, especially for rapid-onset disasters? 6. **What targeting method is practical** from the point of view of not overburdening the administrative capacity? Compare the answers to these questions for standalone emergency response targeting processes, with emergency response delivered using social protection targeting mechanisms used. Also consider combinations of different approaches. By viewing these answers from the lens of what counts as an 'efficient, effective and equitable ' intervention (see section B4 for the criteria— timeliness, sustainability and so forth) you can determine which is most suitable in your context. The way that you plan to use any existing social protection programme for shock response, of course, has implications for how its targeting method has an impact on your own programme. More specifically:  If you decide to **vertically expand** an existing social protection programme, i.e. to give top-ups to existing beneficiaries, then by definition you are relying on the *same targeting method* and the *same list of beneficiaries* as the underlying programme (though potentially only in disasteraffected geographical areas, and potentially only to a sub-set of the list of beneficiaries).  If you decide to **horizontally expand** an existing social protection programme, i.e. extend it to new recipients, then you may be relying on elements of the *same targeting method* (e.g registration data) but selecting a *different list of beneficiaries*. You will need to select the criteria by which you will extend the programme. This might entail, for example: - enrolling individuals or households who meet the current eligibility criteria, in the event that there has been under-coverage (e.g. owing to budgetary constraints); or - enrolling individuals or households who meet the current eligibility criteria but who live in areas not yet covered by the programme (and who might eventually be incorporated into the core programme); or - enrolling those who fall outside the current eligibility criteria, such as those whose incomes are above a poverty cut-off, or whose age falls outside the range for an intervention targeted categorically by age. This could include enrolling entirely new categories of beneficiaries.  If you decide to **piggyback on an existing beneficiary list** then you will have at least some of the same beneficiaries as the underlying programme. You may use different eligibility criteria to select the subset of them for the emergency support (e.g. restricted geographical area).  Alternatively you may piggyback on a wider list of *potential* **beneficiaries** (e.g. of households that were registered and stored in Social Registries but never enrolled on a programme), but may choose to have an entirely different set of eligibility criteria. See section D3 on data management for more on this.  If you propose to **align** your emergency intervention with a prospective or immature social protection intervention then you may need to choose a targeting method that is suitable for the longer term intervention even if it is not the one that you would prefer for an emergency response. Consider the risks of potential negative impact on the outcome of your programme in this scenario, if you are not reaching the households you would ideally wish to reach.  It may also be possible to **tweak the design** of the underlying social protection programme so that the households and individuals who are supported by the core programme are more likely to be those at highest risk of vulnerability to shocks. In some cases, this will include applying 'waivers' to standard programme rules, such as the enforcement of conditionalities. ## D3 Data Management Governments and implementing agencies are increasingly exploring whether databases that have been compiled for one primary objective—such as storing data about beneficiaries of a social assistance programme—can also be used in response to a crisis. The usability of these databases is closely associated with the way that beneficiaries of the original programme have been registered and targeted. We highlight five issues that you should consider when reviewing a database to consider its value in shock response: data relevance, completeness, data currency, accessibility and accuracy. Social protection programmes that are targeted at specific households or individuals usually store information about them on a database. Information about other people—potential future recipients, or households who have been assessed but deemed ineligible—is also collected, but not always stored and maintained. The distinction between these two types of database—beneficiary databases and databases containing information on a wider group of potential beneficiaries (known as social registries)—is crucial. These existing databases - and their wider information systems - have the potential (subject to the challenges below) to improve the efficiency of emergency response by reducing duplication of data by multiple agencies; improving timeliness of identification of individuals for assistance (leading to timely support if acted on promptly), increasing coverage, and ensuring more predictable support for the household (provided they know the circumstances when they will receive it). Existing data could also promote better understanding of households' vulnerability, providing inputs for better planning, and could reduce costs of data collection and management, though evidence on this is scarce. Whether or not this improves programme impact will depend on the database's ability to identify the neediest people in any given shock, compared with alternative data collection arrangements delivering separate interventions. We note three possibilities (Figure 3). In scenarios a. and b. we do not assume that the existing database *should* be used for targeting: it depends on whether they are an improvement on the alternative targeting methods used by humanitarian and DRM actors (see also below). a. Households that can be reached through **vertical expansion** (or piggybacking on the beneficiary database) b. Households that can be easily reached through horizontal expansion (or piggybacking on the social registry) c. Households **less easily** reached through **horizontal expansion** or piggybacking (not covered by existing social protection databases) Source: OPM. Notes (1) The size of each oval will depend on each country's circumstances. (2) The 'National population' oval represents 100% of the population. (3) To keep the figure simple, the red oval exemplifies one programme (e.g. the country's flagship programme with highest coverage), yet most countries have several programme databases, sometimes partly overlapping. Databases of contributory programmes are not included here (by research design), but also offer potential. a) Do disaster-affected households closely match those on the beneficiary list of a social protection programme? If they do, households may be reached through vertical expansion (top-up) of regular support or by piggybacking on the beneficiary list. Table 4 lists three key options for this. | Option | |------------------------------------------------------------------------------------| | This can be pragmatic and improve timeliness in severe shocks where most | | households are likely to have been affected. This was used by the Department | | of Social Welfare and Development and WFP in the Philippines after Typhoon | | Haiyan. It will likely lead to inclusion and exclusion errors* by design. | | Target | | all | | | | beneficiaries | | within the | | selected | | geographical | | area | | Target | | some | | | | beneficiaries | | For less severe crises, or where there is variation in impact, you may wish to | | take the list as a start from which household vulnerability is verified. This will | | likely lead to exclusion errors by design*. | | Target | | no | | beneficiaries | | In some cases beneficiary households have been de-prioritised on the grounds | | that they already receive some help (e.g. during the response to the El Niño | | drought in Mozambique in 2016). This may result from a lack of clear directive | | to agencies as to what to do with the list, leading to discretionary and | | inconsistent decisions (see the Mozambique case study). It will likely lead to | | exclusion errors by design*. | Source: OPM, 2018, Barca and O'Brien (2017). *Unless complementary efforts are made to reach other affected households. b) Are disaster-affected households not beneficiaries of a specific programme, but their data is in a database of potential beneficiaries e.g. a social registry? If it is, explore the feasibility of extending the programme horizontally to new beneficiaries already in the registry, or piggybacking on the registry and delivering a separate programme. Table 5 discussed options for this. | Option | |---------------------------------------------------------------------------| | This presupposes that households worst affected by a disaster can be | | identified from existing variables, e.g. their wealth ranking; their | | geolocation (if GPS coordinates are collected and can be overlaid with | | hazard vulnerability maps); or the characteristics of a household member. | | Use variables in the | | social registry to select | | households | If the criteria, and the circumstances in which they would be used, are planned in advance, such an approach would effectively pre-identify a cohort of households for assistance, enabling immediate targeting in a disaster. Pre-enrolment (e.g. collecting operationally relevant data at registration stage) might also be possible as part of preparedness planning, and might enable a timely response in the manner of 'no regrets'. In this event further screening would be applied post-disaster in order to identify which households have been worst affected. The use of the database as a starting point might enable a more rapid validation process than collecting all information from scratch. Use the records as a starting point to obtain a list of households, but do not target directly from the data c) Are disaster-affected households not covered by social protection* databases? Horizontal expansion of a programme to reach these households will be harder as no information exists. Assess the usefulness of other databases (e.g. national ID) and explore potential efficiency gains of linking to the underlying information systems, infrastructure and capacity offered by existing social protection databases Of course, it is quite likely that the households affected by a shock fall across all of these categories. Moreover, the categories are not necessarily this clear-cut as each country runs a wide variety of social assistance programmes, each with their own approach to data management and varying levels of integration across programmes. Policymakers must decide what approach is most cost-effective given their context, including whether to use separate ways of reaching groups a, b and c, or whether to deliver a single response that reaches a, b and c at once. However you use the data, gaps in coverage and quality mean complementary methods must be used to identify other households in need. Since no targeting mechanism is perfect, errors deriving from either design or poor implementation will lead to errors of inclusion and exclusion in social protection programmes—such that some of those enrolled are not the poorest, whilst some poor households are excluded. You will have to ensure that those excluded from a programme, or a registry, are not systematically excluded from the shock response. ## What You Can Do In Advance Of A Shock Implementing an effective shock response based on social protection data will require careful planning. In particular, you could develop guidelines on:  How to better use data for planning purposes as well as targeting;  The types of crisis these databases and different targeting systems will be used in. For example, in the Philippines, typhoons, El Niño events and earthquakes could lead to the prioritisation of different geographical areas and population groups;  Who can engage in shock response and how those managing social registries will coordinate with social protection institutions, DRM and humanitarian actors;  How to use the systems so as to avoid social protection beneficiaries either receiving multiple benefits from different actors, or being excluded; and  Options for building secure (and respectful of data privacy) two-way information-sharing between social protection and humanitarian actors, to help maintain data currency and ensure timely response. ## Five Dimensions By Which To Assess If A Database Is Useful4 There are five key dimensions of social protection data (and related information systems) that enhance or limit their potential use in emergencies: Data relevance; Completeness (coverage); Data currency; Accessibility; Accuracy. Table 6 explains what you need to consider for each of these. | Dimension | What to look out for when considering their use in a crisis | |----------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------| |  | | | Are the indicators that determine eligibility of households for routine social protection programmes suited for identifying households | | | vulnerable to disasters? Note this will vary depending on the underlying approach to targeting, partly as different programmes have | | | different data requirements. For example universal social pension requires less information than a poverty-targeted grant, while self- | | | targeted programmes such as public works can require even less. | | |  | | | Does the database contain any data on climatic vulnerability? Information on dietary diversity (etc) change too quickly to be of use except | | | Relevance: | | | does it contain | | | the right | | | variables? | | | | | | at the moment of collection - these will always need to be collected at the time of the shock. | | |  | | | Is data on non-beneficiaries adequately stored and maintained? If so, does it include operationally relevant information: recipient details, | | | full address, GIS reference, contact number, bank account number, biometric data, etc? | | |  | | | What percentage of population is covered within existing databases, nationally and in affected areas? A database will be best placed to | | | assist an emergency response if a large proportion of those in need are included. Of course, this can also be achieved via several | | | databases. | | | o | | | | Do beneficiary databases only cover a subset of the population in any given area (e.g. the 'poor', older people, children, etc.)? Who? | | Are they also targeted geographically? How? | | | o | | | | Is there a social registry serving several social protection programmes? Who is excluded from it and why? | | Completeness: | | | Does it contain | | | data on all | | | people / | | | households in | | | the affected | | | area or in | | | need? | | | | | | o | | | | What other databases created for uses other than non-contributory social protection are available—including, potentially, a country's | | contributory social protection databases, national ID database or its civil registry? | | |  | | | To what extent do the data reflect households' circumstances at the required point in time? It is impossible for standard social protection | | | data to reflect reality after a disaster, meaning some post-disaster revalidation is always required. | | |  | | | How out of date is the data and why? E.g. Data collection: mass 'census survey' every few years or continual on demand registration by | | | individuals or households? Who updates the information and how are updates shared? Note: Beneficiary databases tend to be more up to | | | date than databases containing potential beneficiaries, as beneficiary data is used and updated on an ongoing basis. | | | Data currency: | | | Is the | | | information up | | | to date? | | | | | |  | | | To what extent is household well-being affected by the shock? For example, conflict and many natural shocks may cause widespread | | | internal displacement, split up households and significantly change their material circumstances. | | |  | | | Who are the users (e.g. national government versus decentralised government versus non-government agencies) and what protocols and | | | authorisation levels are in place for data sharing with each of them? | | |  | | | Is data maintained and stored digitally? What type of data interface (e.g. web service) is used for sharing data? | | |  | | | What capacity and infrastructure is there in terms of (i) human resources to use the database (ii) availability of computers (iii) availability of | | | electricity and network connection? | | | Accessibility: | | | Can the | | | information be | | | accessed by | | | the people who | | | need it? | | |  | | | What provisions are there for data security and privacy? | | |  | | | Is the data free of mistakes and omissions (to the extent possible)? This affects the confidence that can be placed in the data, its wider | | | Accuracy: | | | Is it | | | free of errors? | | | | | | credibility and ultimately its usability. Perceived accuracy also depends on where data is housed and who has oversight over its quality. | | Source: Source: OPM, 2018 and Barca and O'Brien (2017). *In this table, the term 'social protection' refers to non-contributory social protection. ## D4 Transfer Values Humanitarian interventions aim to ensure that those affected by crises receive assistance that meets their needs. The increasing frequency and severity of crises, and shortfalls in funding, necessitate inevitable trade-offs between scale and value—supporting all those in need with less, or providing adequate assistance to fewer people. The value of humanitarian assistance is increasingly debated as aid becomes monetised—households are increasingly likely to receive emergency relief in cash rather than being given food or other goods—and through use of multisectoral grants, which enable them to spend the cash on whatever they feel is most appropriate (which might be eg. education, health or shelter, besides food). This is highlighting the need for strong coordination and harmonisation of transfer values across the response, and an awareness of the different objectives of different schemes which can justify variations in amounts provided. It can be challenging to harmonise transfer values between interventions delivered through national social protection programmes and systems, and those implemented separately by humanitarian actors. For example, with a focus on cash assistance:  If you decide to **vertically expand** an existing social protection programme, i.e. to give top-ups to existing beneficiaries, you must decide whether either the top-up alone, or the total value including the original support should reflect what other households are being provided through separate emergency interventions.  If you decide to **horizontally expand** an existing social protection programme, i.e. extend it to new recipients, then the rationale underpinning the choice of a transfer value should be clear.  If you decide to **piggyback** on a component of a programme (e.g. by paying into bank accounts or adding a new benefit onto a payment card launched by a different intervention), but you deliver assistance of some other value, you need to be sure that households are absolutely clear why the value is different to what they or others might be receiving under the core intervention. The following should be considered when setting a transfer value for emergency assistance delivered through a social assistance programme: 1. How to maintain the value of the routine social protection transfer in the event of a shock? This will be particularly the case for cash transfers, if there is a shock that affects prices (food, fuel, other). Tools for market analysis adopted by humanitarian actors may prove useful for this (see e.g. Table 15). 2. **What humanitarian needs form the basis of the calculation?** Agencies must first define which needs a response aims to meet: food security, other basic needs, rent, livelihoods recovery etc. Transfers in the form of food will mainly help meet food security needs (if the recipient consumes rather than sells it) whereas cash can potentially meet a range of needs. The sequencing of needs, and the value and frequency of transfers, will vary. Findings from the Philippines and Pakistan suggest that, in a rapid-onset disaster such as an earthquake or cyclone, it may be quicker and easier to manage a response that focuses on basic food and non-food needs that are best supported by regular, recurrent transfers that can be easily standardised—certainly in the early response phase. More specific needs could be factored in during a recovery phase, though this adds a layer of complexity to programme administration since transfer values will vary over time and between households. 3. How will the transfer value be calculated, and what trade-offs may be needed? If the emergency assistance is intended to fulfil humanitarian objectives for a portion of the caseload then transfer values must be based on a calculation of humanitarian needs. However, there are trade-offs. The first is between scale and value, driven by funding limitations—whether to meet some needs of many affected households, or the full needs of fewer. A further trade-off, more likely on a programme linking to national social protection, is between securing adequate value and securing political support. In Lesotho, there was some political resistance to temporarily topping up the Child Grant Programme owing to concerns about its impact on popular support for the transfer value of the core programme. Considering transfer values as part of preparedness planning where possible is important, so that values can easily be computed post-disaster. It is also important to pay the same attention to the ability of the market to absorb additional cash assistance when delivered through a social protection programme as one would if it was a separate emergency response. 4. **How to coordinate with other humanitarian interventions?** It is recognised good practice to harmonise transfer values and agree standards for humanitarian assistance across agencies. Therefore it is important that humanitarian transfers delivered through social protection systems are aligned with those delivered through parallel interventions - or at least that the rationale for the choice of any given transfer level is clearly stated and widely shared. In both the Philippines and Lesotho, variations in transfer values between standalone humanitarian responses and the top-ups to social protection beneficiaries risked confusion and disappointment. The development of common transfer guidelines for government and aid agencies in Philippines and Lesotho subsequently supported greater harmonisation. If going through a social protection system means lowering the support people receive compared with what they would have received under a standalone response, there is a danger of compromising the appropriateness of the support. 5. What is the scope for varying the transfer value delivered through national systems, particularly in an emergency context? Transfer values that are more closely aligned with a household's real needs—which vary, for example, according to the size of the household, location, or phase of the response—will be more effective. However, this adds a layer of complexity to programme administration (communication and delivery). Actors must consider whether the national systems have capacity to deal with these complexities effectively, in a timely fashion. If not, then a standard transfer value to allow delivery at scale and speed may be more useful. These decisions will form part of a 'response analysis', alongside other activities such as a market assessment. ## D5 Payment / Distribution Modality Social assistance may entail the provision of cash, vouchers or in-kind assistance to households, among other instruments. These require a delivery system for getting them to their intended beneficiaries. The system may vary from staff travelling to communities distributing physical cash or goods, to payment service providers such as post offices disbursing cash over the counter, to electronic mechanisms such as transfers by mobile phone or directly into bank accounts. Each combination of instrument (e.g. cash / voucher), disbursement device (e.g. phone, ATM), service provider (e.g. post office, bank, shop) and contracting arrangement (in-house or contracted out) has implications for its appropriateness, accessibility, robustness, degree of integration and cost, even in noncrisis times, and more so when there is disruption due to a disaster. Think about your proposed payment / distribution modality in relation to the crisis scenarios in your context. Conflict and rapid-onset natural catastrophes can disrupt systems, damage infrastructure and displace people and businesses. A slow-onset crisis such as a drought may cause less damage to infrastructure but may affect population movements. What will happen to your existing payment modalities in those contexts, and how can you mitigate the impact? There are three key issues: 1. How can you best maintain the delivery of the *routine* social protection intervention in the event of a shock? 2. How can you make sure that any emergency *assistanc*e channelled through the same system neither compounds the burden on the routine intervention, nor suffers the same disruption? 3. If emergency assistance is delivered through a different system, will this create any unacceptable differences between the support offered to routine social protection and emergency beneficiaries? The Inter-Agency Social Protection Assessment (ISPA) tool on 'What matters' in social protection payment delivery mechanisms provides a comprehensive framework for analysing these issues. Using that framework, we recommend that you consider the impact of a crisis across the three main dimensions it identifies, together with a fourth focusing on cost:  accessibility: for payment beneficiaries;  robustness: designing and implementing a payment mechanism that can be depended on to reliably deliver transfers on a regular basis to the correct recipient;  integration: the extent to which the program is taking advantage of economies of scale by coordinating across the sector. This includes integrating the beneficiary into the financial system (financial inclusion) and, for policy makers, ensuring ease of payment across a variety of programs seeking to deliver cash transfers;  cost (and cost efficiency) of delivery: direct costs of the payment mechanism and effectiveness in achieving intended outcomes. In Table 7 and Box 1 we provide you with some questions and observations to think through. Considerations for delivery mechanisms in a crisis context Element Maintaining routine service delivery Incorporating emergency response Accessibility  Will the crisis increase distance that beneficiaries must travel to the nearest distribution point (e.g. if some distributors close down)? Cost of access  Does this have financial implications for the beneficiary (e.g. transport)?  Is the technology appropriate in a crisis? For example, if it relies on the use of a phone network, what will happen if the network is disrupted? Appropriateness  Is there flexibility as to when and how beneficiaries can collect their assistance, and how much they can collect? Rights / dignity  Is the crisis likely to cause the exclusion of existing beneficiaries? For example, will people with disabilities still be able to reach the distribution point? What will happen if people lose their ID cards or programme cards (e.g. on account of losing their home, or displacement)?  How is the predictability of the disbursement date and  If the same service provider is used for emergency response (either through piggybacking on the mechanism, or through horizontal expansion of the routine programme), will this increase congestion at the service provider, e.g. through longer queues?  If existing beneficiaries are given top-ups, will they incur any additional charges in accessing support (e.g. by exceeding thresholds for number of free withdrawals)?  If implementers piggyback or horizontally expand on the delivery system to provide new support for households who haven't previously received it, will they be familiar with any technology?  Will new beneficiaries receive training on how to access their support?  Is any emergency response likely to place too much strain on the delivery mechanism, e.g. causing liquidity problems (payment providers running out of cash)?  Similarly to the maintenance of routine service delivery (see left): Who might be excluded by the use of the distribution mechanism?  If humanitarian assistance is delivered through a different system to the routine social protection, is this likely to cause any stigmatisation or exclusion of one group or the other?  If vertically or horizontally expanding, or piggybacking on an existing payment modality, what is the payment frequency? Is this appropriate in a crisis context (e.g. does it require beneficiaries to wait three months for the next disbursement, and is this problematic)?  Can the payment frequency be adjusted, e.g. through extra payments outside the usual schedule? What needs to be in place to do this?  Electronic payment channels may have the potential to vary the frequency of transfers according to changing needs. However, they are primarily an advantage only in schemes where beneficiaries tend to store and use the money electronically; if beneficiaries prefer to withdraw it in cash then the usual requirements for liquidity still apply. Governance  Are there clear procedures and policies that include contingency planning for maintenance of service delivery in a crisis?  Is there an increased risk that recipients will not receive the full amount due, or greater risk of theft, in a crisis context? How can this be mitigated? Security  Is there flexibility in authentication arrangements (e.g. waiving of ID card requirements—see 'Rights / dignity')? ## Integration Financial inclusion  If the routine programme has financial inclusion objectives, e.g. by channelling recipients' support through regular bank accounts, is this likely to have any adverse consequences in the event of a crisis? How can this be mitigated?  If the payment provider is already used by multiple programmes, are there any implications for one intervention if another intervention faces disruption? Coordination  Training or guidance for programme staff and any payment providers on recovering operations following disasters will better ensure continuity ## Cost-Efficiency Source: OPM, based on ISPA  Are there clear procedures for introducing variations to the delivery system (e.g. through protocols with payment providers to provide support to additional beneficiaries or different payment schedules)?  Is there a risk that service providers will be distracted from the routine social protection intervention while handling the emergency? How can this be mitigated?  If more staff are required (e.g. for manual distribution of assistance), how will this be funded and obtained (surge capacity)?  Are certain payment providers more secure than others in terms of maintaining privacy of the personal data of recipients of emergency support (especially in a conflict situation)?  Is a crisis an appropriate time to be introducing payment modalities that promote financial inclusion, or are other modalities more suitable?  Does the service provider wish to be contracted for emergency as well as routine support?  Are they likely to increase the commission charged for cash transfers on account of the extra inconvenience of an increased caseload (as was the case for money transfer agents in Somalia during the 2011-12 crisis)?  Some payment mechanisms have high set-up costs (especially electronic systems). Does the duration of the response justify their use, if they are set up specifically for the crisis?  Others typically have high running costs (e.g. manual distribution of cash). How does the duration and geographical spread of the response affect these costs? ## Box 1 Example: Adapting The Payment Modality After A Typhoon In The Philippines In the Philippines, the payment of the Pantawid cash transfer to households was disrupted by Typhoon Haiyan in 2013. Adjustments were made to restore the functioning of the routine intervention. Pantawid's delivery systems were also used to provide emergency top-ups (vertical expansion) to several thousand households. The implications for the delivery system were as follows: | Element | Maintaining routine service delivery | |------------------------------------------------------------------|------------------------------------------------------------------| | | | | Incorporating emergency response | | | | | | Appropriateness | | |  | | | | Power outages prevented the use of e-payment channels for | | several weeks. Households who usually received payments | | | electronically were allowed to collect them over the counter | | | instead while awaiting a replacement cash card (which took up to | | | several months, despite quick revalidation efforts) | | |  | | | | Three mobile ATMs were introduced to help disburse cash card | | payments, although this was delayed so only partially effective | | | Reliability | | | | | | Governance | | |  | | | | Government drafted in staff from non-affected regions to help | | social welfare officers conduct a rapid validation exercise, | | | locating beneficiaries and cross-checking answers to questions | | | against the beneficiary roster, then issuing temporary ID cards | | |  | | | | Many Pantawid beneficiaries lost their ID and ATM cards | | Security | | |  | | | | The Central Bank relaxed national financial regulations, such as | | 'know-your- customer' requirements, acknowledging that many | | | households had lost their identity cards | | Source: Smith *et al*. (2017)  Rather than waiting for the next bi-monthly payment, the top-ups were issued separately  Additional commission was agreed with payment providers to deliver the extra rounds of transfer  Obtaining additional physical cash was a challenge in remote areas  Cash top-ups to beneficiaries added to the workload of service providers.  The unexpected increase in the number of payments (monthly rather than bi- monthly transfers) strained capacity, in some cases leading to missed routine payment dates.  Overall, lack of clarity on financial reporting procedures (e.g. from government to supporting organisations) ## D6 Coordination In many countries, collaboration between the social protection, DRM and humanitarian sectors is limited which creates challenges for the effective implementation of shockresponsive social protection. To improve coordination, attention needs to be paid to (i) improving understanding of one another's fields; (ii) strengthening engagement between the sectors in both policy and practice; and (iii) strengthening coordination between programmes and between delivery systems. DRM programmes and delivery systems are particularly underutilised and can offer potential for improved effectiveness in relation to shock-responsiveness. ## Key Areas For Strengthening Coordination Although social protection, humanitarian and DRM actors are increasingly working together, coordination can be challenging. For shock-responsive social protection, the ideal scenario is that a coordinated social protection sector feeds into a disaster management platform that coordinates a response. However, in many countries this does not happen, in part because of challenges arising from the multi-sectoral nature of the sectors and differing levels of maturity. Coordination and collaboration needs to be strengthened in three key ways: 1. Improve *understanding* of one another's fields. 2. Strengthen engagement between *sectors*—in policy and practice. 3. Strengthen coordination between *programmes* and between *delivery systems*. ## 1. Improve Understanding Of One Another'S Fields Definitions of and principles underlying 'social protection', 'DRM' and 'humanitarian' work are often not widely understood between the three sectors. In fact, both social protection and DRM have long been conceived of in similar cycles, revealing multiple entry-points for joint thinking and working. As shown in Figure 4 below, both sectors aim to prevent shocks, reduce negative impacts if a shock occurs, support affected households and communities, and invest in measures that lessen the impact of any future shocks. ## Ideas Of How To Improve In This Area:  Undertake targeted initiatives to train stakeholders in the basic principles of social protection, humanitarian work and DRM.  Promote national and sub-national reflection on broader institutional links with social protection through the full DRM cycle (prevention, mitigation, preparedness, response and recovery). ## 2. Strengthening Engagement Between Sectors When thinking about how to strengthen coordination across the different sectors, you have to plan and act at different levels. Coordination is needed at the national level, between sectors, but also within and between their representatives at subnational and community levels. This coordination can either be at an institutional level (i.e. policies and governance arrangements) or an organisational level (e.g. activities). ## Coordination At An Institutional Level A starting point for improved institutional coordination is to improve coherence within each sector individually. The more each sector is aligned within itself, the easier cross-sector collaboration becomes. This is particularly challenging for social protection and DRM as they both have a wideranging scope and funding and are sometimes spread across many different ministries. ## Ideas Of How To Improve In This Area:  Work to improve individual sectoral coherence, for example through national and sub-national strategies that other actors can align behind  Pay attention to intersectoral policy coherence: joint policies, strategies and/or frameworks that clearly set out the synergies and overlaps between the sectors and are developed together. ## Coordination At An Organisational Level Organisational coordination needs to be deliberately planned and built within and across sectors. Without formal coordination, there is a risk of policy agendas and programmes overlapping with or competing with each other. The presence and effectiveness of coordination bodies for strategic oversight and information exchange differs dramatically between countries. Examples of coordination structures include:  Forums for data collection and analysis  Technical working groups on specific themes (e.g. shock-responsive social protection)  Cash working groups to coordinate cash assistance in emergencies  Disaster response groups  Alliances for advocacy and policy coordination  Temporary committees  Periodic conferences ## Ideas Of How To Improve In This Area:  Consider creating and activating some of the forums and structures listed above to facilitate information exchange and strategic coordination. More than one type is likely to be necessary, but beware of overlap and meeting fatigue.  Ensure these groups have wide membership drawn from multiple sectors, agencies and government ministries / departments. Consider rotating the chair position between organisations.  Strengthen Cash Working Groups in contexts where cash is becoming a significant feature of both long term social protection and emergency response. This could include joint planning exercises, shared lessons on design and implementation features and joint capacity building. ## 3. Strengthen Coordination Between Programmes And Systems Shock-responsive social protection will only ever be a partial solution for responding to emergencies, and so many separate emergency interventions will need to be effectively coordinated to avoid duplication. Agreement will be required on many different design and implementation details. There is an opportunity to streamline processes, for example for enrolling households, distributing support or communicating why there are differences. Section D8 also sets out the importance of coordinating M&E approaches between different programmes in a particular country, in order to measure them consistently and inform future decisions on effectiveness. Some stakeholders engaging in shock-responsive social protection become preoccupied with avoiding duplication of specific households included in emergency and routine social protection responses. This is not really an issue and social protection programme beneficiaries should not automatically be deliberately excluded from emergency response programmes as a) the value of humanitarian assistance can be significantly higher than the value of regular social assistance transfers; b) households affected by shocks may have lost other sources of food and income, in which case they will have additional needs as a result of the shock. In most countries, the DRM sector is not well coordinated with the social protection and humanitarian sectors. This often results in missed opportunities. The DRM sector often has numerous delivery systems and programmes that could be utilised to support the social protection and / or humanitarian sectors to improve shock-responsiveness. Some examples are included in the table below. Some relate specifically to DRM engagement with shock-responsive social protection programmes and some to social protection more broadly; collaboration between the sectors is likely to lead to a more conducive environment for shock-responsiveness. ## Opportunities For Collaboration Between Drm And Social Protection Element of DRM cycle Typical DRM programmes and systems Opportunities for collaboration with social protection Programmes to reduce vulnerability to disasters Given that reducing poverty and vulnerability is both an underlying driver of disaster resilience and a focus of social protection efforts, there is great potential for collaboration and mutual learning. 'DRM mainstreaming' efforts DRM mainstreaming efforts—linking in with development plans, cross-sectoral strategies, committees, forums etc. at all levels—provide an opportunity for social protection and DRM staff to work together mitigation Community-based prevention programmes 'Cash plus' programmes may contribute to disaster prevention and mitigation through the additional elements, e.g. by distributing drought-resilient seeds or training on flood-mitigating farming techniques. Prevention and Resettlement or adaptive livelihoods programmes Political economy analysis would be necessary to fully understand how social protection could contribute to incentivising change and what obstacles exist Disaster risk financing mechanisms Mechanisms such as contingency funds and sovereign risk insurance schemes could be linked to social protection interventions DRR contingency plans Could incorporate any expected expansion of social protection programmes following a shock. We found several examples of joint working between DRM and social protection on this Early warning systems and criteria for levels of alert These systems should trigger action before an emergency to reduce losses. Data can be used to achieve consensus on the approach and/or extent of a crisis, and trigger finance for social protection response Preparedness Vulnerability, risk and hazard assessments Assessments can be used not just to design responses, but to shape the targeting of social protection programmes to make them more shock-responsive (design tweaks). Public information systems Awareness-raising mechanisms and emergency communication systems, including disaster warning alert apps on mobile phones, could explain to beneficiaries their entitlements under expanded social protection programmes Provision of cash and in-kind emergency transfers Shared modalities, programmes and systems. This was the area of greatest collaboration between the sectors across the case studies, although shared approaches did not guarantee coordination in many places Response Post-disaster needs / damage / loss assessments Post-disaster assessments may be useful for targeting social protection programmes, depending on the speed with which they can be conducted and the content Reconstruction programmes ('build back better' approach) In theory, public works programmes could be used for reconstruction activities such as rebuilding infrastructure. However, this requires technical expertise, machinery, skills and resources that are generally not present Recovery Post-disaster rebuilding of livelihoods Many ways in which these programmes could be linked to social protection, e.g. through in-kind transfers linked to livelihood development e.g. tool distribution DRM committees at regional, local and community levels DRM committees may be able to play an important role in supporting planning, targeting and the implementation of social protection initiatives. General Institutional and organisational framework The DRM institutional framework—laws, policies, codes etc.—could formally incorporate attention to social protection. There should be opportunities to bring social protection and DRM professionals together. Source: O'Brien et al. (2018). ## D7 Communication Strong communication with communities is important when humanitarian assistance is delivered through national social protection programmes, and particularly when there are multiple delivery channels. Adaptations to routine social protection programmes and humanitarian assistance provided using social protection channels may not be well understood by communities which can create frustration, feelings of inequity and misinformation which can ultimately result in individuals not knowing whether they are eligible for support and can affect trust. If social protection systems and programmes are used for shock-response, you must take considerable care to ensure the following points are communicated effectively to both beneficiaries and non-beneficiaries: 1. **Decisions on targeting:** Who is included and excluded, and why. Will existing beneficiaries receive extra support? 2. **Explanations of the type and value of the support:** What it is based on, why this differs from the type and value of social protection in normal times, or other parallel humanitarian assistance, or both. 3. **Duration of support.** For how long households will receive support, if additional assistance is temporarily provided, and how the exit process will work. 4. **How to request further information, complain or query any decisions:** Grievance mechanisms are an important part of enabling two-way communication within shock-responsive social protection, particularly where personal data are used for targeting. Having an effective grievance redress system can reduce errors and improve understanding of the intervention. Misunderstandings around these key points can have further reaching, long term and political ramifications. Any dissatisfaction with the emergency response may be directed not only towards its implementers but also towards the incumbent government, if they are not delivering. Social protection programmes are understood by citizens to be reaching particular groups of people, with particular amounts (if programme communication has been successful). Providing additional payments to beneficiaries (or to some beneficiaries), or including households who do not fit the targeting criteria, without clear explanation may create tensions or undermine public support for the long term programme. If you are an implementer of a social protection intervention or humanitarian assistance for households, you can consider using the communication routes available via the DRM architecture when engaging in shock-response, beyond those that you regularly use. These might include, for example:  SMS / texting, social media and mobile phone apps  DRM city / village committees, forums and response teams  DRM information networks  DRM training sessions, simulations, workshops  Traditional media—radio, emergency broadcasts ## D8 M&E Good monitoring and evaluation of shock-responsive social protection can be made through the careful selection of appropriate and robust indicators, with consideration of harmonising indicators across interventions and sectors (social protection, DRM and humanitarian). This section sets out some principles for developing and selecting appropriate indicators to measure the performance of shock-responsive *programmes* as well as indicators to measure progress in developing shock-responsive *systems*. ## Problems With Current Approaches Monitoring frameworks suffer from similar problems:  an over-emphasis on *inputs* and *outputs*, with less attention paid to *outcomes* and *impact*  poor quality data  lack of coherence or shared indicators across actors, programmes and sectors5. Most importantly, there are no established indicators that are consistently applied to measure the efficiency and effectiveness of using social protection to respond to shocks, nor standard indicators consistently applied to DRM and humanitarian response. It is therefore very difficult to compare emergency support delivered through separate humanitarian or DRM responses with support delivered through social protection programmes and systems. ## Improving Indicators For Shock-Responsive Social Protection For routine monitoring, social protection programmes typically collect data on inputs and outputs (e.g. measuring the resources needed to implement the programmes, and its immediate outputs). This information tends to be the easiest to collect and measure, and more frequently available. However, it is also important to collect information on outcomes and impacts in order to ensure that the programme is meeting its agreed objectives. Programmes will benefit most from having agreed indicators across the different stages outlined in Table 9 below. In attempting to measure the performance of social protection systems in responding to shocks, you can consider four different categories, covering measurement of processes and systems, outcomes and impacts: 1. Indicators focused on the activities and effectiveness of the routine social protection programme in building household resilience by reducing vulnerability to shocks (for example through continued protection of household income or preventing households from falling further into poverty as a result of a shock). 2. Indicators focused on measuring a routine social protection programmes' ability to withstand shocks and continue operations in the context of a crisis. 3. Indicators focused on the **effects of the shock-responsive component**. This might be e.g. the flexible use of social protection to enable households to secure their needs when a shock occurs. These indicators can be used to measure and compare emergency responses through social protection programmes and systems, and traditional emergency response. 4. Indicators focused on **coordination, integration and / or harmonisation** of social protection, humanitarian and DRM actors and interventions to better prepare for, respond to and facilitate recovery from shocks. | Indicator type | Explanation | |--------------------------------------------------------------------------------------|-----------------------------------------------------------------------| | Input | | | The financial, human, material, administrative and regulatory resources used by the | | | programme | | | The activities that turn inputs into outputs. For shock-responsive social protection | | | these are likely to relate to: | | | Process | | |  | | | | Developing system components / policies / legislation (e.g. registry | | databases, targeting mechanisms, payment systems) | | |  | | | | Planning and preparedness (e.g. contingency plans and funds in place) | |  | | | | Creation of partnerships and coordination | | The outputs delivered by a programme. For shock-responsive social protection | | | these are likely to relate to e.g.: | | | Output | | |  | | | | The number of beneficiaries receiving assistance | |  | | | | The timeliness (speed) of the response | | The direct benefits of the programme or short-term changes as a result of the | | | programme. For shock-responsive social protection these are likely to relate to: | | |  | | | | Programme coverage | | Outcome | | |  | | | | Targeting effectiveness and equity | |  | | | | | | The effectiveness and adequacy of benefits in improving beneficiaries' | | | circumstances | | | Impact | | | Broad changes to wellbeing, vulnerability or resilience. This is usually assessed as | | | part of an independent evaluation rather than as part of routine monitoring. | | Source: authors. Note that the timeframe for using different indicators will vary. E.g., input indicators can be considered at the beginning of the response whereas impact indicators will be considered once a response is underway. Existing guidance for measuring the achievements of social protection, DRM and humanitarian response programmes may be of use here, if tailored to the context of shock-responsive social protection. These include DFID's guidance notes on measuring value for money in social transfers, in social protection systems, in humanitarian programming and cash transfers in emergencies, and the OECD-DAC criteria for evaluating development programmes and humanitarian assistance. Some examples of topics that might be covered by potential indicators are presented in Table 10. Indicator type Monitoring how routine social protection copes in a shock Monitoring the shock-responsive component Coordination  Costs, time and human resource inputs  Costs, time and human resource inputs to the Input to the routine programme shock-responsive component  % of funding that is multi-year  Contingency funding agreed and in place  No. of quality plans and procedures in place for shock-responsive component  Completion of activities related to building  Plans completed for continuing Process operations in the event of a shock capacity of delivery infrastructure to absorb increased workload (e.g. no. of payment service providers able to make additional payments)  Development of social registry  Key operational systems developed for accessing and using contingency funds and insurance payouts  No. of programmes operating in areas at  No. of disaster-affected people reached with risk of shock additional support  No. of beneficiaries continuing to be  No. of households / individuals receiving support Output supported throughout shock within x days / weeks (after a specified date)  Amount and regularity of transfers  % of clients receiving additional support within x delivered throughout shock days  % of beneficiary households reporting  Indicators as for recipients of routine social improved livelihoods, reduced negative coping strategies, improved consumption protection (see left), but relating to those receiving support because of the shock Outcome  Evidence of improvement in comparison to  Levels of self-reported food insecurity  Assessment of whether households are emergency response e.g. (% increase in coverage, cost saved, days saved, increase in transfer value etc.). better able to meet daily needs, impact on savings  Evidence of poverty reduction amongst  Evidence of improved dietary diversity and child Impact nutrition amongst beneficiaries, value of household assets maintained beneficiaries, livelihood diversification, improved savings and value of household assets Source: Authors. Note: These are not specific indicators (which would need to be specific, measurable, timebound etc.) but rather themes that might be covered.  Costs, time and human resource inputs coming from other sectors / ministries  Integration of social protection in disaster insurance payout plans  Links developed with early warning systems  Examples of data sharing on vulnerability  Signed memorandums of understanding and action plans in place between different actors  Examples of shared systems and operations  Money saved through shared systems or economies of scale (e.g. through eliminating duplication of data collection)  Evidence that systems for improved working across sectors have been institutionalised (e.g. joint strategies developed and routinely implemented) ## Considerations When Choosing Indicators Indicators should be chosen that are context-specific and that are suitable given the existing data availability and monitoring activities. Indicators should relate to the overall objectives of the programme, or differentiate between the routine programme and the shock-responsive element. In situations where a long-term programme is being scaled up, or a system is being piggybacked on, it makes sense to integrate the systems and processes for monitoring the shock-responsive element with the M&E of the long-term programme if possible, while making sure that the two elements can be distinguished in the data. There are numerous guidelines to support the development of measurable indicators including RACER: Relevant, Acceptable, Credible, Easy and Robust (EC, 2012); SMART: Specific, Measurable, Achievable, Realistic and Time-limited; and CREAM: Clear, Relevant, Economic, Adequate and Monitorable (McCord et al., 2017). Some of the indicators currently used by scaled up social protection programmes are not very measurable, for example "use of adequate targeting system to identify the right beneficiaries" or a "a system for scaling up". It is much better to specify a timeframe, number, percentage or completion of a particular milestone. Whilst it is not possible that all programmes can use exactly the same indicators, ideally actors responding to the same shocks in a particular country would harmonise their frameworks and use comparative indicators as much as possible. If the social protection and humanitarian sectors in a country can start to use comparable indicators then it will become much easier to identify whether and how shock-responsive social protection has been able to improve on other emergency responses. Box 2 provides considerations when selecting indicators to be used for measuring the performance of shock-responsive social protection. ## Box 2 Considerations When Selecting Social Protection Indicators A checklist of key questions to be considered in relation to the type of indicators to select are:  How many indicators are desirable for a policy or programme (taking into consideration the size of the programme)?  What types of indicators are already used or omitted and are necessary for appraising performance (input, output, outcome, impact)?  What is the rationale behind using the existing indicators?  Do these indicators collect an appropriate range of preparedness and shock response outcomes and impacts?  What indicators can be used to assess the quantity of response provided?  What indicators can be used to measure the quality of response?  What types of benchmarks are used to measure the quantity and quality of preparedness and shock response (both processes and provision) (e.g. objective, time-based, comparative national or international)?  Are composite indicators used and if so are the results useful or meaningful for appraising performance?  Do indicators create perverse monitoring incentives?  Are targets disaggregated by, for example, sex, disability, geography? Source: adapted from McCord et al., 2017 ## Section E Experience This section provides a reference to selected recent examples of cases where shockresponsive social protection has been considered and/or put into practice. This toolkit is mainly based on research carried out in the following countries and regions, alongside a global literature review (Smith *et al*, 2017): Source: OPM (2017). We also draw on OPM's recent case studies (of shock-responsive social protection in Latin America and the Caribbean (Ecuador, Guatemala, Dominican Republic, Haiti, Peru and El Salvador), undertaken on behalf of WFP (see project here and Section F for details). ## E1 Design Tweaks In Practice Example Of A Design Tweak: Cash Transfers In The Philippines Following Typhoon Haiyan Source: Smith *et al.* (2017) Changes to the regulatory environment can enhance shock-responsive social protection, particularly when they are made before the shock occurs. Before Typhoon Haiyan, earlier in 2013, the Department for Social Welfare and Development (DSWD) in the Philippines had passed a resolution that if a state of calamity was declared, household conditions on cash transfer programmes would be waived for three months. This change meant that Pantawid transfers automatically became unconditional following Typhoon Haiyan, at the same time that DSWD and WFP began their discussions on delivering an emergency cash transfer through Pantawid. This made it easier to plan an unconditional top-up and vertically expand the programme. Similarly, in the wake of the typhoon, the Central Bank relaxed its national financial regulations related to 'know-your-customer' requirements, in acknowledgement that many households had lost their identity cards. This contributed to the conducive environment for implementing emergency cash assistance. ## Example Of A Design Tweak: School Feeding Programme In Mali Source: O'Brien *et al.* (2018) In Mali the government has tailored the roll-out of its school meals programme to prioritise the most food-insecure areas. The Ministry of Education's long-term objective is to provide free meals for pupils in all schools, but as it does not yet have the capacity to do so, it reaches 20% of primary schools for now (others are supported by WFP). The government has geographically targeted its programme so as to prioritise the 166 communes considered most vulnerable to food insecurity. Within the targeted zones, priority is given to schools with low enrolment and retention rates, especially of girls. Although shock-responsiveness is not the primary objective of the programme, by prioritising these areas - and by prioritising girls, whom some evidence shows to have higher vulnerability to disasters compared to boys - it is more relevant in the event of a shock. ## An Opportunity For A Design Tweak: Mozambique'S Cash Transfer Programme Source: Kardan *et al*. (2017) In Mozambique, where the social protection programmes are relatively under-resourced and the overall system is relatively immature (although some programmes have been established for a long time), our research team identified an opportunity to tweak the design of the cash transfer programme, the Basic Social Subsidy Programme (PSSB). The PSSB routinely suffers from disbursement delays in the first quarter of each new financial year in January. Unfortunately, that also coincides with the period of greatest risk of climatic shocks such as cyclones and floods. A simple design tweak could be made to the payment plan, such as a double payment in December in place of a payment in January or February: this would ensure that households were covered at the time of increased vulnerability, and would be fiscally cost neutral if the aggregate amount paid across the year remained the same. In addition, as the programme continues its expansion in line with the objectives of the national social protection strategy, it could consider prioritising geographical areas and populations most vulnerable to particular shocks, as in the Mali school meals example above. ## A Challenge In Adjusting Programme Design: Lesotho'S Socioeconomic Database Source: Kardan *et al*. (2017) Lesotho is reforming (overhauling rather than tweaking) its large database, known as NISSA, which records the socioeconomic characteristics of poor households in some areas. Under the reform it aims to record details of 50% of households in each location, selected by the community, rather than seeking full coverage in each area as per the earlier database. The change is intended to increase the influence of the community, improve accuracy and speed up completion of the database. However, a side effect is that the data—while possibly more accurate—may cover a smaller percentage of households in any given area than the previous one, so may be a less useful starting point for finding out about households in the event of an emergency, since many of those who were not considered poor initially will not be on it. ## E2 'Piggybacking' On An Established System Or Programme In Practice Examples Of Piggybacking On Beneficiary Lists And Databases: Lesotho And Mali Source: Kardan *et al*. (2017); O'Brien *et al*. (2018) During fieldwork, several examples of piggybacking were found to be under discussion or under implementation. Commonly, actors take advantage of databases or households lists that have already been set up by another programme, in order not to duplicate the effort: indeed, often these databases are set up with that purpose in mind (see section D7 above for more on such databases).  In Lesotho during the El Niño-induced drought in 2016, the UN Food and Agriculture Organisation (FAO) and Catholic Relief Services (CRS) piggybacked on a specific programme: they used the Child Grant Programme's beneficiary list to distribute seeds, training and vouchers.  In Mali, the government has piggybacked on humanitarian databases to build the Registre Social Unifié, a unified social registry that is still being developed but is envisioned as a gateway for all actors working on social assistance to access information about individuals and households. The appropriateness of this action depends on factors such as the extent to which social protection programme beneficiaries are also disaster-affected, and the data privacy arrangements in place. ## An Opportunity For Piggybacking: Pakistan'S National Socioeconomic Registry Source: Watson *et al*. (2017) Piggybacking was identified by some stakeholders as the most feasible option for effective shockresponsive social protection in Pakistan. Agencies responding to a disaster might usefully build on elements of the delivery systems used by the national social assistance intervention, the Benazir Income Support Programme (BISP). For example, they could obtain support regarding data from the the underlying social registry, the National Socio Economic Registry (NSER) and regarding registration from the National Database and Registration Authority (NADRA) who are responsible for the issuance of computerised national IDs. This would provide the opportunity to build upon the technical knowledge and procedures developed within BISP as an organisation, including the strong relationship with NADRA and the NSER database which, despite some limitations, still contains the strongest household data that exists in the country. ## A Challenge In Lesotho: To Piggyback On The National Social Registry Or Not? Source: Kardan *et al.* (2017) In Lesotho, during the 2016 drought, some humanitarian agencies considered whether to select households for support by piggybacking either on the national social registry, the National Information System for Social Assistance (NISSA), which listed over 100,000 households who were thought to be chronically poor and vulnerable; or on a subset, the 27,000 households who receive transfers under the Child Grant Programme (CGP). Some international agencies had existing relationships with the implementers of the NISSA and the CGP, which made it an accessible route through which to reach affected households. The relatively extensive coverage was also an advantage. On the other hand, the database covered households in only about half the community councils (subdistricts) in Lesotho; some areas had been picked by lottery, so were not necessarily the areas most affected by a drought; and the data had been collected several years earlier, some of it in 2010, so much of it was out of date. The data were also not visible to people outside the capital, including the district disaster management teams who coordinated the emergency response. In the end no agency used the broader NISSA database, ie. of non-CGP households, since that data had not been used since it was collected and it did not seem the best way to identify households currently facing food insecurity. However, some agencies—such as FAO and CRS— did piggyback on the CGP beneficiary list to distribute their assistance as those households were currently in receipt of transfers so their records were more up-to-date and they could be traced (see also above). Other social protection databases were not assessed for their suitability to be piggybacked on, so we cannot compare these benefits and drawbacks relative to other programmes. ## Example From Ecuador: Response To The 2016 Earthquake Source: Beazley (2017) WFP provided support to the Government of Ecuador in response to the 2016 earthquake. WFP channelled its support through the emergency allowance Bono de Alimentación, which relied on systems, processes and infrastructure used by regular social assistance schemes. ## E3 'Vertical Expansion' In Practice: Top-Ups To Current Beneficiaries Example Of Vertical Expansion: Top-Ups To A Cash Transfer In The Philippines Source: Smith *et al.* (2017) The Philippines has a major government-led national conditional cash transfer (CCT) programme, the Pantawid Pamilyang Pilipino Programme (known as Pantawid or 4Ps). Pantawid routinely delivers cash benefits to 4.4 million poor households with children—making it the world's third largest CCT. Following Typhoon Haiyan in 2013, Pantawid was vertically expanded in two ways: WFP provided a small amount of extra cash and rice to 105,000 beneficiary households in typhoon-affected areas immediately after the disaster, and UNICEF provided a much larger top-up to about 5,800 beneficiary households with children for six months during the subsequent recovery phase, prioritising structurally vulnerable households. We class this as vertical expansion of Pantawid—rather than WFP and UNICEF piggybacking on Pantawid's beneficiary list—because the response was fully integrated into the national programme: all the Pantawid systems were used, rather than just one or two, and the programme continued to be branded as Pantawid throughout. ## Benefits Of Vertically Expanding A Cash Transfer: Example Of The Philippines Source: Smith *et al.* (2017) In wanting to respond with cash at scale following Typhoon Haiyan, WFP could not find an NGO with the capacity to identify households and disburse cash quickly across all of the affected area, which would have required new systems and processes for communication, targeting and payment. The Pantawid programme had well established systems and extensive coverage, and many disaster-affected families were already enrolled in it. It therefore offered a rapid means to reach a large number of people with emergency cash assistance, at a speed and scale that was not possible through traditional humanitarian channels (over 105,000 households within two months, compared to 85,000 through NGOs over a longer period). As explained by a WFP official: 'The first cash we got out was through our NGO partners. But to reach the scale that we reached with cash transfers through the Pantawid partnership— there was no other way of doing this rapidly. The targeting, verification, ID, delivery instrument and multi-pathway delivery channels with pre-existing contracts all helped' . The timeframe for launching the vertical expansion of Pantawid (one month) also compared favourably with the several months that it took WFP to establish a service agreement with a financial service provider on its separate 'cash for assets' programme during the recovery phase. This ability of the CCT to disburse emergency relief quickly at scale means that for those households who were Pantawid beneficiaries, it was a more efficient channel for cash distribution than the parallel humanitarian system. The donor, WFP, reports that using existing systems also meant relatively low transaction costs compared to the alternatives through implementing partners. ## Vertical Expansion Of Cash Transfers In Latin America And The Caribbean Source: Beazley, Solorzano and Sossouvi, (2016) In Latin America and the Caribbean, governments tend to lead and fund the response to shocks. Cash-based social assistance has been mostly used to respond to shocks, largely because of strong administrative capacity in managing cash transfer programmes. For example, in Argentina, the government gave additional benefits to beneficiaries of the child grant Asignación Universal por Hijo, and of the social pension, in response to the flooding of 2015. In Guatemala, recipients of the CCT Bono Seguro who inhabit areas that are declared by the state as suffering from an emergency situation receive an increase of up to 50% of their transfer. In Chile, a lump sum was paid to beneficiaries of the Chile Solidario programme affected by the 2010 earthquake. In other cases, school meals have also been used in emergency responses, providing additional rations of food and meals during school holidays (i.e. Haiti, Honduras and Nicaragua). Despite the low coverage of social insurance— particularly coverage of poor people—there are also some experiences in the region of expanding social insurance vertically in response to emergencies (i.e. Argentina, Brazil, Costa Rica, Dominican Republic and El Salvador). ## E4 'Horizontal Expansion' In Practice: Temporary Inclusion Of New Beneficiaries Example Of Horizontal Expansion: The Hunger Safety Net Programme (Hsnp) In Kenya Source: O'Brien *et al.* (2018) The case of the HSNP cash transfer in northern Kenya, led by the National Drought Management Authority, is routinely cited as a prime example of a programme with a flexible component that allows for horizontal expansion in an emergency. The core programme gives cash every two months to 100,000 very poor households across the region. Every household has been registered with a bank account, into which money is paid directly. An innovation in Phase 2 of HSNP, which started in 2013, has been the registration of almost all other households in the four participating counties—nearly 300,000—and give them a bank account as well. The account of these 'Group 2' households is normally dormant—they do not receive a routine transfer—but some are eligible to receive ad-hoc payments from HSNP in a drought, depending on their wealth ranking at the time of a targeting exercise. HSNP has triggered this temporary expansion of transfers to more beneficiaries several times since a first emergency payment in early 2015. It is worth noting that the HSNP operates in an environment where the social protection system is relatively sophisticated and well resourced (by both the government and donors), and where the routine HSNP already reaches over 25% of the population in the areas where it operates. We therefore caution against assuming this can be easily replicated in contexts with nascent social protection systems where the challenges and risks mentioned below are likely to be felt more strongly. ## Example Of Horizontal (And Vertical) Expansion: Ethiopia'S Psnp Source: Gray and Asmare (2012)6; Maunder et al., (2015)7 The Productive Safety Nets Programme (PSNP), originating in 2005 to reduce reliance on annual emergency food aid appeals in chronically food insecure *woredas* (districts), is implemented by Ethiopia's Ministry of Agriculture and supported by a donor coalition. In its most recent phase it has been operating a continuum of four risk management instruments: 1. First, it provides six months of regular transfers per year (cash, food or a mix) to households identified by communities as chronically food insecure. 2. The second stage comprises woreda and regional contingency budgets, 20% of the annual PSNP budget. 3. In 2009 a Risk Financing Mechanism (RFM) was introduced to mobilise additional resources in an emergency. Based on an in-principle donor commitment, it allows for up to $80 million to be mobilised for a crisis each year. The established early warning system triggers the release of funds. 4. A fourth instrument, the Humanitarian Requirements Document, is released twice a year and defines the needs of non-beneficiaries, mostly in terms of food aid, though there is a cash element for non-food requirements such as water, health and education provision The federal government triggered the RFM in August 2011 to address the transitory food needs of about 9.6 million people in PSNP districts, of whom two-thirds were existing PSNP clients and onethird were non-beneficiaries, who received up to three months' support. The literature highlights that the mechanism significantly reduced the 'typical' humanitarian timeline for response. It took nine months from the launch of the humanitarian appeal to leverage all funding. By comparison from request to disbursement of funds the RFM took six weeks, although, though there were significant delays in the government making the initial request to draw down the RFM funds. In 2014 it was triggered again, but with some challenges in timeliness. ## Horizontal Expansion Of Cash Transfers In Latin America And The Caribbean (Lac) Source: Beazley, Solorzano and Sossouvi (2016) As a response to the global financial crisis of 2008 many countries in LAC extended the coverage of their cash transfer programmes. For example, in Colombia, Familias en Acción (Families in Action) increased its number of beneficiaries by almost 50%, from 1.8 million families (7.9 million people) in 2008 to 2.6 million families (11.6 million people) in 2009. In the Dominican Republic, the Solidaridad programme almost doubled, from 1.2 million individuals in 2007 to 2.1 million in 2008, and has remained rather constant since. In Jamaica, the number of beneficiaries of the Programme of Advancement through Health and Education ('PATH'), established in 2002, remained stable in 2008 and 2009, at about 355,000, but increased to 419,000 in 2010. In Peru, the number of beneficiaries of Juntos increased from 2.3 million in 2008 to 2.6 million in 2010. In Paraguay, the programme Tekopora increased coverage exponentially in 2009, from 14,000 families to over 80,000. In Ecuador, the coverage of the BDH, a Human Development Grant, increased from 1 million to 1.2 million between 2008 and 2009. In Mexico, following high food prices and riots of 2007, the Mexican government increased the Prospera budget and the number of beneficiaries was increased by 1 million. In many cases, these horizontal expansions have led to permanent (long-term) increases in social protection caseloads in the region. ## Challenges With Implementing Horizontal Expansion: Decision Not To Proceed In The Philippines Source: Smith *et al*. (2017) In the Philippines after Typhoon Haiyan, WFP and UNICEF considered horizontal expansion of Pantawid but quickly dismissed it. It was not considered to be feasible to design and implement it quickly or effectively post-disaster. This was due, first, to the scale of the disaster, which had affected the government's and the payment service provider's personnel and resources; and, second, the acknowledgement that such an expansion could not be automatic but would require definition, communication and implementation of processes and procedures for identifying, enrolling and paying beneficiaries. ## Risks Of Horizontal Expansion: Perspectives From Pakistan And The Philippines Source: Smith *et al*. (2017); Watson *et al*. (2017) Reservations were expressed by some stakeholders in Pakistan at the prospect of the horizontal expansion of BISP in the event of a major shock. Early experiences with its horizontal expansion in a specific crisis had not subsequently been pursued. Most stakeholders felt that BISP had been designed for a clear purpose and had clear associated targeting criteria. These would need to be changed in times of disaster, which risked obscuring BISP's objectives, and also risked inappropriately raising expectations of long-term support among the temporary caseload. Similar concerns were cited by government personnel in the Philippines, as a reason for not pursuing horizontal expansion of the Pantawid programme after Typhoon Haiyan. Again, there was concern that enrolling a caseload that did not fit the usual eligibility criteria would change Pantawid's focus, which is very specifically to improve human development of poor families. This risked undermining the legitimacy of the long-term programme. The same issues also arose around communicating the temporary nature of the programme's expansion, which could create problems when households were removed post-disaster. ## E5 Alignment In Practice Example Of Alignment: Cash Transfers In Northern Mali Source: O'Brien *et al*. (2018) In Mali, following the 2012 political crisis, only humanitarian and dual-mandate organisations were able to work in the north. A group of NGOs, with ECHO funding, provided one year of emergency cash support in 2014 to nearly 40,000 households under the banner of the '*Cadre Commun*' ['Common Framework']. The support consisted of a total of CFA 100,000 (about $160) per household, split into three tranches. Meanwhile, the government had set up an unconditional poverty-targeted cash transfer programme, Jigisѐmѐjiri, with World Bank funding, in the south in 2012 This supported households with CFA 120,000 (about $194) a year, i.e. CFA 10,000 ($16) per month. Jigisѐmѐjiri had been unable to roll out in the north while the area was not fully under government control. One aim of the Cadre Commun was to provide a model for extending Jigisѐmѐjiri to the north. Acknowledging that the Cadre Commun was not dealing with exceptional crisis needs, but rather with cyclical food insecurity or chronic poverty that is also an issue in the south, the transfer value 2016 was aligned with Jigisѐmѐjiri and disbursed with the same frequency. This has two advantages: first, when the programme finishes, households that transfer onto Jigisѐmѐjiri (if it is still running and enrolling new beneficiaries) will not be surprised by a sudden change in support. Second, if others in the same localities are enrolled on Jigisѐmѐjiri there will not be a mismatch between the benefits received. It is worth noting that not all aspects of cash transfer delivery were deemed suitable for alignment by the NGOs. For example, the Cadre Commun used its own mixture of payment modalities (both cash and voucher) and payment service providers (microfinance institutions, mobile phone operators and local traders) depending on what they thought would work best in a given area. ## Example Of Alignment: The Kore Lavi Programme In Haiti Source: Beazley, Solorzano and Sossouvi (2016); Beazley (2017) As part of a consortium, CARE, Action Contre la Faim (ACF), WFP and World Vision have been supporting the Government of Haiti in establishing a replicable safety net system to reduce food insecurity and vulnerability while building resilience. The Kore Lavi programme is implemented in 24 communes and has four objectives: 1) the completion of household surveys and the establishment of a Management Information System (MIS) for targeting, monitoring and coordinating with other interventions, 2) the provision of food vouchers to around 18,000 households and their gradual inclusion in Village Savings and Loans Associations (VSLAs), 3) the provision of supplementary food rations to pregnant and lactating women, and children and 4) the institutionalisation of the program in Government and in local organisations. Given how prone Haiti is to natural disasters, Kore Lavi aims to strengthen the country's capacity to respond to such disasters. This, together with the intention of establishing a programme that could be replicated by the government, makes it one of the few examples of an 'alignment' type of response in the region. ## Benefit Of Alignment: Cash Transfers And Medical Assistance In Mali Source: O'Brien *et al*. (2018) In Mali it was realised that the assessment form for the Jigisèmèjiri cash transfer could, with a few adjustments to questions, be used to simultaneously assess eligibility for the free medical assistance programme, known as RAMED, for the poorest households. By aligning the forms and the targeting criteria, so that Jigisèmèjiri beneficiaries were automatically enrolled onto RAMED, enrolment onto RAMED greatly increased, as lack of resources for targeting had previously been one of the impediments to its take-up. At the time of the research there were proposals to formalise a protocol of collaboration between the two interventions, harmonise the household ID code for improved monitoring, and changing the duration of eligibility for the medical assistance to three years to match the cash transfer. This type of harmonisation is of routine programmes, but can be considered to improve the shockresponsiveness of both interventions by reducing the likely impact of a shock when it strikes. ## Section F Other Resources The toolkit is just one of a set of outputs produced by the Shock-Responsive Social Protection Systems global research project. Here are links to the others. You may wish to explore these to understand more about the concepts of shock-responsive social protection and their application. There are also many other guides that may be of further use to you in your analysis of the current context, or to think through options for shock-responsive social protection. We provide some examples. ## F1 Global Study On Shock-Responsive Social Protection (Dfid)  All written outputs of the project are available on the **OPM website** at http://www.opml.co.uk/projects/shock-responsive-social-protection-systems  There is a **community of practice** on 'Social Protection in Crisis Contexts' on the socialprotection.org website8 created by this project and now self-sustaining. This is a space where you can post documents and ideas, and interact with other professionals working in the field. It also contains links to the many relevant documents.  The **literature review**, listed below, contains references to hundreds of documents relevant to the topic of shock-responsive social protection Six case studies, a global literature review and a synthesis report, form the core of the Shock- Responsive Social Protection Systems research project. Other outputs include policy briefs, blogs, infographics, webinars and an animated cartoon summarising key findings. | Link to full report | Link to summary policy brief | Document | |------------------------|---------------------------------|-------------| | Year | | | | published | | | | Lesotho | 2017 | In | | Mali | 2018 | In | | Mozambique | 2017 | In | | Pakistan | 2017 | In | | Philippines | 2017 | In | | Sahel | 2017 | In | | 2017 | In | English | | Literature review | | | | (2nd edition) | | | | Synthesis report | 2018 | In | ## Table 12 Other Outputs From The Global Study | Link to document | Document | Title | |---------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------|-----------------| | Year | | | | published | | | | Policy brief | | | | Factors affecting the usefulness of existing social protection databases in disaster preparedness | | | | and response | | | | 2017 | Policy brief | | | One-pager | Conceptualising shock-responsive social protection (published as part of IPC-IG One-Pager series) 2017 | One-pager | | Working | | | | Paper 1 | | | | Conceptualising shock-responsive social protection | 2015 | Working paper 1 | | Working | | | | Paper 2 | | | | Preparatory document for Mali case study [ | | | | Document de travail 2 : Etude de cas du Mali. | | | | Document préparatoire | | | | ] | | | | 2016 | | | | Working paper 2 | | | | (French only) | | | | Working | | | | Paper 3 | | | | Shock-Responsive Social Protection in the Sahel: Community Perspectives | 2016 | | | In | English | and | | French | | | | Blog | | | | OECD Insights: What do we know about how social protection systems can respond to needs | | | | during a crisis? | | | | 2016 | Blog | | | Blog | PLACARD: How do social protection systems respond to needs during a crisis? | 2016 | | Blog | | | | Humanitarian Practice Network: Shock-responsive social protection in the Sahel: How to | | | | incorporate community perspectives? | | | | 2017 | Blog | | | Infographic | Original Conceptual Framework informing study | 2017 | | Animated | | | | cartoon | | | | Shock-Responsive Social Protection | 2017 | Video | | | | | ## Table 13 Global Study Webinars | No. | Title | |-----------|--------------------------------------------------------------------------------------------------------------| | Year | | | published | | | 1 | A framework and practical guidance on linking humanitarian cash transfers with long-term social safety nets | | 2 | Shock-responsive social protection in practice: perspectives from Kenya and Mozambique | | 3 | Shock-responsive social protection in practice: experiences in Pakistan and the Philippines | | 4 | What role can social protection play in responding to humanitarian emergencies? Findings from a global study | ## F2 Regional Study On Shock Responsive Social Protection In Latin America And The Caribbean (Wfp) This study was conducted by OPM during the same timeframe as the Global Study, with a focus on Latin American and Caribbean countries. Key outputs are summarised below. ## Table 14 Outputs From Opm And Wfp'S Regional Study On Shock Responsive Social Protection In Latin America And The Caribbean | Document | Title and link | |------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------| | Year | | | published | | | Report | Theoretical framework and literature review (LAC focus) | | One-pager | Are social protection systems in Latin America and the Caribbean shock-responsive? | | Case study | Ecuador case study | | Case study | Guatemala case study | | Case study | Haiti case study | | Case study | Dominican Republic case study (in Spanish) | | Report | (Draft) Summary of key findings and policy recommendations | | Factsheet | Shock-Responsive Social Protection in Latin America and the Caribbean | | 2017 | | | Webinar | | | Protección social reactiva frente a emergencias en América Latina y el Caribe: las Experiencias de Ecuador y Guatemala | | | (in Spanish) | | | Webinar | Shock Responsive Social Protection in Latin America and the Caribbean: recent regional experiences | | Video | Shock Responsive Social Protection in Latin America and the Caribbean | | | | ## F3 Other Resources And Toolkits The list in Table 17 below is indicative of the resources and tools that are available on topics related to shock response, primarily developed by NGOs, INGOs and multilateral organisations involved in emergency response. It includes a list of useful websites. ## Table 15 Other Resources And Toolkits | Title and organisation | Description | Link | |-----------------------------------------------------------------------------------------------------------|----------------|-------------------------------------------------------------------------------------------------------------| | Specific focus on shock responsive social protection and related | | | | Here | | | | Shock response | | | | readiness appraisal | | | | toolkit, ODI | | | | This toolkit is intended to inform the development and re-orientation of national social protection | | | | strategies to enable them to better cope with future shocks, and has been prepared for an audience of | | | | national or donor stakeholders. The diagnostic approach presented in the toolkit enables an appraisal to | | | | be made of the readiness of the social protection sector to respond to shocks in low- and middle-income | | | | countries, with the aim of informing planning and resource allocation decisions and identifying priority | | | | actions to feed into national strategy development. | | | | Here | | This guidance note has been prepared from a humanitarian perspective, for humanitarian actors engaged | | in cash based programming. It recognises that social protection is the responsibility of national | | | | governments, but also that there is immense scope for humanitarian actors to play a role in strengthening | | | | existing, and supporting the creation of new, social protection systems where they do not exist or are | | | | underdeveloped. | | | | Working with cash based | | | | safety nets in | | | | humanitarian contexts: | | | | Guidance note for | | | | humanitarian | | | | practitioners, CaLP | | | | Here | | The paper discusses the role that social protection can play in saving livelihoods while also enhancing the | | capacity of households to respond, cope and withstand threats and crises. The paper builds on FAO | | | | Social Protection Framework (FAO, 2017) and focuses on the role of social protection systems in | | | | humanitarian contexts, with a closer look at protracted crises and a discussion on the importance of | | | | shock-sensitive and responsive systems, even in stable contexts. | | | | Social protection and | | | | resilience. Supporting | | | | livelihoods in protracted | | | | crises and in fragile and | | | | humanitarian contexts, | | | | FAO | | | | Here | | | | Building Resilience to | | | | Disaster and Climate | | | | Change through Social | | | | Protection | | | | This toolkit provides guidance on how to prepare social protection programs to respond to disasters and | | | | climate change. The snapshots of good practice experiences and practical tips for implementation are | | | | intended to guide decision makers in countries facing these risks in adapting their social protection | | | | programs to reduce negative impacts and accelerate recovery. The toolkit consists of a synthesis | | | | document and a set of online materials, comprising five Guidance Notes, five case studies, two technical | | | | notes, and a video | | | | Title and organisation | Description | Link | |----------------------------------------------------------------------------------------------------------------|----------------|---------------------------------------------------------------------------------------------------------------| | Here | | This toolkit outlines the process required to incorporate climate change adaptation and/or disaster risk | | reduction into social protection programmes, thereby ensuring that they become examples of adaptive | | | | social protection. | | | | Adaptive Social | | | | Protection, Making | | | | Concepts a Reality, | | | | guidance note, IDS | | | | Here | | The objective of this tool is to provide key elements for analysis to identify to what extent national Social | | Protection (SP) systems incorporate Disaster Risk Management (DRM) and Climate Change Adaptation | | | | (CCA) components with a specific focus on children, and existing gaps and opportunities for articulation | | | | between institutions in the field of resilient development and SP. | | | | Analysis tool for linking | | | | social protection with | | | | disaster risk management | | | | and climate change | | | | adaptation, UNICEF | | | | Assessing social protection systems (see also Section C4) | | | | Here | | | | Social Assistance in | | | | Developing Countries | | | | Database | | | | The Social Assistance in Developing Countries Database aims to: provide a summary of the evidence | | | | available on the effectiveness of social assistance interventions in developing countries; focus on | | | | programmes seeking to combine the reduction and mitigation of poverty, with strengthening and | | | | facilitating household investments capable of preventing poverty and securing development in the longer | | | | term; select programmes for inclusion in the database on the basis of the availability of information on | | | | design features, evaluation, size, scope, or significance. | | | | Here | | | | Atlas of Social Protection | | | | (ASPIRE), World Bank | | | | This portal provides harmonized indicators which describe the country context where SPL programs | | | | operate, and show performance of social assistance, social insurance and labor markets programs based | | | | on nationally representative household survey data from 122 developing countries.. | | | | | | | | Data underpinning the ILO 2017-2019 Social Protection Report | Here | | | Data from ILO 2017-2019 | | | | Social Protection Report | | | | Here | | | | Inter-Agency Social | | | | Protection Assessment | | | | tools | | | | | | | | | | | | A set of practical tools that help countries improve their social protection system by analysing its strengths | | | | and weaknesses and offering options for further action. Key existing tools include the comprehensive | | | | Core Diagnostic Instrument (CODI), a tool on payment systems, one on ID systems and one on Public | | | | Works programmes. | | | | Forthcoming | | | | `Preparedness' | | | | assessment tool for | | | | humanitarian cash | | | | transfers, UNICEF | | | | | | | | This is a basic assessment tool for determining the feasibility, or "readiness", of the country's social | | | | protection system to implement preparedness and mitigation strategies supporting the use of CTP in | | | | emergencies. In addition, it helps with the feasibility or readiness of UNICEF and other actors | | | | (humanitarian implementing agencies, financial service providers) for preparing for and implementing | | | | humanitarian cash transfer programmes. | | | | Title and organisation | Description | Link | |----------------------------------------------------------------------------------------------------------------|----------------|------------------------------------------------------------------------------------------------------| | Assessing risks and impacts of disasters/shocks (see also section | | | | C1 | | | | ) | | | | Here | | | | Multi-Hazard Disaster | | | | Risk Assessment, DFID | | | | Carrying out a multi-hazard risk assessment is the first step in preparing a disaster resilience country | | | | strategy. This How to Note sets out a framework for undertaking the assessment. A number of | | | | approaches and methodologies could be employed for each step, though as far as possible, the process | | | | should be light touch and make use of existing information. | | | | Here | | | | Global Risk Data Platform | | | | A multi-agency effort to share spatial data information on global risk from natural hazards. It is possible to | | | | visualise, download or extract data on past hazardous events, human & economical hazard exposure and | | | | risk from natural hazards. | | | | Here | | | | INFORM index | | | | INFORM is a national-level composite indicator (combining 53 indicators on three dimensions of risk: | | | | Hazards & Exposure, Vulnerability and Lack of Coping Capacity) that identifies countries at risk of | | | | humanitarian crisis and disaster that would overwhelm national response capacity | | | | Here | | | | The International Disaster | | | | Database (EM-DAT) | | | | In 1988, the Centre for Research on the Epidemiology of Disasters (CRED) launched the Emergency | | | | Events Database (EM-DAT). EM-DAT was created with the initial support of the World Health | | | | Organisation (WHO) and the Belgian Government. The main objective of the database is to serve the | | | | purposes of humanitarian action at national and international levels. The initiative aims to rationalise | | | | decision making for disaster preparedness, as well as provide an objective base for vulnerability | | | | assessment and priority setting. EM-DAT contains essential core data on the occurrence and effects of | | | | over 22,000 mass disasters in the world from 1900 to the present day. | | | | Here | | Disaster Risk Management Programs for Priority Countries has data on 31 countries, including risk | | profiles, details of government agencies working on disaster risk management, agencies active in risk | | | | mapping, key donor engagements. | | | | Global Facility for | | | | Disaster Reduction and | | | | Recovery (GFDRR) | | | | Here | | The Famine Early Warning Systems Network is a leading provider of early warning and analysis on food | | insecurity. Created by USAID in 1985 to help decision-makers plan for humanitarian crises, FEWS NET | | | | provides evidence-based analysis on some 34 countries. | | | | Famine Early Warning | | | | Systems Network | | | | (Fewsnet) | | | | Here | | | | Disaster Risk Index (DRI) | | | | The DRI enables the calculation of the average risk of death per country in large- and medium-scale | | | | disasters associated with earthquakes, tropical cyclones and floods, based on data from 1980 to 2000. It | | | | also enables the identification of a number of socio-economic and environmental variables that are | | | | correlated with risk to death and which may point to causal processes of disaster risk. In the DRI, | | | | countries are indexed for each hazard type according to their degree of physical exposure, their degree of | | | | relative vulnerability and their degree of risk. | | | | Title and organisation | Description | Link | |------------------------------------------------------------------------------------------------------------|----------------|------------------------------------------------------------------------------------------------| | Here | | | | World Risk Index | | | | The index evaluates the exposure to natural hazards faced by 171 countries and assesses the inherent | | | | vulnerability in the countries towards suffering from impacts when facing these hazards | | | | Here | | | | Global Climate Risk Index | | | | The Global Climate Risk Index 2017 analyses to what extent countries have been affected by the impacts | | | | of weather-related loss events (storms, floods, heat waves etc.). The most recent data available - from | | | | 2015 and 1996–2015 - were taken into account. | | | | Here | | | | Natural hazards Risks | | | | Atlas, Maplecroft | | | | The Natural Hazards Risk Atlas, which assesses 197 countries on physical and economic exposure to 12 | | | | types of natural hazards, including flooding, storm surge, earthquakes, tsunamis, cyclones, wildfires and | | | | volcanoes, is produced annually to assist companies and insurers to identify risks to assets worldwide | | | | Here | | | | Global Humanitarian | | | | Overview, OCHA | | | | The Global Humanitarian Overview is the most comprehensive, authoritative and evidence-based | | | | assessment of world humanitarian needs. The GHO is based on detailed analysis of comprehensive data | | | | from a wide range of sources, and face-to-face interviews with hundreds of thousands of people directly | | | | affected by humanitarian crises across the globe. Our global plan facilitates effective, rapid and | | | | coordinated responses to humanitarian crises, supporting prompt life-saving action by humanitarian | | | | agencies, generously financed by governmental, private and individual donors. | | | | Here | | | | ND-GAIN Country Index | | | | The ND-GAIN Country Index summarizes a country's vulnerability to climate change and other global | | | | challenges in combination with its readiness to improve resilience. It aims to help governments, | | | | businesses and communities better prioritize investments for a more efficient response to the immediate | | | | global challenges ahead. | | | | Here | | | | Guidance Note on | | | | Conducting a Disaster | | | | Risk Finance Diagnostic, | | | | ADB and World Bank | | | | The World Bank and Asian Development Bank have worked in more than 50 countries to (i) quantify the | | | | economic and fiscal impact of disasters; (ii) take stock of existing mechanisms to finance these costs and | | | | analyze their legal and institutional underpinnings; (iii) review aspects of the insurance and capital | | | | markets that are relevant for disaster risk finance; and (iv) estimate potential funding gaps following | | | | disasters. This note provides guidance on how to conduct such a diagnostic exercise in a systematic and | | | | comprehensive manner. | | | | Here | | The RVAA system is widely acknowledged as the main system to track, report and respond to food | | insecurity in the Region. The Programme produces outputs at the regional and national level, including | | | | national and regional vulnerability assessments. | | | ## Sadc Regional Vulnerability Assessment And Analysis (Rvaa) Programme | Title and organisation | Description | |---------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------| | Here | | | Shock Impact Simulation | | | Model, (SISMod) | | | Developed jointly by WFP (VAM) and FAO (Global Information and Early Warning System), SISMod is an | | | economic modelling system that serves as a food security analysis tool, used to measure the impact of | | | shocks on food security in vulnerable countries. It brings new possibilities to allow timely quantitative | | | assessments on the ex-ante and ex-post impact of various types of shocks (market, economic, climatic) | | | on livelihood and food security. It identifies and profiles the vulnerable groups, and estimates to what | | | extent they are in need. SISMod provides early estimates of the impacts of shocks before field | | | assessments are carried out, informing the initial development of response scenarios. | | | Here | | | Safety Nets Alert Platform | | | (SNAP), WFP | | | The World Food Programme's (WFP) Safety Nets Alert Platform (SNAP) is an innovative regional (Middle | | | East, North Africa and Central Asia) food price monitoring system with state of the art analytical tools that | | | will serve to enhance food security early warning, risk management and social protection mechanisms. | | | SNAP supports decision-makers to take rapid action and prepare interventions in support of vulnerable | | | populations that are based on best available evidence. | | | Here | | | RIMA | | | A quantitative approach that enables a rigorous analysis of how households cope with shocks and | | | stressors. Comparisons can be made between different types of households (for example, male-headed | | | versus female-headed or urban versus rural) in a given country or area. | | | Here | The IPC is a set of protocols (tools and procedures) to classify the severity of food insecurity and provide | | actionable knowledge for decision support. | | | Food Security Phase | | | Classification (IPC) | | | Forthcoming | | | Risk Informed | | | programming guidance, | | | UNICEF | | | This guidance provides the methodology to programme sectors, Government counterparts and other | | | stakeholders to participate in and contribute to the design and implementation of programmes that are | | | grounded in a deep understanding of the risk landscape. By facilitating analysis, the guidance aims to | | | bring together partners to build consensus related to risk for children, their families, communities and | | | systems. The guidance helps teams on the ground to understand vulnerability, capacity, exposure as well | | | as shocks and stresses to integrate risk considerations into programming, including monitoring and | | | evaluation. | | | Vulnerability, needs and context analysis | | | Here | | | Participatory Vulnerability | | | Analysis, ActionAid | | | This guide is developed to assist field workers and communities to analyse people's vulnerability, draw | | | action plans, mobilise resources and enact appropriate policies, laws and strategies to reduce their | | | vulnerability to disaster. Provides a framework and tools for doing this, including steps to 1) assess | | | vulnerability, 2) assess causes, 3) assess current action/coping mechanisms. Again focus remains at | | | community-level but there are components of district and national-level analysis. | | | Title and organisation | Description | Link | |--------------------------------------------------------------------------------------------------------------|----------------|-----------------------------------------------------------------------------------------------------| | Here | | | | | | | | Multi-Sector Initial Rapid | | | | Assessment Guidance | | | | (MIRA), IASC | | | | The Multi-Cluster/Sector Initial Rapid Assessment (MIRA) is a joint needs assessment tool that can be | | | | used in sudden onset emergencies, including IASC System-Wide level 3 Emergency Responses (L3 | | | | Responses). It is a precursor to cluster/sectoral needs assessments and provides a process for collecting | | | | and analyzing information on affected people and their needs to inform strategic response planning. | | | | Here | | | | Household Economy | | | | Approach (HEA) | | | | The Household Economy Approach (HEA) is a unique livelihoods-based framework designed to provide a | | | | clear and accurate representation of the inside workings of household economies at different levels of a | | | | wealth continuum and in different parts of the world. At the heart of the HEA is an analysis of: 1. how | | | | people in different social and economic circumstances get the food and cash they need; 2. their assets, | | | | the opportunities open to them and the constraints they face; and 3. the options open to them at times of | | | | crisis. It involves the analysis of the connections among different groups and different areas, providing a | | | | picture of how assets are distributed within a community and who gets what from whom. | | | | Here | | | | Household Livelihood | | | | Security Analysis (HLSA), | | | | CARE | | | | HLSA is CARE's basic framework for program analysis, design, monitoring and evaluation. HLS grows | | | | out of a food security perspective, but is based on the observation that food is only one important basic | | | | need among several, and adequate food consumption may be sacrificed for other important needs. Given | | | | that the causes of poverty are complex, HLS provides a framework to analyse and understand the web of | | | | poverty and people's mechanisms for dealing with it. | | | | Here | | | | Household Vulnerability | | | | Index (HVI), FAO | | | | The Household Vulnerability Index (HVI) is a measure that was developed by the Food, Agriculture and | | | | Policy Analysis Network (FANRPAN) to measure vulnerability of households and communities to the | | | | impacts of diseases and shocks such as HIV and AIDS and poverty. | | | | Here | | Guidelines that provide a framework within which an assessment can be organized. By working through | | the guidelines, you should be able to cover all the main issues required for a successful assessment in | | | | the context of an emergency. | | | | Guidelines for | | | | assessment in | | | | emergencies, IFRC | | | | Here | | | | PCVA "is a risk analysis process designed to help staff and partner organisations engage with | | | | communities in contexts where natural disasters are significant drivers of poverty and suffering" - with the | | | | aim of developing a risk reduction action plan and putting it in to practice. Participatory, community- | | | | level/focused assessment tools, which includes: secondary data collection; participatory community | | | | appraisal; (participatory) hazard analysis; prioritisation of risks | | | ## Participatory Capacity And Vulnerability Analysis (Pcva): A Practitioner'S Guide, Oxfam | Title and organisation | Description | |---------------------------------------------------------------------------------------------------------------|----------------| | Here | | | Guidelines for Resilience | | | Systems Analysis, OECD | | | Step by step approach to resilience systems analysis, for field practitioners to: | | |  | | | prepare for, and facilitate, | | | a successful multi-stakeholder resilience analysis workshop | | |  | | | design a roadmap to boost the resilience of | | | communities and societies | | |  | | | integrate the results of the analysis into their development and humanitarian | | | programming. | | | Here | | | Post-Disaster Needs | | | Assessment and | | | Recovery Framework | | | (PDNA/RF) | | | An approach to harmonize the assessment, analysis and prioritization of damages, losses and needs by a | | | range of stakeholders (United Nations agencies and programmes, the World Bank, donors, non- | | | governmental organizations) in support of the national government. PDNA is a government-led exercise, | | | with integrated support from the United Nations, the European Commission, the World Bank and other | | | national and international actors. A PDNA pulls together information into a single, consolidated report, | | | information on the physical impacts of a disaster, the economic value of the damages and losses, the | | | human impacts as experienced by the affected population, and the resulting early and long-term recovery | | | needs and priorities. | | | Here | | | Food Security and | | | Livelihoods in First Phase | | | Emergency 48-Hours | | | Assessment Tool, Oxfam | | | The purpose of this tool is to obtain a quick understanding of the emergency food security and livelihood | | | situation within the first few days after a rapid-onset disaster. This tool is independent of other inter- | | | agency multi-sectoral assessments such as the MIRA and collects information only on food security and | | | livelihoods. However, this tool can be used alongside such processes. The results of this initial | | | assessment are aimed to inform the design of first phase responses, for the first 6 to 8 weeks after the | | | disaster occurred. | | | Here | | | WFP Vulnerability | | | Analysis Mapping One | | | Stop Shop (VAM) | | | The VAM One Stop Shop is an innovative platform which allows access to the latest food security data, | | | publications and analytical tools. The VAM publications include baseline studies, household/ market | | | monitoring, emergency assessments/market studies and secondary data analysis. The publications are | | | navigable by year, assessment type and field work status, as well as by country through the world map. | | | Here | | | Comprehensive Food | | | Security & Vulnerability | | | Analysis (CFSVA), WFP | | | Designed to understand and describe the profiles of food-insecure and vulnerable households, identify the | | | root causes of hunger, and analyze the risks and emerging vulnerabilities among populations in crisis- | | | prone countries. It also makes recommendations on the best response options (food or non-food) to | | | reduce hunger, target the neediest and informing preparedness. | | | Here | | | Emergency Food Security | | | Assessment (EFSA), WFP | | | The purpose is to assess the impact of shock on the food security of households and communities within | | | the affected area. Key outputs include: - description of the current food and nutrition security situation; - | | | analysis of the ways in which the affected population, the government and other stakeholders are | | | responding to the emergency; - forecast of the future evolution of food and nutrition security; - | | | identification of response options, and recommendations for intervention or non-intervention. An EFSA | | | may be conducted as a rapid assessment or an in-depth assessment. | | | Title and organisation | Description | |----------------------------------------------------------------------------------------------------------------|----------------| | Here | | | Vulnerability and | | | Capacity Assessment | | | (VCA), IFRC | | | | | | VCA is complementary to national and sub-national risk, hazard, vulnerability and capacity mapping | | | exercises that identify communities most at risk. Vulnerability and Capacity Assessment (VCA) uses | | | various participatory tools to gauge people's exposure to and capacity to resist natural hazards. It is an | | | integral part of disaster preparedness and contributes to the creation of community-based disaster | | | preparedness programmes at the rural and urban grass-roots level. | | | Here | | | Climate Vulnerability and | | | Capacity Analysis | | | (CVCA), CARE | | | | | | The main objectives of the CVCA are to: Analyze vulnerability to climate change and adaptive capacity at | | | the community level; Combine community knowledge and scientific data to yield greater understanding | | | about local impacts of climate change. The CVCA process builds people's understanding about climate | | | risks and adaptation strategies. It provides a framework for dialogue within communities, as well as | | | between communities and other stakeholders (e.g. local and national government agencies). | | | Here | | | Guidelines for resilience | | | systems analysis, OECD | | | Simple "how to" guide to analyse what is needed to boost the resilience of specific groups, specific | | | systems, and specific programmes, to the risks people face every day. The results of this analysis are | | | then used to design new programmes to boost resilience, or to modify ongoing plans and actions. | | | Here | | | CLEAR - Consolidated | | | Livelihood Exercise for | | | Analysing Resilience, | | | WFP | | | CLEAR is an analytical tool developed by WFP to assess and better understand the impacts of climate | | | risks on food security. It consists in a livelihood zoning and profiling exercise carried out using a rapid | | | livelihood assessment, aiming at identifying and describing generalizable trends and patterns in | | | livelihoods that can then serve as a starting point for analyzing food security and vulnerability. In addition | | | to the delineation of geographic areas based on patterns of livelihood activities, it furthers the analysis by | | | ranking the livelihood zones according to their experiences of food security, diversity of livelihood | | | activities and sensitivity of income to climate-related hazards. | | | Here | | | Integrated Context | | | Analysis (ICA), WFP | | | Part 1 of WFP's 3-pronged approach. A collaborative and consultative programming tool that helps orient | | | geographic prioritisation for intervention based on where different levels of recurrence of food insecurity | | | and natural shocks have historically overlapped. It is used to inform strategic programmatic decision- | | | making in specific geographical areas in resilience, disaster risk reduction, social protection, and | | | preparedness actions. | | ## Emergency Programming And Planning Here Seasonal Livelihoods Programming (SLP), WFP Part 2 of WFP's 3-pronged approach Consultative process that brings together communities, government, and partners to develop a shared understanding of the context and to highlight which programmes should be implemented when, for whom, and by which partners, during typical and crisis years. This dialogue aims to strengthen operational plans across multiple sectors and institutions, to inform resilience-building, productive safety nets and other relevant agendas, and to enhance partnerships and coordination. | Title and organisation | Description | |------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------| | Here | | | | | | A local level participatory exercise to empower vulnerable communities and women, build a shared | | | understanding of livelihoods, landscapes, shocks and stresses, vulnerabilities and priority needs, and to | | | develop a multi-sectorial action plan tailored to the local context. | | | Community-based | | | Participatory Planning | | | (CBPP), | | | WFP | | | Here | | | Emergency Preparedness | | | and Response Package, | | | WFP | | | The Package is WFP's toolbox for enhancing emergency preparedness and response capabilities at the | | | field level. The Package builds on the experience and expertise gathered by WFP and its partners in | | | contingency planning, business continuity and pandemic planning. It creates linkages with other planning | | | processes and frameworks, at both internal and inter-agency levels | | | Here | | | Market Analysis | | | Framework, WFP | | | The Market Analysis Framework (MAF) provides an overview of various market analysis tools, including | | | what purpose(s) they serve, how they are related, and where to find the technical details on each of them. | | | This guidance can help you to: understand the links between market and food security analysis - prioritize | | | market information needs for food security analysis and response planning - and select the appropriate | | | tool according to the context, objectives and information requirements. | | | Here | Quick, rough-and-ready market analysis toolkit to inform practical recommendations that are suitable for | | the early stages of emergencies. | | | Emergency Market | | | Mapping and Analysis | | | Toolkit (EMMA) | | | Here | | | Cash in emergencies | | | toolkit, ICRC | | | The Cash in Emergencies Toolkit has been devised by the International Red Cross and Red Crescent | | | Movement as a means to make tools, practical guidance and minimum standards easily accessible to | | | staff and volunteers. The toolkit should inform and guide the implementation of CTP, to improve the | | | quality of CTP at the different phases of the project cycle. | | | Here | The Cash Transfer Programming (CTP) Toolkit is a basic guide to cash transfer programming in | | emergency response and early recovery settings. | | | Cash Transfer | | | Programming toolkit, | | | MercyCorps | | | Here | | | Core Humanitarian | | | Standard | | | The Core Humanitarian Standard on Quality and Accountability (CHS) sets out Nine Commitments that | | | organisations and individuals involved in humanitarian response can use to improve the quality and | | | effectiveness of the assistance they provide. | | | Here | The Sphere Handbook is one of the most widely recognized sets of common principles and universal | | minimum standards for the delivery of quality humanitarian response. | | | The Sphere | | | Handbook: Humanitarian | | | Charter and Minimum | | | Standards in | | | Humanitarian Response | | | Title and organisation | |---------------------------------------------------------------------------------------------------------------| | Here | | Good Practice Review | | Emergency food security | | interventions | | This Good Practice Review explores programming practices in emergency food security. It provides an | | overview of conceptual issues and planning approaches, together with programming practices in | | interventions designed to protect the food security of disaster or crisis-affected groups. Along with a brief | | description of the intervention, its application, management and monitoring, each chapter includes | | references to topic-specific overviews, tools and case studies. | | | ## Other Useful Websites And Repositories On Related Topics | Here | | |-----------------------------------------------------------------------------------------------------------|-----| | Humanitarian Response, | | | OCHA | | | Purpose: to support efficient, effective, and coordinated humanitarian response through the sharing of | | | operational information. Managed by OCHA, this website serves as a central repository for information | | | management tools and services, enabling information exchange among humanitarian aid agencies and | | | staff. This global site is complimented by country-specific emergency sites. | | | Here | | | Reliefweb, OCHA | | | ReliefWeb is the leading humanitarian information source on global crises and disasters. It is a | | | specialized digital service of the UN Office for the Coordination of Humanitarian Affairs (OCHA). | | | Here | | | Preventionweb | | | PreventionWeb is a collaborative knowledge sharing platform on disaster risk reduction (DRR), managed | | | by the UN Office for Disaster Risk Reduction (UNISDR). The site offers a range of knowledge products | | | and services to facilitate the work of DRR professionals. | | | Here | | | ALNAP | | | ALNAP is a global network of NGOs, UN agencies, members of the Red Cross/Crescent Movement, | | | donors, academics and consultants dedicated to learning how to improve response to humanitarian | | | crises. | | | Here | | | The Cash Learning | | | Partnership (CaLP) | | | CaLP is a global partnership of humanitarian actors engaged in policy, practice and research within cash | | | transfer programming (CTP). Formed of a community of practice including over 150 organisations and | | | more than 5,000 individuals in the humanitarian sector, CaLP is based on learning, knowledge sharing, | | | networking and coordination around the appropriate and timely use of CTP in humanitarian response. | | | Here | | | Humanitarian Practice | | | Network (HPN) | | | Independent forum for policy-makers, practitioners and others working in or on the humanitarian sector to | | | share and disseminate information, analysis and experience, and to learn from it. The only network of its | | | kind, HPN plays a key role in examining policy developments and distilling practice. | | | Here | | | PLACARD | | | PLACARD's (PLAtform for Climate Adaptation and Risk reDuction) mission is to be the recognised | | | platform for dialogue, knowledge exchange and collaboration between the Climate Change Adaptation | | | (CCA) and Disaster Risk Reduction (DRR) communities. | | | Here | | | Socialprotection.org | | | Socialprotection.org aims to facilitate knowledge sharing and capacity building on effective social | | | protection policies and programmes, particularly among low- and middle- income countries. | | ## Section G Glossary9 | Term | Definition | |------------------------------------------------------------------------------|---------------| | Adaptive social | | | protection | | | | | | The concept that synergies can be gained if social protection, disaster | | | risk management and climate change adaptation are considered | | | simultaneously, in order to reduce vulnerability to the impacts of climate | | | change and disasters. | | | Alignment | | | The development of one or more elements of a parallel humanitarian | | | response that aligns as best as possible with those used in a current or | | | possible future social protection programme or DRM system. This could | | | be, for example, an alignment of objectives, targeting method, transfer | | | value or delivery mechanism. This is distinct from piggybacking on | | | elements of a system as it uses a parallel infrastructure rather than the | | | same system. (Note: The term has been used throughout this toolkit in a | | | way that is different from 'alignment' in relation to aid effectiveness | | | principles). | | | Contingency planning | | | A management process that analyses specific potential events or | | | emerging situations that might threaten society or the environment and | | | establishes arrangements in advance to enable timely, effective and | | | appropriate responses to such events and situations. Contingency | | | planning results in organised and coordinated courses of action with | | | clearly-identified institutional roles and resources, information processes, | | | and operational arrangements for specific actors at times of need. Based | | | on scenarios of possible emergency conditions or disaster events, it | | | allows key actors to envision, anticipate and solve problems that can | | | arise during crises. Contingency planning is an important part of overall | | | preparedness. Contingency plans need to be regularly updated and | | | exercised. | | | Design tweak | | | The design of social protection programmes and systems can be | | | adjusted in a way that takes into consideration the crises that a country | | | typically faces. These 'design tweaks' can serve one of two purposes. | | | First, they can introduce flexibility into a social protection programme so | | | as to maintain the provision of the regular service for its usual | | | beneficiaries in the event of a shock. Second, changes to a programme's | | | design can be introduced that can improve its coverage, timeliness or | | | predictability in the event of a crisis, even without requiring the | | | programme to flex at the moment of the shock itself. | | | Disaster risk | | | The potential disaster losses, in lives, health status, livelihoods, assets | | | and services, which could occur to a particular community or a society | | | over a specified future time period. | | | Disaster risk | | | management | | | The systematic process of using administrative directives, organisations, | | | and operational skills and capacities to implement strategies, policies and | | | improved coping capacities in order to lessen the adverse impacts of | | | hazards and the possibility of disaster. | | | Disaster risk reduction | | | The concept and practice of reducing disaster risks through systematic | | | efforts to analyse and manage the causal factors of disasters, including | | | through reduced exposure to hazards, lessened vulnerability of people | | | and property, wise management of land and the environment, and | | | improved preparedness for adverse events. | | | | | Early warning system The set of capacities needed to generate and disseminate timely and meaningful warning information to enable individuals, communities and organisations threatened by a hazard to prepare and to act appropriately and in sufficient time to reduce the possibility of harm or loss. Emergency response Actions taken to mitigate the impact of a dangerous incident on the public or the environment. Horizontal expansion Temporary inclusion of new beneficiaries from disaster-affected communities in a social protection programme. Humanitarian assistance Resources used to fund actions that are designed to, 'save lives, alleviate suffering and maintain human dignity during and in the aftermath of manmade crises and natural disasters, as well as to prevent and strengthen preparedness for the occurrence of such situations (Good Humanitarian Donorship Initiative, 2003). Humanitarian assistance may take many forms. It may include reconstruction and rehabilitation (e.g. restoring infrastructure and community assets such as water supplies), emergency food or cash assistance, services such as the provision of shelter, health, nutrition and education, and measures to protect the safety of the population. Humanitarian assistance is often provided in line with some or all of the key 'humanitarian principles' of humanity, impartiality, neutrality and independence. Humanitarian crisis An exceptional and generalised threat to human life, health or subsistence. Crises may appear within the context of an existing lack of protection, where a series of pre-existing conditions (poverty, inequality etc) exacerbated by a natural disaster or armed conflict, are likely to aggravate destructive effects. Humanitarian assistance must be provided in accordance with the principles of: 1) Humanity - human suffering must be addressed wherever it is found, with particular attention to the most vulnerable in the population, such as children, women and older people. The dignity and rights of all victims must be respected and protected. 2) Neutrality - Humanitarian assistance must be provided without engaging in hostilities or taking sides in controversies of a political, religious or ideological nature. Humanitarian principles 3) Impartiality - Humanitarian assistance must be provided without discriminating as to ethnic origin, gender, nationality, political opinions, race or religion. Relief of the suffering must be guided solely by needs and priority must be given to the most urgent cases of distress 4) Independence - Humanitarian action must be autonomous from the political, economic, military or other objectives that any actors may hold with regard to areas where humanitarian action is being implemented. Mitigation The lessening or limitation of the adverse impacts of hazards and related disasters. Piggybacking Use of part of an established system or programme by a new programme response (either by government or partners). One or more elements could be used, for example the beneficiary list, staff or a payment mechanism. Preparedness The knowledge and capacities developed by governments, professional response and recovery organisations, communities and individuals to effectively anticipate, respond to, and recover from, the impacts of likely, imminent or current hazard events or conditions. Prevention The outright avoidance of adverse impacts of hazards and related disasters. Protracted crisis Protracted crises refer to situations in which a significant portion of a population is facing a heightened risk of death, disease, and breakdown of their livelihoods. These circumstances are often linked to recurrent natural disasters or conflicts. While each protracted crises is a distinct occurrence, there are several characteristics which are often present: duration or longevity (hence 'protracted'); conflict; weak governance or public administration; unsustainable livelihood systems and poor food security outcomes; breakdown of local institutions Recovery The restoration, and improvement where appropriate, of facilities, livelihoods and living conditions of disaster-affected communities, including efforts to reduce disaster risk factors. Resilience The ability of a system, community or society exposed to hazards to resist, absorb, accommodate to and recover from the effects of a hazard in a timely and efficient manner, including through the preservation and restoration of its essential basic structures and functions Response The provision of emergency services and public assistance during or immediately after a disaster in order to save lives, reduce health impacts, ensure public safety and meet the basic subsistence needs of the people affected. Risk assessment A methodology to determine the nature and extent of risk by analysing potential hazards and evaluating existing conditions of vulnerability that together could potentially harm exposed people, property, services, livelihoods and the environment on which they depend. Seasonal variations Seasonal variations refer to predictable seasonal patterns which are usually related to agricultural production, such as the harvest season or the lean season. Seasonal variations are different from shocks and stresses, although they may be strongly interconnected. Seasonal variations refer to predictable cyclical variations in weather and the impact on agricultural production. Seasonal variations often result in a food-security crisis if the affected population remain vulnerable to these changes, for example, a large number of households requiring short-term assistance on a regular basis in the lean season. Covariate shocks affect large numbers of people and/or communities at once. Such shocks are often concurrent. Covariate shocks may be natural, economic or political. They include, for instance, drought, floods, typhoons and earthquakes; locust invasions; high food prices and economic downturns; political crises and armed conflict; high numbers of refugees; or outbreaks of disease such as the Ebola epidemic. Shocks vary in:  Speed of onset (rapid vs. slow). Slow-onset shocks bring critical Shock (covariate) questions as to when a gradually worsening situation can be classified as an emergency, and at what point humanitarian agencies should step in and authorise the disbursement of funds. A social protection system designed to respond to slow-onset crises faces the same question as to when its emergency response mechanism should be triggered. Drought is the main slow-onset shock.  Predictability. Slow-onset shocks ought always to be predictable to some degree, though it is not always possible to predict whether or not a slowly developing situation, such as rain failures, will turn into a crisis. Rapid-onset shocks may appear to be less predictable but there is still usually some indication where such shocks might be expected, if not always when: the existence of geological faultlines for earthquakes, for example, or regular weather patterns that commonly lead to cyclones. From this perspective one would expect that a shock-responsive social protection system should take note of this predictability and put in place activities that strengthen early warning systems and improve preparedness for a disaster.  Duration (short-, medium-term or protracted). Protracted crises are often associated with conflict, which will have an effect on the ability of systems to respond. Shock (idiosyncratic) Idiosyncratic shocks affect individual households or household members, for example job loss or the death of a breadwinner. Social assistance Direct, regular cash or in-kind transfers to poor and vulnerable individuals or households. Transfers are non-contributory i.e. those in need are not asked to make contributions to be entitled to receive assistance. Some are targeted based on categories of vulnerability, and some are targeted broadly to low-income groups. Social care Social care helps address the interaction between social and economic vulnerability, through services such as home-based care and family support services. Whilst poverty may be one of the drivers that leads people to require social care and support, income generation alone will not, in many cases, provide the solution to meeting the needs of people who are dependent on others for basic care or protection. This may include children (including orphans, street/working children, children at risk of abuse and neglect, children lacking appropriate care), the disabled of all ages and older people with limited capacities. Social insurance Contributory programmes where participants make regular payments to a scheme that will cover costs related to life-course events, for example, pregnancy, unemployment or illness. Sometimes costs are matched or subsidised by the provider. Social insurance includes contributory pensions. ## Stress Stresses are, 'long-term trends that undermine the potential of a given system or process and increase the vulnerability of actors within it' (DFID, 2011). Stresses can include natural resource degradation, loss of agricultural production, urbanisation, demographic changes, climate change, political instability and economic decline. Some crises are caused by longer term or recurrent problems which eventually cause a livelihood system to reach breaking point. The term 'shock' is often taken to refer to a single event, or a situation developing in a short period of time, and problems caused by difficulties that build up for people over many years might more properly be classified as stresses rather than shocks. However, once the breaking point is reached, or a crisis is recognised, there is a tendency to think of the problem in terms of a shock. In some cases, breaking point or crisis is reached simply because of the duration of the stress. In other cases, though, it is caused when the stress becomes a little more severe than normal, e.g. a particularly long dry season, and in such cases, the situation will almost always be thought of as a shock. Vertical expansion The benefit value or the duration of a social protection programme is temporarily increased for some or all beneficiaries. Vulnerability The characteristics and circumstances of a community, household, system or asset that make it susceptible to the damaging effects of a hazard.
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Mr and Mrs Scott Preliminary Roost Assessment Hall Farm Barn Hall Lane, Litton, Derbyshire, SK17 8QP Project number 027 Version 1 August 2020 ## Document Control Project Information | Client | Mr and Mrs Scott | |------------------|-----------------------------------------| | Project Name | Hall Farm Barn | | Project Number | 027 | | Project Location | Hall Lane, Litton, Derbyshire, SK17 8QP | | Project Type | Preliminary Roost Assessment | | Principal Author | Jo Pedder | | | | | Notes | | | Issue | | | 01 | Original document to client. | | 02 | Minor amendment | | 03 | Minor amendment | | 04 | | | 05 | | Copyright Jo Pedder. All rights reserved. No part of this report may be copied or reproduced by any means without prior written permission from Jo Pedder. This report has been prepared for the exclusive use of the commissioning party and, unless otherwise agreed in writing by Jo Pedder, no other party may use, make use of, or rely on the contents of the report. No liability is accepted by Jo Pedder for any use of this report, other than for the purposes for which it was originally prepared and provided. Opinions and information provided in the report are on the basis of Jo Pedder using due skill, care, and diligence in the preparation of the same and no explicit warranty is provided as to their accuracy. It should be noted, and it is expressly stated that no independent verification of any of the documents or information supplied to Jo Pedder has been made. Any legal information provided by Jo Pedder is an outline only, intended for general information and does not constitute legal advice. Consult the original legal documents and/or seek legal advice for definitive interpretation ## Non-Technical Summary Non-Technical Summary Background In August 2020, Jo Pedder was instructed by Mr and Mrs Scott to undertake a Preliminary Roost Assessment of Hall Farm Barn, Hall Lane, Litton, Derbyshire, SK17 8QP (Ordnance Survey (OS) grid Reference SK 16482 75079). ## Aims - Identify Potential Roosting Features on structures at the Site - Assess the potential value of those features for bats following best practice - Identify signs of nesting birds - Recommend further surveys if necessary - Recommend mitigation, compensation, and enhancement measures. ## Site Description The Site is a two-storey, stone built, agricultural building with a cement-tiled, pitched, roof. The roof is lined with bitumen felt and possibly a second layer of a breathable membrane. It also has a small cement block addition with a mono pitched, corrugated asbestos roof. The Site is part of a complex of barns at Hall Farm which were converted into housing in the 1970s. The surveyed building is attached to converted buildings but has not been renovated. The ground floor is currently used for storage and the first floor is unused. Some of the external walls have recently been repointed up to approximately 2 m. The owner has purposefully stopped at that level to avoid impacts to bats. ## Development Proposals The proposals are to renovate the property as a residential house. The roof will be replaced, and a new structure will replace the existing lean-to ## Information Used For The Assessment - Preliminary Roost Assessment - Internet based desk search - Plans supplied by Axis Architecture ## Outline Assessment And Recommendations The building is used by bats as a feeding perch. Bats may also roost in the building, and additional surveys are required to demonstrate whether this is the case. If bats do roost here, there are licencing procedures that will allow the renovation to be completed, but mitigation and compensation will be required. ## 1 Introduction 1.1 Terms Of Reference In August 2020, Jo Pedder was instructed by Mr and Mrs Scott (the Client) to undertake a Preliminary Roost Assessment of Hall Farm Barn, Hall Lane, Litton, Derbyshire, SK17 8QP (Ordnance Survey (OS) grid Reference SK 16482 75079) (The Site). Information for the assessment was obtained from: - Preliminary Roost Assessment - Internet based desk search - Plans supplied by Axis Architecture The Site is a two-storey, stone built, agricultural building with a cement-tiled, pitched, roof. It also has a small cement block addition with a mono pitched, corrugated asbestos roof. The Site is part of a complex of barns at Hall Farm which were converted into housing in the 1970's. The surveyed building is attached to converted buildings but has not been renovated. The ground floor is currently used for storage and the first floor is unused. Some of the external walls have recently been repointed up to approximately 2m. The owner has purposefully stopped at that level to avoid impacts to bats. The proposals are to renovate the property as a residential house. The roof will be replaced, and a new structure will replace the existing lean-to. ## 1.2 Aims And Objectives The aims of the study were to: - Identify Potential Roosting Features on structures at the Site - Assess the potential value of those features for bats following best practice - Identify signs of nesting birds - Recommend further surveys if necessary - Recommend mitigation, compensation, and enhancement measures. ## 2 Methodology 2.1 Personnel The survey was led and reported by Jo Pedder. Jo Pedder BSc. hons MCIEEM is an ecologist with over 15 years' experience in the environmental consulting sector. Jo holds survey licences for bats (level 2) and great crested newts (level 1) and development licences for bats and newts. Jo has experience in a range of projects from barn conversions to sites over 300 ha and has worked in the minerals, housing, and energy sectors. ## 2.2 Preliminary Roost Assessment A Preliminary Roost Assessment (PRA) was undertaken on the 04/08/2020. The PRA followed the Bat Conservation Trust (BCT) guidelines criteria1 (see Appendix 1). This entails inspecting a structure (e.g. a building or tree) for field evidence of roosting bats such as feeding remains, droppings, urine staining and Potential Roosting Features (PRFs) such as voids, cracks, and crevices. The survey is undertaken from the ground level (or floor level within buildings). Any direct evidence, type, and number of PRFs and the Site's environment is then used to grade the structure's suitability for bats. The assessment is based on the potential value of a roost in the structure, not the likelihood of a bat roost at the structure. A low suitability structure would, at most, have features that individual bats could roost in opportunistically. Structures with a moderate suitability may support bats regularly but are not likely to include hibernation or maternity roosts. A high suitability structure would have one or more potential roost sites that are obviously suitable for use by larger numbers of bats on a more regular basis. ## 2.3 Desk Study Given the limited scale of the proposals and limited potential for impacts to arise outside the Site, a full data search was not commissioned for this stage of the project. Ordnance Survey maps and online aerial photos were used to provide site context and the online Multi-Agency Geographical Information Centre2 (MAGIC) was used to identify any internationally and nationally statutory protected areas within 1 km of the Site. ## 2.4 Survey Constraints Any ecology assessment must be considered as a 'snapshot' of the site conditions at the time of the survey. Ecological constraints will change over time and therefore the findings of this report are considered to be valid for a period of one year, after which the report should be reviewed to assess whether the survey should be updated. The first floor of the building could not be fully accessed due to a potential unsafe floor. However, ladder access was available in two opposite corners and the survey was conducted with a high-powered torch and binoculars. No constraints were such that they affect the overall conclusions and recommendations made herein. ## 3 Results 3.1 Surrounding Area The Site is located in the White Peak National Character Area (NCA). The NCA is a raised, undulating limestone plateau deeply incised with steep-sided limestone valleys. It has a strong sense of place arising from the effect of the underlying geology on landform and its influence on natural and manmade landscape features such as caves, crags, drystone walls, and traditional buildings. The dales are of significant wildlife value, particularly because of their flower-rich limestone grassland and ash woodland, and many contain clean, clear rivers which support species such as white-clawed crayfish, bullhead, lamprey, and dipper. Habitats within 100 m of the Site are predominantly pasture, with farm buildings and the village of Litton. Figure 1, an aerial photograph of the Site, shows the Site in context with the surrounding landscape. | Designation / Location | Ecological Feature | |-------------------------------------------------------|--------------------------------------------------------| | Local Nature Reserves | | | None | n/a | | Nation Nature Reserves | | | Derbyshire Dales | limestone scenery, diverse flora and the wide range of | | butterflies and other insects this supports. | | | | | | Main habitats: limestone grassland, scrub, and valley | | | woodlands; also hay meadows, streams and dew | | | ponds, scree, acid grassland and small areas of | | | 'limestone heath' | | | Sites of Special Scientific Interest | | | Cressbrook Dale | Limestone habitats, rare plants and insects, lichens. | | The Wye Valley | Ancient woodlands, scree habitats, grasslands | | Special Areas of Conservation | | | Peak District Dales | Semi-natural grasslands, calcareous forests. | | Special Protection Areas | | | None | n/a | | Ramsar Sites | | | None | n/a | ## 3.2 Site'S Habitats The Site is a two-storey, stone built, agricultural building with a cement-tiled, pitched, roof. The roof is lined with bitumen felt and possibly a second layer of a breathable membrane. It also has a small cement block addition with a mono pitched, corrugated asbestos roof. The Site is part of a complex of barns at Hall Farm which were converted into housing in the 1970s. The surveyed building is attached to converted buildings but has not been renovated. The ground floor is currently used for storage and the first floor is unused. Some of the external walls have recently been repointed up to approximately 2 m. The owner has purposefully stopped at that level to avoid impacts to bats. Photos taken during the survey are shown in Appendix 2 and detailed survey results are in Appendix 3. The building was found to be suitable for roosting bats. There are numerous locations which crevices roosting bats could roost e.g. in cavities in the stone walls, between lintel timbers, and between roof tiles and roof felt. Direct evidence of bats was found; discarded moth and butterfly wings indicate that the building is used as a feeding perch (mostly likely by brown long-eared bats), staining and scratch marks were also recorded at the ridge beam above a pile of wings. No bat droppings were found at the Site but as the first floor could not be fully accessed it is quite possible that further evidence of bats is present but was not observed during the survey. As potentially large roosts, including a maternity colony could occur at the building, it has been assessed as of **High Potential Value** for bats. Signs of nesting birds were recorded within the building - several very old moss nests were found in crevices and broken eggs and an old pigeon chick carcass was found on the first floor. No nests appeared to be from this season. ## 4 Assessment 4.1 Project Proposals The proposals are to renovate the property as a residential house. The roof will be replaced, and a new structure will replace the existing lean-to. ## 4.2 Further Surveys Required The following surveys are recommended in line with best practice to complete an assessment of the likely ecological impacts of the project. Three dusk or pre-dawn bat roosts surveys (including at least one pre-dawn survey). Two visits must be between May and August and one visit between May and September. ## 4.3 Ecological Constraints Bats Reasonable Worst Case In order to aid the assessment of impacts arising from the proposal based on this initial assessment, and therefore allow the Client to prepare for the recommendations in this report, it is useful to consider a 'reasonable worst case' for the presence of bats. The worst-case assessment is not a substitution for complete surveys and the local authority will not determining the application prior to completing surveys. If bats are present at the Site, they could be any species which commonly roost within buildings as there are structures favoured by crevice roosting bats and void roosting bats. The building is probably too light during the day for light averse species (such as brown long-eared bats) to roost here (although it is almost certain that this species uses the building as a feeding perch at night). A reasonable worst-case scenario is that the building supports a maternity roost of common or soprano pipistrelle bats which roost under roof tiles, small roosts of myotis bats in wall crevices and a brown longeared bat feeding perch. As bats and their roosts are protected, there are procedures that must be followed to lawfully undertake works that might affect them. Natural England are able to grant licences which allow impacts to occur that would otherwise by unlawful. These licences are applied for after planning has been granted. Note that this section is In order for a project to be granted planning permission by a Local Planning Authority (LPA) or for a license to be granted by Natural England (NE), evidence must be presented to satisfy the three 'derogation tests' applied to European Protected Species (EPS) under the Conservation of Species and Habitat Regulations 2010. The tests of 'overriding public interest' and 'no satisfactory alternative' are planning issues and are beyond the scope of this report. However, the recommendations given in this report aim to address the third test - 'maintenance of the favourable conservation status of the species.' More information on legislation, licensing and the derogation test is provided in Appendix 1. based on the worst-case scenario: it is quite possible that no bats will be found, and a licence, mitigation and compensation will not be required. The licence application is accompanied by a method statement, which would include (but not be limited to) the following measures: ## Capture And Release - Timing of works: Works that may impact bats should avoid the maternity season (May to September) and hibernation season (November to February). - Installation of temporary bat box to move any captured bats. - Pre-works inspection by ecologist: Pre-inspection required prior to further re-pointing of the walls, removal of timbers or roof materials. If bats are found and accessible, they will be removed by hand or hand net. - Use of temporary or permanent exclusion measures: one-way exclusion devices will be attached to the roost entrances and left in place for five consecutive days/nights during suitable weather conditions - Supervised soft-strip of features where bats may be encountered under ecologist's supervision and during suitable weather conditions. Where applicable, materials will be lifted away and not rolled, scraped, or sprung and underneath of the materials will be inspected by the ecologist prior to removal. ## Retention Of Roosts - Key roosting areas accessed from gaps in mortar on external walls will be retained. ## Modification Of Existing Roosts - Existing roosts under roof tiles will be recreated in-situ by using slate bat access tiles. - Breathable roofing membranes will not be installed into any roof where bats are being provided access. If the use of roof membranes is necessary, only Bitumen type 1F felt with a hessian matrix will be permitted. Note that this section is - No lighting will be positioned which will directly illuminate roost features, or flight ways to/from the entrance points. ## New Roost Creation - Two integral bat boxes will be created within the walls of the part of the building which will replace the lean-to (see suitable examples in Appendix 4). ## Lighting based on the worst-case scenario: it is quite possible that no bats will be found, and a licence, mitigation and compensation will not be required. There is no legal duty requiring any place to be lit. British Standards and other policy documents allow for deviation from their own guidance where there are significant ecological/environmental reasons for doing so. In the public realm, while lighting can increase the perception of safety and security, measurable benefits can be subjective. A lighting scheme for the Site should be produced based on advice given in Bats and artificial lighting in the UK3. The guidance sets out five steps to mitigating impacts on bats from lighting: Determine whether bats could be present on site. Determine the presence of - or potential for - roosts, commuting habitat and foraging habitat and evaluate their importance. Avoid lighting on key habitats and features altogether. ## Favourable Conservation Status It is my opinion that the outline mitigation/compensation given above would be sufficient for the Favourable Conservation Status (FCS) of bats (as per the reasonable worst-case scenario) to be maintained. The details of the mitigation proposals draw directly from our experience of successful EPSL applications elsewhere and our detailed knowledge of bat ecology and roosting requirements. ## Birds Birds may nest within the building. Appropriate and pragmatic measures will be taken to avoid committing the offence of killing or injuring a wild bird or damaging or destroying its nest. Any operations that may disturb nesting habitat, such as demolition, will be undertaken outside the main breeding season (which is generally taken to run from March to August inclusive4). An alternative approach would be to check for nesting birds immediately prior to habitat removal by a suitably experienced ecologist. However, if the latter approach is taken and nesting is encountered there is a risk of delay since an 'exclusion zone' may need to be set up around nests until young have fledged. ## 4.4 Ecological Opportunities Under the National Planning Policy Framework and the 25-year environmental plan the government has set out policies and aims to deliver a net gain in biodiversity through improved green infrastructure and increased opportunities for wildlife. In accordance with these policies enhancement measures are recommended for inclusion in the proposed development. Enhancement measures should go beyond those required for mitigation and will create new opportunities for biodiversity at the Site. For enhancement of the proposed development it is recommended that there is the provision of roosting and nesting habitat for birds and bats in the form of wildlife boxes. At least one bat box could be integrated into the façade and one into the soffit boxes of the building. These would be installed at a minimum height of 4 m and should be south or east facing. At least two bird boxes should be integrated into the façade of the proposed building. These would be installed at a minimum height of 3 m and can be integrated into the facades on any compass direction. Examples of wildlife boxes are presented in Appendix 4. ## Legislation There are many active pieces of legislation which are aimed at protecting wildlife and habitats within the UK. These are summarised in Table 2. ## Table 2 - Summary Of Primary Legislation In The Uk | Legislation | Description | |-------------------------------------------------------------------------------------------------------|----------------| | The Wildlife | | | and | | | Countryside | | | Act | (WCA) | | 1981 | | | The WCA is the primary piece of legislation relating to nature conservation in Great Britain. The | | | Act is supplemented by provisions in the CRoW Act 2000 and the NERC Act 2006. It provides for | | | the notification and confirmation of Sites of Special Scientific Interest by Natural England. It also | | | sets out, in schedules, important and invasive species which are legally protected or require active | | | management. | | | | | | The WCA consolidates and amends existing national legislation to implement the Convention on | | | the Conservation of European Wildlife and Natural Habitats (Bern Convention) and Council | | | Directive 79/409/EEC on the conservation of wild birds (Birds Directive) in Great Britain (NB | | | Council Directive 79/409/EEC has now been replaced by Directive 2009/147/EC of the European | | | Parliament and of the Council of 30 November 2009 on the conservation of wild birds (codified | | | version)). | | | The | | | Conservation | | | of | Habitats | | and Species | | | Regulations | | | 2017 | | | The Conservation of Habitats and Species Regulations 2017 consolidate the Conservation of | | | Habitats and Species Regulations 2010 with subsequent amendments. The Regulations transpose | | | Council Directive 92/43/EEC, on the conservation of natural habitats and of wild fauna and flora | | | (EC Habitats Directive), into national law. They also transpose elements of the EU Wild Birds | | | Directive in England and Wales. The Regulations came into force on 30 | | | th | | | November 2017 and | | | extend to England and Wales (including the adjacent territorial sea) and to a limited extent in | | | Scotland (reserved matters) and Northern Ireland (excepted matters). | | | The | | | Countryside | | | and Rights of | | | Way (CRoW) | | | Act 2000 | | | The CRoW applies to England and Wales only, received Royal Assent on 30 November 2000, with | | | the provisions it contains being brought into force in incremental steps over subsequent years. | | | Containing five Parts and 16 Schedules, the Act provides for public access on foot to certain types | | | of land, amends the law relating to public rights of way, increases measures for the management | | | and protection for Sites of Special Scientific Interest (SSSI) and strengthens wildlife enforcement | | | legislation, and provides for better management of Areas of Outstanding Natural Beauty (AONB). | | | The Act is compliant with the provisions of the European Convention on Human Rights, requiring | | | consultation where the rights of the individual may be affected by these measures. | | Natural Environment & Rural Communities (NERC) Act 2006 The NERC places a duty on authorities to have due regard for biodiversity and nature conservation during the course of their operations. The NERC Act requires the Secretary of State to publish a list of habitats and species which are of principal importance for the conservation of biodiversity in England. The list replaces the UK Biodiversity Action Pans (UKBAP) and has been drawn up in consultation with Natural England, as required by the Act. The S41 list is used to guide decision-makers such as public bodies, including local and regional authorities, in implementing their duty under section 40 of NERC Act, to have regard to the conservation of biodiversity in England, when carrying out their normal functions. Fifty-six habitats of principal importance (HPI) are included on the S41 list. These are all the habitats in England that were identified as requiring action in the UK Biodiversity Action Plan (UK BAP) and continue to be regarded as conservation priorities in the subsequent UK Post-2010 Biodiversity Framework. Of most relevance to the Site, they include ponds, open mosaic habitats on previously developed land and lowland heathland. There are 943 species of principal importance (SPI) included on the S41 list. These are the species found in England which were identified as requiring action under the UK BAP and which continue to be regarded as conservation priorities under the UK Post-2010 Biodiversity Framework. ## European Protected Species Licencing The animal and plant species listed on Schedule 2 and 4 of The Conservation of Habitats and Species Regulations 2010 (as amended) are referred to as European Protected Species (EPS). If a project is likely to impact a EPS and breach the Conservation of Habitats and Species Regulations 2010, and where best practice guidance avoidance measures either cannot be followed or are not applicable, licences can be obtained to allow persons to carry out activities that would otherwise be prohibited, without committing an offence. Natural England has powers to grant such licences in England if it meets three 'derogation tests'. The three tests are that: The activity to be licensed must be for imperative reasons of overriding public interest5 or for public health and safety ('public' can in some circumstances be interpreted as an individual or family). There must be no satisfactory alternative. Favourable conservation status of the species must be maintained. There are two licencing routes available (depending on the location of the project). A Project Licence, where the developer would apply for a licence for their project and be the licensee, or a District Licence, where a third party (a Natural England or a Local Authority) is already a licensee and grants permission for the development to be undertaken under their licence. ## Project Licence The licence application consists of three documents, Section one - Application details (a basic application form), Section two - Method Statement (MS) (specifying the proposals, mitigation, compensation and schedule and demonstrating how the project meets Test 3) and Section three - Reasoned Statement (RS) (demonstrating how the project meets Tests 1 and 2). The Application form and Method Statement are usually completed by your ecologist (who is included in the application as a Named Ecologist) and the Reasoned Statement by the client or their planning consultant or environmental lawyer. The developer is usually the applicant and licensee and is legally responsible to carrying out the method statement. In order to protect other people working on the project (and also to legally tie them to the MS) contractors and consultants that may affect the EPS, such as demolition or construction contractors and the ecologist should be appointed as 'accredited agents' to the licence by the licensee. Natural England aim to determine an application within 30 working days, at which point they make a Further Information Request (FIR) if there are uncertainties or they do not agree with the MS or RS. At the end of the licensable activities the licensee is required to submit a licence return (although this is usually completed on their behalf by the Named Ecologist), where they declare the success (or failure) of the mitigation and are obliged to report on breaches to the MS. ## District Licence District Licencing is a relatively new approach to licencing projects which impact great crested newts in the UK (and may be rolled out to other protected species). There are currently three schemes, which are being managed slightly differently. In each scheme a third party holds the district level licence and a developer applies to join the licence: - Cheshire and Kent, licensed and managed by Natural England, - Woking Borough, licensed and managed by the local authority, - South Midlands, licensed by the local authorities and managed by NatureSpace. - Central Bedfordshire, Bedford Borough, Milton Keynes, Aylesbury Vale, South Oxfordshire, Vale of the White Horse, Oxford City. The developer pays the licensee, (or their agent in the case of the South Midlands District License) a fee, which funds off-site compensatory habitat creation. There is a first stage payment, which covers costs of assessing the application, and a second stage payment which funds the compensation works. District licences do not need to be supported by survey information on local ponds (although this can help inform the licence) and on-site mitigation or compensation is typically reduced compared to an individual project licence. ## Bct Roost Assessment Criteria | Suitability | Description of Roosting Habitats | Commuting and Foraging Habitats | |---------------------------------------------------|--------------------------------------------------|------------------------------------| | Negligible | Negligible habitat features on site likely to be | | | used roosting bats. | | | | Low | A structure with one or more potential roost | | | sites that could be used by individual bats | | | | opportunistically. | | | | However, these potential roost sites do not | | | | provide enough space, shelter, protection, | | | | appropriate | conditions | and/or | | surrounding habitat to be used on a regular | | | | basis or by larger numbers of bats (i.e. unlikely | | | | be suitable for maternity or hibernation). | | | | A tree of sufficient size and age to contain | | | | PRFs but none seen from the ground or | | | | features seen with only very limited roosting | | | | potential. | | | | Moderate | | | | | | | | A structure or tree with one or more potential | | | | roost sites that could be used by bats due to | | | | their size, shelter, protection, conditions, and | | | | surrounding habitat, but unlikely to support a | | | | roost of high conservation status6. | | | | High | A structure or tree with one or more potential | | | roost sites that are obviously suitable for use | | | | by larger numbers of bats on a more regular | | | | basis and potentially for longer periods of | | | | time due to their size, shelter, protection, | | | | conditions and surrounding habitat. | | | | A structure or tree with one or more potential | | | | roost sites that are obviously suitable for use | | | | by larger numbers of bats on a more regular | | | | basis and potentially for longer periods of | | | | time due to their size, shelter, protection, | | | | conditions' and surrounding habitat. | | | Negligible habitat features on site likely to be used by commuting or foraging bats. Habitat that could be used by small numbers of commuting bats such as a gappy hedgerow or un-vegetated stream, but isolated, i.e. not very well connected to the surrounding landscape by another habitat. Suitable, but isolated habitat that could be used by small numbers of foraging bats such as a lone tree (not in a parkland situation) or a patch of scrub. Continuous habitat connected with the wider landscape that could be used by bats for commuting such as lines of trees and scrub or linked back gardens. Habitat that is connected to the wider landscape that could be used by bats for foraging such as trees, scrub, grassland, or water. Continuous, high-quality habitat that is well connected to the wider landscape that is likely to be used regularly by commuting bats such as river valleys, streams, hedgerows, lines of trees and woodland edge. High-quality habitat that is well connected to the wider landscape that is likely to be used regularly by foraging bats such as broadleaved woodland, tree-lined watercourses, and grazed parkland. Site is close to and connected to known roosts. ## National Planning Policy Framework (Nppf) (2018) Chapter 15 of the National Planning Policy Framework (NPPF) aims at conserving and enhancing the natural environment and states that planning policies and decision should contribute to and enhance the natural and local environment. In terms of biodiversity this should be achieved by: - protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils - recognising the intrinsic character and beauty of the countryside, and wider benefits from natural capital and ecosystem services - minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures The NPPF states that to protect and enhanced biodiversity, [local] plans should: - identify and safeguard components of wildlife-rich habitats and wider ecological networks - promote the conservation and enhancement of priority habitats and ecological networks and the protection and recovery of priority species The NPPF states that when determining planning applications, local planning authorities should refuse applications which: - cause significant harm to biodiversity which cannot be avoided, adequately mitigated or as a last resort, compensated for - plan to develop on land within or outside of a Site of Special Scientific Interest (SSSI) and which is likely to have an adverse effect on it (either individually or in combination with other developments) - result in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees), unless there are wholly exceptional reasons and where a suitable compensation strategy exists The local planning authority should support developments whose primary objective is to conserve or enhance biodiversity, especially where this can secure measurable net gains in biodiversity. ## Hm Government - 25 Year Environment Plan The 25-year plan to improve the environment sets out what the government intends to do to increase biodiversity, reduce climate change and secure ecosystem services. It aims to deliver cleaner air and water, protect threatened species, and provide richer wildlife habitats. ## Appendix 2 Photos ## Appendix 4 Enhancement, Compensation, Mitigation Schwegler Bat Tube The 1FR Bat Tube is designed to be installed on the external walls of buildings, either flush or beneath a rendered surface. It can also be painted to match your building with an air permeable paint if desired. Comprised of Woodcrete with integrated wooden panel. Dimensions: 200mm wide x 470mm high x 120 mm deep Entrance Dimensions: 150 x 90 x 20 mm Weight: Approximately 9.8 kg ## Habibat Integrated Bat Box These boxes can be built into the walls of new buildings to create purpose-built crevices for bats. Facing products include: a. Brick b. Stone c. Granite d. Masonry e. Slate f. Terracotta g. Tile h. Timber Dimensions: 215 mm wide x 440 mm high x 102 mm deep Weight: Approximately 7 kg ## Habibat Bat Access Slate The Habibat Bat Access Slate has been designed to fit seamlessly to slate roofs. The Bat Access Slate consists of a standard sized slate, with a capped vent which allows access to roof felt or roof space. Habibat can supply a standard slate, but also provide a service whereby an exact match can be achieved. Dimensions: 375 mm wide x 418 mm high x 80 mm deep Entrance Hole Dimensions: 100 m wide x 200 mm high Weight: Approximately 1.3 kg ## Schwegler Brick Nest Box Type 24 - Small Birds A brick bird nest box comprised of a wood and concrete blend. The dimensions of the box allow for 1 cm layer of mortar enabling the boxes to be inserted into any new wall without needing to cut adjoining bricks. The box can be flush with the wall and rendered so that only the entrance hole is visible. This model features an upright box with removeable entrance hole at the top. With an entrance hole diameter of 32mm, this box is suitable for many small birds including great, blue, marsh, coal and crested tits, redstarts, nuthatch, tree, and house sparrows. Dimensions: 180 mm wide x 230 mm high x 180 mm deep Weight: Approximately 7.3 kg ## Schwegler Brick Nest Box 26 - Open Fronted Nest Box A brick bird nest box comprised of a wood and concrete blend. The dimensions of the box allow for 1 cm layer of mortar enabling the boxes to be inserted into any new wall without needing to cut adjoining bricks. The box can be flush with the wall and rendered so that only the entrance hole is visible. Features an upright box with large open front. With a large open hole (110 x 80mm), this box will attract species that use open-fronted nest boxes, such as redstart, pied wagtail, spotted flycatchers and sometimes robin. Dimensions: 980 mm wide x 980 mm high x 180 mm deep. Weight: Approximately 5.4 kg www.ecology-surveyor.co.uk www.bat-surveyor.co.uk Fast bat surveys in Derbyshire, Nottinghamshire, and Staffordshire. A trading name of Jo Pedder, a freelance ecologist based in Belper, Derbyshire.
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## Letters From The First World War, 1915 These Are Some Of The Many Letters Sent By Staff Of The Great Western These are some of the many letters sent by staff of the Great Western Railway Audit office at Paddington who had enlisted to fight in the First World War. Here you will find all the letters and transcripts from this collection that relate to the soldiers' experience of training in England before they were sent abroad. ## 1915, Training: Contents Training: 'do you like the photo?' .............................................................................................. 2 Training: 'drill before breakfast' ................................................................................................. 3 Training: 'no signs of moving' ..................................................................................................... 6 Training: 'We are now fully equipped' ..................................................................................... 7 ## Training: 'Do You Like The Photo?' Harold George Giles, 17 May 1915, Churn Camp, Oxford, England. **Born:** 18 May 1898, **Joined GWR:** 7 August 1912, Joined up for service: 19 March 1915, **Regiment:** Royal Bucks Hussars, Regiment number:2125; 205745, **Rank:** Private, **Retired:** Resigned from Audit office on 9 May 1920 ## Transcript Dear Mr Jones Just a line to let you know that I'm still alive and am moving to King's Lynn on Wednesday next. Will write you later. How do you like the photo? Best regards to the office. From, H. Giles ## Training: 'Drill Before Breakfast' Arthur Smith, 4 April 1915, France. **Born:** 8 March 1895, **Regiment:** Railway Troop, Royal Engineers, Regiment number: 87760, **Rank:** Lance Corporal ## Transcript Dear Sir, I have now been out in France a fortnight. I am getting on quite well in the army. Food is also good and plentiful. Of course, I find the life much rougher from that which I have been used to, but it is a fine experience all the same. We were at Longmoor camp for a week where we were equipped and put through elementary drills. We slept in a big hut there and had a sack of straw and three blankets each. The huts, of which ours was one, were called Apple Pie and they are about a mile from the camp, so we had to be up about six every morning in order to march down for parade at the camp. The parade was at 7.15am. Some mornings we had an hour's drill before breakfast. It was about 11pm I should think, when we arrived at Longmoor on 31st March, and consequently we went straight to our hut. No light was provided so we had to fish about for our beds in the dark. Fortunately it was moonlight, and after some time a lantern was brought. We were only too glad when getting up time came the next morning. It was before six. We were marched down to the camp and were inspected by the Sergeant Major and after waiting some time went into breakfast. Roast sausage was the chief item on the menu but to our amazement no knives and forks were supplied for us…Well, the only thing was to convey the sausages to our mouths with fingers. The nearest thing to a knife and fork that some had was a pair of nail scissors so these were used. Personally I did not know whether to feel shocked or to laugh at the situation; it ended in the latter. We Audit fellows got to one table and we had to have a good laugh before we could eat much. It was a hopeless situation to be in. Don't let this discourage anyone from coming but I warn him to bring a knife and fork with him. After the first day we were issued with kits and we treasure our knives and forks now. We came across on the mail boat *Hantonia* from Southampton to Havre. … We had to sleep in huts there on the docks but the sleeping accommodation was better. We Audit fellows were able to keep together till last Saturday night, when Pond and I were sent off to different railheads. He is at 3rd Corps Railhead. We had to travel in horseboxes and during night time. We travelled in this manner Saturday, Sunday and Monday nights. French shunting is severe and we were shaken up. Saturday and Sunday we were about 30 in the trucks, Monday 17. We were fortunate enough to get out into every town at which we stopped during the day. On Tuesday night another young fellow and I were stranded at a station somewhere in France, and we were instructed by the military authorities to sleep in the goods shed. We had to sleep on the deck of the shed and shunting was going on during the night. This was about the limit, I thought. I arrived finally at my destination about midday last Wednesday. Now I live in a truck at a small French station. There are two other Sappers and a Lieutenant here. We deal chiefly with gifts and comforts sent to the troops… We are out in the country. I think this railhead is about seven miles from the firing line. Can hear the guns and see the star shells at night. I must ask you kindly to excuse me for writing in pencil because I have no pen and ink here. Would you mind letting this letter be treated as to the whole of the statistical department, please sir. With kindest regards to all. I am yours obediently, Arthur Smith ## Training: 'No Signs Of Moving' Sidney Broad Hodges, 30 December 1915, Longmoor, England. **Born:** 7 January 1884, **Regiment:** Royal Engineers, Railway Troop, Regiment number: 138032, **Rank:** Sapper, **Died:** 1956 ## Transcript I might say we are all merry and bright and not down hearted yet. Dear Mr Hunt, Received card alright for which I must thank you very much. We are still at Longmoor and no signs of moving as I have been made cook's mate and had to work very hard all through Xmas. Sapper Hodges ## Training: 'We Are Now Fully Equipped' Nicholas Boyce, 9 November 1915, Longmoor Camp, England. **Born:** 21 October 1879, **Joined GWR:** 10 February 1896, **Regiment:** Railway Troop, Royal Engineers, **Regiment number:** 138015, **Rank:** Sapper, Retired: October 1939 ## Transcript Dear Lack, Many thanks for the photographs received. We all think they are good and on Saturday the six of us had out photo taken here in a similar position– in khaki. The two pictures together should make a lasting memento. We have had little spare time since we have been training here. Having been through company drill mixed with route marches, physical drill, semaphore, knot tying and frog, long jumping etc. Some of our men were able to go to town on Saturday… but I myself with a few others have been under orders for overseas service now waiting to proceed, so popping up town seems out of the question for us. We are numbered in alphabetical order, and in the order we are sent out. We are now fully equipped. I enclose … postage for the photographs. If you are printing any more you might save me one as I am afraid I have spoilt mine, it got bent in my overcoat pocket on Saturday. Please remember me to all at the office… N. Boyce
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Open Data Institute 3rd Floor, 65 Clifton Street, London EC2A 4JE    Friday 10th May ‐ 09:30 to 11:30pm    ## Agenda 1. Welcome and introductions      (Chair ‐ 5 mins)  2.  Action Points from the previous meeting  (Chair‐ 10 mins)  3. Presentation by the Open Data Institute  (ODI Management Team – 20 mins)  4. HMRC's Legal Framework      (Cindy Bell ‐ 15 mins)    5. The criteria to be used, when considering  (All ‐ 40 mins)  data requests    6. Sub UK Geography and Geodemography  (Bill Elmore ‐ 20 mins)    7. Summary and AOB   (Chair ‐ 10 mins) th
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## Synopsis Of Causation ## Personality Disorder Author: Dr David M B Christmas, University of Dundee, Ninewells Validator: Dr Jonathan Bisson, Senior Lecturer in Psychiatry, University Hospital of Wales, Cardiff September 2008 ## Disclaimer This synopsis has been completed by medical practitioners. It is based on a literature search at the standard of a textbook of medicine and generalist review articles. It is not intended to be a metaanalysis of the literature on the condition specified. Every effort has been taken to ensure that the information contained in the synopsis is accurate and consistent with current knowledge and practice and to do this the synopsis has been subject to an external validation process by consultants in a relevant specialty nominated by the Royal Society of Medicine. The Ministry of Defence accepts full responsibility for the contents of this synopsis, and for any claims for loss, damage or injury arising from the use of this synopsis by the Ministry of Defence. ## 1. Definition 1.1. Overview. The classification of personality and the diagnosis of personality disorders has been a contentious subject for many years. Whereas most mental disorders represent an alteration in the normal functioning of an individual (an abnormal "state"), personality disorders represent exaggerations of "traits" that are frequently present in the normal population. However, despite the difficulties that have arisen in classification, specific patterns of personality dysfunction appear to occur among certain people. 1.1.1. A significant minority of patients with mental health problems will be found to have comorbid personality disorder. Indeed, it can often be difficult to differentiate someone's premorbid personality traits from the effects of illness. For example, a depressed patient may seem morose, humourless, withdrawn, and irritable. Enduring mental illness from the late teens (e.g. psychotic illnesses or mood disorders) has the potential to affect an individual's personal and social development, frequently causing diagnostic difficulties. As a general rule, abnormal mental states represent a change from normal, but personality disorders are enduring and consistent patterns. 1.1.2. The diagnosis of personality disorder is fraught with procedural and classification difficulties.1 One criticism of the concept as a whole has been that the collections of symptoms and behaviours thus described do not appear to fit easily into a disease framework. Certainly, there is no consistent model which explains the variety of supposed disorders of personality. From a practical point of view, the standard methods of assessment (such as structured interview and self-report questionnaire) have low consistency.2 Furthermore, it is a frequent observation that the diagnosis of personality disorder is often made pejoratively.3 ## 1.2. Normal Personality Development 1.2.1 Psychodynamic theories. Sigmund Freud believed that the personality has three main components: the ego, the id, and the *superego*. The id is totally unconscious and is made up of the basic inborn drives, and the sexual and aggressive impulses. The superego is the moral structure of personality and consists of conscience and ideals which are derived through the internalisation of parental or other authority figures. Freud believed that the superego is involved in the experience of guilt, perfectionism, indecision, and preoccupation with right or wrong. He argued that it was responsible for depression, obsessional disorders and sexual problems. The ego is the conscious part of the whole and uses reason to maintain a sense of reality. It is responsible for the control and regulation of instinctual drives. In essence, Freud thought that our early childhood experiences were too threatening to be dealt with consciously and that via a variety of defence mechanisms (the main one being repression) we can reduce the anxiety of this conflict. Freud's theories have been developed and modified over the last hundred years or so by a variety of analysts but key concepts such as conscious and unconscious, and instinctual drives have persisted in common usage. 1.2.2 Trait theories. All trait theories make 3 assumptions. Firstly, traits are stable across time and, therefore, predictable. Secondly, traits are stable across different situations and can explain why people act in predictable ways in different settings. Finally, that individuals differ in how much of a particular trait they possess, resulting in an infinite variety of unique personalities. One of the first prominent trait theories was developed by Raymond Cattell in 1965. He used factor analysis to calculate the degree to which various personality traits correlated with each other. He identified 16 "factors", such as shy versus bold and trusting versus suspicious, which he proposed are present in everyone. Hans Eysenck used a dimensional approach to the categorisation of personality. He argued that personality can be described along 3 dimensions: psychoticism (consisting of cruelty, hostility, oddness); introversion-extraversion; and emotionality-stability, also known as neuroticism (characteristics such as worry, anxiety, and moodiness). His theories predicted that criminals tended to be emotional and extraverted, whilst anxious people score highly on emotionality and introversion. One of the most robust trait theories is the "Big Five" model. Factor analysis has reduced the number of factors down to 5. The 5 factors are: openness to experience, conscientiousness, extraversion, agreeableness, and neuroticism. Studies have demonstrated that these factors are present in a variety of different cultures from around the world. 1.2.3 Social learning theories. These view personality as the sum of all the cognitive and behavioural habits that individuals develop through learning from experience in the world. Social learning theorists argue that their approach provides a high degree of predictability of most people's behaviour in a variety of situations. ## 1.3. Common Approaches To The Diagnosis Of Personality Disorder 1.3.1 The European and American classification of psychiatric disorders, i.e. the International Classification of Diseases 10 (ICD-10)4 and the Diagnostic and Statistical Manual IV (DSM-IV)5 respectively, differ slightly in their classification of personality disorders. Both systems are, however, nonaetiological classification systems; individual disorders are based on collections of symptoms rather than on distinct disease processes. 1.3.2 Personality disorder in both systems is characterised by the presence of abnormal traits which are maladaptive and which result in persistent dysfunction and/or personal distress in a number of areas, including social relationships, employment, self-image, and interpretation of the world. 1.3.3 ICD-10 identifies 9 main types of personality disorder, which are discussed later in more detail. The ICD-10 does not offer definitions of key terms or guidance on the extent to which a trait should be present in order to make a diagnosis. For example, it does not define "long duration" and does not indicate when "late childhood or adolescence" can be considered to start or end. 1.3.4 One of the key differences between ICD-10 and DSM-IV is the multi-axial approach of the US classification. Mental illness is classified on the first axis, whilst personality disorder, if present, is classified on the second axis. Axes III- V cover physical illness, social stressors, and level of functioning. 1.3.5 The DSM-IV organises personality disorders into one of three "clusters" which contain disorders that share similar groups of symptoms and personality dysfunction. Like the ICD-10, there are no definitions of key terms to assist in assigning the person to the appropriate cluster. - Cluster A (odd/eccentric). This cluster contains paranoid personality disorder, schizoid personality disorder, and schizotypal personality disorder - Cluster B (dramatic/emotional/impulsive). This group consists of antisocial personality disorder, borderline personality disorder, histrionic personality disorder, and narcissistic personality disorder - Cluster C (anxious/fearful). This cluster contains avoidant personality disorder, dependent personality disorder, and obsessive-compulsive (anankastic) personality disorder 1.3.6 In terms of diagnostic criteria, for some personality disorders (histrionic, dissocial, and anxious/avoidant), ICD-10 has a slightly higher threshold, requiring more criteria to be met for diagnosis. It should also be noted that although most people with personality disorder will fit one specific type, some people with personality disorder have features of several different types. ## 1.4. Icd-10 Criteria For Personality Disorder4 1.4.1 There is evidence that the individual's characteristic and enduring patterns of inner experience and behaviour as a whole deviate markedly from the culturally expected and accepted range. Such deviations must be manifest in more than one of the following areas: - Cognition (i.e. ways of perceiving and interpreting things, people and events, forming attitudes, and images of self and others) - Affectivity (range, intensity and appropriateness of emotional arousal and response) Control over impulses and gratification of needs - Manner of relating to others and of handling interpersonal situations - 1.4.2 The deviation must manifest itself pervasively as behaviour that is inflexible, maladaptive, or otherwise dysfunctional across a broad range of personal and social situations. 1.4.3 There is personal distress or adverse impact on the social environment, or both. 1.4.4 There must be evidence that the deviation is stable and of long duration, having its onset in late childhood or adolescence. 1.4.5 The deviation cannot be explained as a manifestation or consequence of other adult mental disorders. 1.4.6 Organic brain disease, injury, or dysfunction must be excluded as the possible cause of the deviation. ## 1.5. Dsm-Iv Criteria For Personality Disorder 1.5.1 An enduring pattern of inner experience and behaviour that deviates markedly from the expectations of the individual's culture. This pattern is manifested in 2 (or more) of the following areas: - Cognition (i.e. ways of perceiving and interpreting self, other people, and events) - Affectivity (i.e. the range, intensity, lability, and appropriateness of emotional response) Interpersonal functioning - Impulse control - 1.5.2 The enduring pattern is inflexible and pervasive across a broad range of personal and social situations. 1.5.3 The enduring pattern leads to clinically significant distress or impairment in social, occupational, or other important areas of functioning. 1.5.4 The pattern is stable and of long duration and its onset can be traced back at least to adolescence or early adulthood. 1.5.5 The enduring pattern is not better accounted for as a manifestation or consequence of another mental disorder. 1.5.6 The enduring pattern is not due to the direct physiological effects of a substance (e.g. a drug of abuse, a medication) or a general medical condition (e.g. head trauma). ## 2. Clinical Features 2.1. For each of the disorders below, the cardinal features required for diagnosis using ICD- 10 are italicised under the heading "clinical features". Typically, 3-4 of these features should be present along with the core features of personality disorder described above. 2.2. General 2.2.1 Epidemiology. Most studies show relatively consistent rates of personality disorders within the general population and among specific groups of individuals. Among community samples the prevalence rate of DSM-IV disorders is approximately 9%, with lower rates (5.1%) for ICD-10 disorders.6 The prevalence of all personality disorders is raised in psychiatric patients and, among community mental health teams, the rates of comorbid personality disorder in patients with a psychotic illness may be as high as 92%.7 2.3 Paranoid personality disorder 2.3.1 Epidemiology. 0.7% of the general population has this disorder which is found in 4 times as many men than women.8 2.3.2 Clinical features (4 should be present). People with paranoid personality disorder tend to be overly *suspicious*, and misconstrue the neutral intentions of others as being hostile or threatening. They are *mistrustful*, interpreting events as being conspiratorial. They are *sensitive* to setbacks, and have a tendency to bear grudges. They are typically *argumentative* and their sense of personal rights is out of keeping with the situation. Their relationships are characterised by *jealousy*, repeatedly doubting the sexual fidelity of their partner. Most patients are *self-centred*, with a self-referential and self-important outlook. ## 2.4 Schizoid Personality Disorder 2.4.1 Epidemiology. Approximately 1% of the UK population has schizoid personality disorder.8 It is more common in men than women. 2.4.2 Clinical features (4 should be present). These individuals are *humourless*, with few activities providing pleasure. They are seen by others as "loners", tending to be *emotionally cold*, with little expression of emotion. Indeed, they tend to be detached - having limited ability to express warmth, tenderness, or even anger towards other people. In social situations, they appear *indifferent* to praise or criticism. Their activities are *solitary* and they are *loveless*, showing minimal interest in having sexual relationships with other people. They have no desire for close friendships and most appear to be *friendless*. Many schizoid people are introspective, and preoccupied by fantasy. In keeping with their indifference to social relationships, they often appear to be *unconventional*, showing little sensitivity to social norms and conventions. ## 2.5 Dissocial Personality Disorder 2.5.1 Epidemiology. Dissocial personality disorder is much commoner in men than women with up to 3-5% of men in the general population having the disorder.6 Higher rates are found in younger adults, urban populations, the prison population, substance misuse programmes, and lower socio-economic groups. 2.5.2 Clinical features (3 should be present). The outdated name for people with this disorder was "psychopath". The disorder is characterised by a *callous* unconcern for other people's feelings. Individuals with antisocial PD tend to ignore social norms, behaviours, and rules. They are typically in trouble with the police. They have a *low tolerance to frustration* and will frequently resort to aggression and violence. Frequently presenting as being charming, they have no difficulty in establishing relationships, but have difficulty in maintaining them, resulting in *short relationships*. They display a *lack of guilt*, failing to respond to adverse experience such as punishment, and they tend to *blame others* for their behaviour. ## 2.6 Emotionally Unstable Personality Disorder (Borderline Personality Disorder) 2.6.1 Epidemiology. This disorder is present in approximately 1% of the general population.8 Three quarters of people with borderline personality disorder are women. 2.6.2 Clinical features (5 should be present). Individuals with borderline personality disorder tend to have unstable and *capricious* moods, combined with chronic feelings of emptiness. They have *poor self-image*, with longstanding disturbances of self-image, including sexual preference. They tend to have relationship crises, with a pattern of intense and unstable relationships. Most people with borderline personality disorder can be *unpredictable*, acting impulsively without thinking of the consequences. If others tend to criticise such impulsive acts, they can become *quarrelsome*. At times, their behaviour can be *explosive*, with an inability to control the outbursts of anger or violence. In the longer term, they are desultory - having difficulty in continuing courses of action which do not have immediate reward. Such individuals have a fear of abandonment, making excessive efforts to avoid being abandoned. *Self-harm* (either threats or acts) is common. ## 2.7 Histrionic Personality Disorder 2.7.1 Epidemiology. Histrionic personality disorder is estimated to be present in 2- 3% of the general population. It is more common in women than men. 2.7.2 Clinical features (4 should be present). Individuals with histrionic personality disorder are characteristically *dramatic*, with theatrical or exaggerated displays of emotion. Their prevailing mood is typically *shallow and labile*, and they are stimulus seeking - constantly trying to be the centre of attention. They may appear to live in a fantasy world, often becoming bored with routine. Such people tend to be *suggestible*, easily influenced by other people or by the circumstances. Their behaviour may be flirtatious or *seductive* at times but they are emotionally shallow. Individuals are often *vain*, and overly concerned about their attractiveness. ## 2.8 Anankastic Personality Disorder 2.8.1 Epidemiology. About 2% of the general population has obsessive-compulsive personality disorder with twice as many men than women having this disorder.8 Rates are higher in those with anxiety and depressive disorders. 2.8.2 Clinical features (4 should be present). Such individuals are excessively cautious, expressing doubt about most of their activities. They are obsessed by orderliness, and are preoccupied with rules, lists, order, and organisation. They are *conscientious*, but this conscientiousness is excessive. They are typically perfectionist in what they do, but such perfectionism interferes with the completion of tasks and activities. Indeed, their *preoccupation with productivity* excludes other pleasurable activities and social relationships. They can also be pedantic and *rigid*, appearing stubborn in their manner and beliefs. They will often adhere excessively to social conventions, and may be reluctant to allow others to do things their way. Such people find it difficult to relax and may appear to be 'workaholics'. Because of their stiffness and formality, they may have problems in the workplace or in interpersonal relationships. ## 2.9 Anxious (Avoidant) Personality Disorder 2.9.1 Epidemiology. Among the general population, 0.5-1% of people has this disorder. 2.9.2 Clinical features (4 should be present). People with anxious personality disorder exhibit a high degree of *anxiety*, feeling tense and apprehensive in most situations. They are preoccupied with being criticised or rejected in social situations. Often they will *feel inferior*, unattractive, or socially inept. As a result, they will frequently *avoid social* or occupational situations which involve personal contact for fear of criticism or *fear of rejection*. They are often afraid to trust people, and will avoid social contact unless they are certain of being liked. Due to their anxiety and need for physical security, they tend to lead a restricted lifestyle. These people may also have features of dependent personality disorder and many will meet criteria for social phobia. ## 2.10 Dependent Personality Disorder 2.10.1 **Epidemiology.** The prevalence in the general population tends to be lower than other personality disorders, with rates typically being lower than 0.5%. 2.10.2 **Clinical features** (4 should be present). People with dependent personality disorder are *dependent on others for* making most of life's decisions. They need reassurance and cannot make decisions without excessive amounts of advice and reassurance from others. They will *subordinate* their own needs to those that they are dependent on, and will be very compliant with their wishes. They are *undemanding*, finding it difficult to make demands on the people that they depend on. They have *a fear of not coping*, and when left alone they feel helpless because they fear that they cannot look after themselves. Typically, they will have problems questioning authority, and ask others for guidance. ## 3. Aetiology 3.1. Introduction 3.1.1. The aetiology of personality disorder is largely unknown. Indeed, whilst certain associations have been described between specific life experiences and later personality disorder(s), the mechanism by which this influences behaviour is not known. Similarly, the development of most personality disorders is believed to have a genetic component, but the precise mechanism of interaction between a genetic predisposition and later experience is yet poorly understood. 3.1.2. Most theories of abnormal personality development reflect psychodynamic theories of the self. Such theories focus on early childhood experiences and how these affect the development of a person's relationships with the world and other people. Most psychodynamic theories relate to early life (typically childhood) and such theories predicate that the effects of adverse experience as a teenager will be very different to that of an infant. There is no evidence that adverse experience in an individual over the age of 16 can cause personality disorder by itself. Indeed, in most cases there is evidence of disturbance of functioning prior to this, and such a diagnosis would be extremely rare in someone with normal personality functioning prior to the late teens. 3.1.3. It should be noted that most personality disorders research is conducted on relatively small numbers of patients, and it is difficult to confidently extrapolate findings to all cases of personality disorder. ## 3.2. Paranoid Personality Disorder 3.2.1. Some have found that the incidence of schizophrenia-like personality disorders is higher in first-degree relatives of those with schizophrenia.9 The nature of this link is not established. Others have proposed that deficits in childhood care might account for the development of paranoia and hostility in adulthood, but such ideas are largely theoretical and unsupported by evidence. 3.2.2. Other theories suggest that abnormalities of the dopaminergic system in the brain (which shows abnormalities in schizophrenia) may account for dysfunctional patterns of thinking which are reflected in distorted interpretations of the world.10 ## 3.3. Schizoid Personality Disorder 3.3.1. The dopaminergic system in the brain is involved with behavioural adaptation to rewarding stimuli. Associations have been reported with polymorphisms of the dopamine D2 receptor and schizoid/avoidant behaviours,11 suggesting that common abnormalities of dopamine function may contribute to disorders on the schizophrenic spectrum. Such findings have yet to be replicated by other genetic studies and remain associations only. ## 3.4. Dissocial Personality Disorder 3.4.1. The causes of this disorder, as other personality disorders, are likely to involve a complex interaction between genetic influences, developmental factors, and social behaviour. 3.4.2. Family studies would support a genetic component to antisocial behaviour, with twins sharing a greater number of antisocial characteristics.12 This, together with similar findings from adoption studies, supports the view that genetic factors account for some degree of antisocial behaviour.13,14 3.4.3. Reduced central serotonergic activity has been associated with impulsive aggression in a subset of patients with personality disorder.15 A common finding in other studies supports a relationship between violent suicide attempts and low metabolites of serotonin in the cerebrospinal fluid.16 However, the evidence would not support the conclusion that serotonergic abnormalities underlie antisocial behaviour in all cases of dissocial personality disorder. 3.4.4. The evidence for structural and functional brain abnormality is weak. Reported findings include: frontal lobe hypoperfusion in some cases of antisocial behaviour;17 reduced activity in the limbic system when processing emotional information in criminal psychopaths;18 and reduced volume of the prefrontal cortex in antisocial personality disorder.19 Neuroimaging studies tend to be small (typically 15-20 individuals) and such findings, however interesting, should not be seen as underpinning all cases of dissocial behaviour. 3.4.5. In terms of developmental factors, growing up with an alcoholic or psychopathic father is reported to be associated with adult antisocial behaviour.20 Some studies have found further associations with a history of physical abuse21 and low parental care with maternal overprotection.22 However, such studies are small scale and such putative associations cannot be assumed to reflect common factors in causation. ## 3.5 Borderline Personality Disorder (Bpd) 3.5.1 Over 85% of people with BPD will have experienced childhood trauma, either physical or sexual.23,24 Psychodynamic theories posit that such trauma impacts on the development of the self, and it is probable that the earlier the abuse occurs the more damaging to the personality it tends to be. 3.5.2 Psychodynamic theories go on to develop the idea that early abuse or neglect affects the individual's ability to think about their own feelings, as well as those of others. A lack of sense of self has been proposed as the core pathology in BPD. In order to deal with childhood trauma, it is postulated that the individual resorts to "defence mechanisms" which often include dissociation (separation of cognitive and emotional functions) and "splitting" (conflicting yet simultaneous emotions/thoughts), the latter of which is frequently encountered in patient care. ## 3.6 Histrionic Personality Disorder 3.6.1 Some researchers have suggested that a similar core pathology underlies histrionic personality disorder in women and dissocial personality disorder in men,25 but empirical evidence for this is lacking. Indeed, there is little research into the aetiology of histrionic personality disorder but as with other personality disorders, it is assumed to have developmental, social, and genetic contributory factors. 3.6.2 Individuals with histrionic or antisocial personality disorders will often share common features in terms of a history of childhood abuse, and lack of emotional care. ## 3.7 Anankastic Personality Disorder 3.7.1 Twin studies suggest a degree of heritability to obsessive-compulsive traits.26,27 Many authors argue for the existence of an obsessive-compulsive spectrum, which also includes other disorders such as Tourette's syndrome and body dysmorphic disorder.28,29 However, only 6% of patients with obsessivecompulsive disorder have obsessive-compulsive personality disorder,30 and the relationship between the two is not clear. ## 3.8 Anxious (Avoidant) Personality Disorder 3.8.1 Since the core feature of this disorder is avoidance of social situations, it is thought that such individuals may be on a spectrum that includes anxiety disorders such as social phobia.31 As with most personality disorders, a degree of inheritance of biological vulnerability is assumed and those with reduced self-esteem from overly-critical parenting tend to be socially avoidant, which will perpetuate the problem throughout schooling. Little is otherwise known about the causes of this personality disorder. ## 3.9 Dependent Personality Disorder 3.9.1 Most theories about the aetiology of this disorder focus on psychodynamic theories of personality development. For example, Sigmund Freud believed that dependent personality was due to fixation on the oral phase of psychosexual development. However, there is little empirical evidence to support such theories and very little is known about the aetiology of this disorder. ## 3.10 Relationship Between Military Service And Personality Disorders 3.10.1 Due to the way that personality disorder is defined (i.e. evidence of enduring patterns of behaviour from late childhood or adolescence onwards), the strength of association between personality disorder and military service reduces with advancing age of military experience. A diagnosis of personality disorder is extremely unlikely in someone with no disturbance of function or social relationships during their second decade of life. There is no evidence to suggest that specific experiences associated with military service have any causal link with the development of personality disorder. 3.10.2 There is evidence that premorbid personality factors may act as vulnerability factors for the development of specific mental disorders. For example, Axelrod et al report that features of pre-war borderline personality disorder accounted for variability in post-combat symptoms of post-traumatic stress disorder (PTSD).32 Other studies have identified that individuals with PTSD are more likely to have personality dysfunction of a number of types: paranoid, borderline, and avoidant.33,34 However, these studies cannot support the conclusion that PTSD or trauma causes the personality disorder, and the extent to which personality disorder predisposes to PTSD is largely unknown. Whilst the presence of personality disorder tends to be a risk factor for mental disorders such as depression35 and drug misuse,36 the nature and extent of this vulnerability is not yet understood. 3.10.3 In terms of antisocial behaviour, associations have been identified between combat exposure and adult antisocial behaviour. Within studies performed in Vietnam veterans, it has been suggested that trauma may perpetuate adult antisocial behaviour in some individuals.37 These findings have not been replicated in larger studies, or within combat veterans from different theatres of conflict, so the strength of association is uncertain and conclusions cannot be drawn. 3.10.4 Among US veterans of the Persian Gulf War in 1991, lower rates of hospitalisation for personality disorder have been reported.38 The study lacked detailed assessments of pre-combat mental health and a greater rate of outpatient treatment for personality disorders might account for such findings. It would be fallacious to conclude that combat exposure reduces prevalence rates of personality disorder or that individuals with personality disorder are somehow directed away from combat duties. ## 4. Treatment And Prognosis 4.1 General Principles 4.1.1 By their nature, personality disorders tend to be lifelong patterns of malfunction and distress which are not readily amenable to treatment. In addition, people with personality disorder of any type are generally more vulnerable to other psychiatric disorders which, if present, should be treated. In some individuals, effects of personality disorder diminish with ageing, perhaps due to adoption of more effective coping behaviours. In addition, for those individuals who do experience improvements in functioning with treatment, the goal will often be one of managing to cope with, or adapt to, the distressing problems associated with the diagnosis.40,41 4.1.2 Psychodynamic psychotherapy. Only certain types of personality disorder may respond to "insight-oriented" treatments such as psychodynamic psychotherapy. Such disorders include anankastic, anxious (avoidant), and dependent types. Such treatment may require as long as 5 years to show any benefit. The number of studies is small, but psychodynamic psychotherapy appears to have reasonable effect sizes.39 4.1.3 Psychotherapy is generally not recommended for paranoid or dissocial personality disorders since the individual may resent the therapist, whom they may view as trying to control them. 4.1.4 Cognitive behavioural therapy (CBT). A CBT-based approach may be helpful for individuals with avoidant or dependent personality disorders. ## 4.2 Paranoid Personality Disorder 4.2.1 Treatment. Psychological approaches are unlikely to be fruitful for the reasons given above. If comorbid anxiety or depression is present, then anxiolytics or antidepressants may be useful. Low-dose antipsychotics might have a role if psychotic symptoms become evident. 4.2.2 Outcome. Paranoid individuals are likely to generate hostility and social anxiety in peers, which might contribute to continued paranoid interpretations of the world. Some people will undoubtedly develop frank delusional thinking in late adolescence together with hallucinations and thought disorder, and go on to develop schizophrenia. Others may harbour longstanding fixed paranoid interpretations without other psychotic symptoms and attract a diagnosis of delusional disorder. ## 4.3 Dissocial Personality Disorder 4.3.1 Treatment. There is some suggestion that group therapy is more effective than individual therapy but large, randomised trials have not been performed. Groups tend to be small, with insufficient numbers of therapists. Self-help groups may be beneficial for some. Traditionally, the therapeutic community has been a popular form of treatment but such resources are inevitably limited. 4.3.2 A variety of pharmacological treatments for impulsivity and aggressive behaviour have been suggested, although large, randomised controlled trials are lacking. Lithium has been shown to reduce aggression in prisoners,42 and other drugs used to treat aggression include phenytoin, carbamazepine, propranolol and the antipsychotic drugs.43,44 4.3.3 Outcome. Antisocial behaviour is frequently a lifelong pattern, in most cases developing before the age of 15. Adolescent problem behaviour appears to be a predictor of adult antisocial behaviour,45 although antisocial behaviour tends to decrease with increasing age. This may be due to maturation of the personality, or the presence of a supportive and compensatory relationship. ## 4.3 Borderline Personality Disorder (Bpd) 4.4.1 Treatment. Dialectical behaviour therapy (DBT) is a novel treatment method which has been designed for the treatment of BPD. It is based on the belief that individuals with BPD have difficulties in self-regulation and interpersonal skills, and it assumes that these can be learnt in therapy. It incorporates a variety of techniques including individual therapy, group skills training, telephone contact, and therapist consultation. DBT has been shown (including in some randomised controlled trials) to reduce self-harming behaviour and reduce hospitalisation of those undergoing therapy.46 4.4.2 Psychoanalytic approaches have been the most commonly used treatment for some time, and have demonstrated effectiveness over 18 months.47 It seems likely that for many people, a stable therapeutic relationship might be helpful in allowing a more functional psychological development. 4.4.3 A variety of pharmacological treatments have been trialled for the treatment of BPD. Olanzapine, an antipsychotic, has been found to improve the mood symptoms and behavioural disturbance associated with BPD, although the numbers involved were small.49,50 SSRIs have also been used to treat the emotional instability and dysphoria of BPD. 4.4.4 Outcome. The long-term outcome of BPD may not be as pessimistic as many psychiatrists believe. Whilst 3-9% of patients will have committed suicide at 10-25 year follow-up, 50-60% will have shown a clinical recovery.51 4.5 Histrionic personality disorder 4.5.1 Treatment. Individuals with histrionic personality disorder will often present with depressive symptoms, and treatment with antidepressants and/or psychological approaches is necessary. 4.5.2 For the disorder itself, psychotherapy is probably the treatment of choice with the goals being the prevention of depressive episodes, and stability of mood. 4.5.3 Outcome. Like many of the personality disorders, histrionic personality disorder may become less problematic with advancing age, as the individual matures and learns more constructive coping behaviours. Many people with histrionic personality disorder will have depressive episodes, and self-harming behaviour is not uncommon. ## 4.6 Anankastic Personality Disorder 4.6.1 Treatment. Those individuals who experience a high degree of anxiety as a result of doubt and indecision may respond to trials of antidepressants with serotonergic activity. The SSRIs and clomipramine are the preferred drugs. Antidepressants should be considered where the individual has comorbid depressive disorder. 4.6.2 Psychological treatment focuses on the cognitions associated with perceived failure - a cognitive behavioural approach would be the intervention of choice. 4.6.3 Outcome. In most western societies conscientiousness and perfectionism are valued personality traits and individuals with this disorder may find occupational roles in which such traits offer an advantage. They may be able to sustain relationships in which their partner tends to be submissive. 4.6.4 Due to their rigidity, they often have difficulty in adjusting to changes in circumstances, and depressive episodes are not uncommon in later life. ## 5. Summary 5.1. Personality disorders are a heterogeneous group of diagnoses which are united by the impact that a particular set of personality traits has upon an individual's life. Prevalence rates for all personality disorders combined are approximately 10% in the general population but the rate increases among psychiatric inpatients and other populations. 5.2. The causes of each disorder are relatively poorly understood but, for a diagnosis to be made, the dysfunctional patterns of behaviour must be stable, present since late adolescence and not due to any other mental illness or disease. Personality disorders are likely to be caused by a combination of inherited vulnerability and early life experience. Whilst an individual may experience greater difficulties due to the disorder at times of stress, specific life events in adulthood are unlikely to have a role in the causation of the disorder. 5.3. Historically, it was believed that personality disorders would not respond well to treatment and that there was little to offer. However, there is some evidence that symptomatic improvements can be obtained from psychotherapy, although there is uncertainty as to which form of therapy is best and which group of patients will respond. Whatever the answer, for many individuals the improvements from treatment will be modest at best. ## 6. Related Synopses Post-Traumatic Stress Disorder Adjustment Disorder Generalised Anxiety Disorder Alcohol Dependence/Alcohol Abuse Syndrome Bipolar Affective Disorder Obsessive Compulsive Disorder ## 7. Glossary | aetiology | The study of the causes, e.g. of a disorder. | |-------------------------------------------------------|----------------------------------------------------------| | | | | anankastic | Compulsive nature. | | | | | antipsychotic | A medication (or another measure) that is believed to | | be effective in the treatment of psychosis. | | | | | | anxiolytic | Anxiety-reducing. The term is used to describe a class | | of drugs which includes the benzodiazepines. | | | | | | body dysmorphic disorder | A condition in which the individual is preoccupied | | with a perceived physical defect. This preoccupation | | | becomes consuming and results in significant | | | impairment in the individual's life and social | | | functioning, typically avoiding social contact. The | | | individual may consult multiple doctors and surgeons, | | | looking for surgical intervention. | | | | | | clomipramine | A tricyclic antidepressant drug used to treat depression | | and obsessive-compulsive disorder (OCD). | | | | | | comorbid | The presence of one or more disorders (or diseases) in | | addition to a primary disorder or disease. | | | | | | cognition | The process of knowing and, more precisely, the | | process of being aware, knowing, thinking, learning | | | and judging. | | | | | | dopaminergic system | Relating to dopamine (a neurotransmitter). | | | | | dysphoria | Lowered mood, typically experienced as | | "unhappiness" but not of a severity which would be | | | associated with depressive illness. | | | | | | heterogeneous | Derived from a different source or species. Also called | | heterogenic. | | | | | | hypoperfusion | Reduced perfusion, i.e. blood flow, and by inference, | | reduced activity. | | | | | | neuroimaging | A range of methods, including magnetic resonance | | scanning (MRI), used to investigate and study the | | | functioning of the central nervous system. | | | | | | polymorphism | A variation in the DNA that is too common to be due | | merely to new mutation. A polymorphism must have a | | | frequency of at least 1% in the population. | | | | | post-traumatic stress disorder (PTSD) A common anxiety disorder that develops after exposure to a terrifying event or ordeal in which grave physical harm occurred or was threatened. psychodynamic psychotherapy A type of psychotherapy that draws on psychoanalytic theory to help people understand the roots of emotional distress, often by exploring unconscious motives, needs, and defences. schizophrenia One of several brain diseases with symptoms that may include psychosis, disturbance of behaviour, social withdrawal and impairment of normal functioning, and abnormal emotional responses. It may also include catatonia. serotonergic Relating to serotonin (a neurotransmitter also known as 5-HT). SSRI Abbreviation for selective serotonin reuptake inhibitors, commonly prescribed drugs for treating depression, OCD and anxiety disorders. Tourette syndrome Gilles de la Tourette syndrome/Tourette Syndrome is a neurological disorder characterised by persistent motor and/or vocal tics. It usually presents in childhood. trait In genetics, a trait refers to any genetically determined characteristic. In personality, it refers to a distinguishing characteristic. There is insufficient evidence to conclude that specific personality traits are genetically determined. ## 8. References 1. Tyrer P. Personality disorder. Br J Psychiatry 2001;179(1):81-4. 2. Perry JC. Problems and considerations in the valid assessment of personality disorders. Am J Psychiatry 1992;149(12):1645-53. 3. Lewis G, Appleby L. Personality disorder: the patients psychiatrists dislike. Br J Psychiatry 1988;153(1):44-9. 4. World Health Organisation. International statistical classification of diseases and related health problems, 1989 Revision. Geneva: World Health Organisation; 1992. 5. American Psychiatric Association. 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QB1. SHOWCARD Which of the following do you, or does anyone in your household, have in your home at the moment? (MULTI CODE).........................................................................................................................................................................................................42 Base : All QB1 respondents QB2. SHOWCARD And do you personally use...? (MULTI CODE)............................................................................................................................................................................................................................................................................................................................48 Base : All QB1 respondents QB3 (QB4). SHOWCARD Which games console/s do you or does anyone in your household have at the moment? (MULTI CODE) ...................................................................................................................................................................................................................54 Base : Those who have access to a games console at home QB4 (QB5). SHOWCARD Which, if any, of these do you use your games console for? (MULTI CODE) .................................................................................................................................................................................................................................................................59 Base : Those who have access to a games console at home QB5 (QB6) Does your household's e-reader (digital book reader) have built-in 3G or 4G access to a mobile network? This means that books can be purchased online and downloaded from anywhere with a signal, without the need for a Wi-Fi connection? ..............65 Base : Those who personally use an e-reader/ digital book reader All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. ## Qb1. Showcard Which Of The Following Do You, Or Does Anyone In Your Household, Have In Your Home At The Moment? (Multi Code) Base : All QB1 respondents GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 3612 1766 1846 496 585 1149 1382 639 410 448 680 811 1079 742 980 2264 492 496 360 Effective Weighted Sample 2598 1261 1337 353 431 827 1004 462 306 318 518 585 802 540 713 2010 326 352 316 Total 2655 1291 1364 363 465 909 918 408 286 321 593 709 715 574 657 2236 233 132 54 49% 51% 14% 18% 34% 35% 15% 11% 12% 22% 27% 27% 22% 25% 84% 9% 5% 2% A standard DVD player 1616 775 841 215 253 609 539 208 171 203 381 465 423 356 372 1347 154 88 28 61% 60% 62% 59% 55% 67% 59% 51% 60% 63% 64% 66% 59% 62% 57% 60% 66% 66% 52% cdf g g g ln r r or 48% 52% 13% 16% 38% 33% 13% 11% 13% 24% 29% 26% 22% 23% 83% 10% 5% 2% Video games console connected to a TV (e.g. Sony PlayStation, Nintendo Wii or Microsoft Xbox) 1236 583 653 262 288 545 140 129 110 163 341 309 357 289 281 1048 100 62 27 47% 45% 48% 72% 62% 60% 15% 32% 38% 51% 57% 44% 50% 50% 43% 47% 43% 47% 50% def f f g gh gh kn kn 47% 53% 21% 23% 44% 11% 10% 9% 13% 28% 25% 29% 23% 23% 85% 8% 5% 2% An MP3 player/iPod 924 468 456 166 198 404 156 60 55 115 338 316 285 190 134 787 85 39 13 35% 36% 33% 46% 43% 44% 17% 15% 19% 36% 57% 45% 40% 33% 20% 35% 36% 29% 25% f f f gh ghi mn mn n qr r 51% 49% 18% 21% 44% 17% 6% 6% 12% 37% 34% 31% 21% 14% 85% 9% 4% 1% E-reader - digital book reader (e.g. Kindle, Sony Reader, Kobo eReader, Nook eReader) 737 356 382 100 138 310 190 44 54 82 270 271 231 145 90 642 48 34 13 28% 28% 28% 27% 30% 34% 21% 11% 19% 26% 46% 38% 32% 25% 14% 29% 21% 26% 24% f f cf g gh ghi lmn mn n p 48% 52% 14% 19% 42% 26% 6% 7% 11% 37% 37% 31% 20% 12% 87% 7% 5% 2% A Blu Ray DVD player 558 312 246 81 103 248 126 40 37 72 203 206 166 115 71 494 29 26 9 21% 24% 18% 22% 22% 27% 14% 10% 13% 23% 34% 29% 23% 20% 11% 22% 13% 20% 16% b f f df gh ghi lmn n n pr p 56% 44% 15% 18% 44% 23% 7% 7% 13% 36% 37% 30% 21% 13% 89% 5% 5% 2% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. ## Qb1. Showcard Which Of The Following Do You, Or Does Anyone In Your Household, Have In Your Home At The Moment? (Multi Code) Base : All QB1 respondents GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 3612 1766 1846 496 585 1149 1382 639 410 448 680 811 1079 742 980 2264 492 496 360 Effective Weighted Sample 2598 1261 1337 353 431 827 1004 462 306 318 518 585 802 540 713 2010 326 352 316 Total 2655 1291 1364 363 465 909 918 408 286 321 593 709 715 574 657 2236 233 132 54 49% 51% 14% 18% 34% 35% 15% 11% 12% 22% 27% 27% 22% 25% 84% 9% 5% 2% Handheld/ portable games player (e.g. Nintendo DS, Sony PSP) 542 244 298 101 121 261 59 50 47 73 148 132 180 123 106 462 37 33 10 20% 19% 22% 28% 26% 29% 6% 12% 17% 23% 25% 19% 25% 21% 16% 21% 16% 25% 18% f f f g gh kn n p pr 45% 55% 19% 22% 48% 11% 9% 9% 13% 27% 24% 33% 23% 20% 85% 7% 6% 2% A smart watch - a wearable computer that may be compatible with a smartphone. Brands include Pebble, Samsung and Sony, with the Apple Watch due to be released in 2015 87 38 49 20 25 36 7 13 5 12 14 19 36 19 14 77 6 3 1 3% 3% 4% 6% 5% 4% 1% 3% 2% 4% 2% 3% 5% 3% 2% 3% 3% 2% 2% f f f kn 44% 56% 23% 28% 41% 8% 15% 6% 14% 16% 21% 41% 22% 16% 88% 7% 3% 1% ANY DVD PLAYER 1856 914 943 244 299 710 603 225 189 233 475 554 499 404 399 1561 164 100 32 70% 71% 69% 67% 64% 78% 66% 55% 66% 72% 80% 78% 70% 70% 61% 70% 71% 76% 59% cdf g g ghi lmn n n r r or 49% 51% 13% 16% 38% 32% 12% 10% 13% 26% 30% 27% 22% 21% 84% 9% 5% 2% ANY GAMES CONSOLE 1302 610 692 272 297 577 156 139 119 168 356 333 376 297 296 1106 104 66 27 49% 47% 51% 75% 64% 63% 17% 34% 42% 52% 60% 47% 53% 52% 45% 49% 44% 50% 51% def f f g gh ghi kn n 47% 53% 21% 23% 44% 12% 11% 9% 13% 27% 26% 29% 23% 23% 85% 8% 5% 2% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. ## Qb1. Showcard Which Of The Following Do You, Or Does Anyone In Your Household, Have In Your Home At The Moment? (Multi Code) Base : All QB1 respondents GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 3612 1766 1846 496 585 1149 1382 639 410 448 680 811 1079 742 980 2264 492 496 360 Effective Weighted Sample 2598 1261 1337 353 431 827 1004 462 306 318 518 585 802 540 713 2010 326 352 316 Total 2655 1291 1364 363 465 909 918 408 286 321 593 709 715 574 657 2236 233 132 54 49% 51% 14% 18% 34% 35% 15% 11% 12% 22% 27% 27% 22% 25% 84% 9% 5% 2% None of these 431 194 237 32 66 84 249 127 52 41 39 77 100 90 163 372 39 12 8 16% 15% 17% 9% 14% 9% 27% 31% 18% 13% 7% 11% 14% 16% 25% 17% 17% 9% 15% ce cde hij j j k klm q q q 45% 55% 7% 15% 19% 58% 30% 12% 10% 9% 18% 23% 21% 38% 86% 9% 3% 2% Don't know 6 4 1 - 3 - 2 - 1 2 - 3 - 1 1 6 - - - *% *% *% -% 1% -% *% -% *% 1% -% *% -% *% *% *% -% -% -% e 74% 26% -% 59% -% 41% -% 20% 33% -% 53% -% 26% 21% 100% -% -% -% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. QB1. SHOWCARD Which of the following do you, or does anyone in your household, have in your home at the moment? (MULTI CODE) Base : All QB1 respondents ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c d e f g h i j k l m n o Unweighted total 3612 252 258 247 245 249 252 252 251 258 2667 945 1895 1710 1800 1812 Effective Weighted Sample 2598 243 243 238 235 238 243 243 240 247 2175 448 1367 1269 1242 1357 Total 2655 327 371 234 189 231 249 224 113 299 2299 357 1541 1109 1251 1404 12% 14% 9% 7% 9% 9% 8% 4% 11% 87% 13% 58% 42% 47% 53% A standard DVD player 1616 155 233 149 95 146 168 131 85 184 1391 225 950 663 822 794 61% 48% 63% 64% 50% 63% 67% 59% 75% 62% 61% 63% 62% 60% 66% 57% ad ad ad adg a abcdegi ad o 10% 14% 9% 6% 9% 10% 8% 5% 11% 86% 14% 59% 41% 51% 49% Video games console connected to a TV (e.g. Sony PlayStation, Nintendo Wii or Microsoft Xbox) 1236 143 164 125 78 122 117 102 58 140 1091 146 861 373 545 691 47% 44% 44% 53% 41% 53% 47% 46% 51% 47% 47% 41% 56% 34% 44% 49% abd d d k m n 12% 13% 10% 6% 10% 9% 8% 5% 11% 88% 12% 70% 30% 44% 56% An MP3 player/iPod 924 90 144 103 45 82 100 72 45 107 793 131 655 267 477 447 35% 27% 39% 44% 24% 35% 40% 32% 39% 36% 35% 37% 42% 24% 38% 32% ad adeg d ad d ad ad m o 10% 16% 11% 5% 9% 11% 8% 5% 12% 86% 14% 71% 29% 52% 48% E-reader - digital book reader (e.g. Kindle, Sony Reader, Kobo eReader, Nook eReader) 737 72 118 76 50 70 83 58 33 82 626 111 504 233 411 326 28% 22% 32% 32% 27% 30% 33% 26% 29% 28% 27% 31% 33% 21% 33% 23% a a a a m o 10% 16% 10% 7% 9% 11% 8% 4% 11% 85% 15% 68% 32% 56% 44% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. QB1. SHOWCARD Which of the following do you, or does anyone in your household, have in your home at the moment? (MULTI CODE) Base : All QB1 respondents ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c d e f g h i j k l m n o Unweighted total 3612 252 258 247 245 249 252 252 251 258 2667 945 1895 1710 1800 1812 Effective Weighted Sample 2598 243 243 238 235 238 243 243 240 247 2175 448 1367 1269 1242 1357 Total 2655 327 371 234 189 231 249 224 113 299 2299 357 1541 1109 1251 1404 12% 14% 9% 7% 9% 9% 8% 4% 11% 87% 13% 58% 42% 47% 53% A Blu Ray DVD player 558 56 89 61 34 41 69 53 23 68 475 83 383 173 315 244 21% 17% 24% 26% 18% 18% 28% 24% 20% 23% 21% 23% 25% 16% 25% 17% ade ade m o 10% 16% 11% 6% 7% 12% 9% 4% 12% 85% 15% 69% 31% 56% 44% Handheld/ portable games player (e.g. Nintendo DS, Sony PSP) 542 83 56 46 34 52 55 45 32 58 482 59 363 176 254 288 20% 25% 15% 20% 18% 22% 22% 20% 28% 20% 21% 17% 24% 16% 20% 21% b b bcdgi k m 15% 10% 9% 6% 10% 10% 8% 6% 11% 89% 11% 67% 33% 47% 53% A smart watch - a wearable computer that may be compatible with a smartphone. Brands include Pebble, Samsung and Sony, with the Apple Watch due to be released in 2015 87 18 11 8 4 3 9 11 6 7 81 6 55 32 32 55 3% 5% 3% 4% 2% 1% 4% 5% 6% 2% 4% 2% 4% 3% 3% 4% e e de k n 20% 12% 10% 4% 3% 10% 13% 7% 8% 93% 7% 63% 37% 37% 63% ANY DVD PLAYER 1856 176 274 176 116 157 191 157 90 223 1593 264 1123 730 959 897 70% 54% 74% 75% 61% 68% 77% 70% 80% 75% 69% 74% 73% 66% 77% 64% ad ad a ade ad adeg ad j m o 9% 15% 9% 6% 8% 10% 8% 5% 12% 86% 14% 60% 39% 52% 48% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. QB1. SHOWCARD Which of the following do you, or does anyone in your household, have in your home at the moment? (MULTI CODE) Base : All QB1 respondents ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c d e f g h i j k l m n o Unweighted total 3612 252 258 247 245 249 252 252 251 258 2667 945 1895 1710 1800 1812 Effective Weighted Sample 2598 243 243 238 235 238 243 243 240 247 2175 448 1367 1269 1242 1357 Total 2655 327 371 234 189 231 249 224 113 299 2299 357 1541 1109 1251 1404 12% 14% 9% 7% 9% 9% 8% 4% 11% 87% 13% 58% 42% 47% 53% ANY GAMES CONSOLE 1302 155 171 128 83 130 124 105 60 149 1143 159 898 402 581 721 49% 47% 46% 55% 44% 56% 50% 47% 53% 50% 50% 45% 58% 36% 46% 51% d bdg d m n 12% 13% 10% 6% 10% 10% 8% 5% 11% 88% 12% 69% 31% 45% 55% None of these 431 88 54 28 42 37 33 37 10 43 371 60 188 241 167 264 16% 27% 14% 12% 22% 16% 13% 16% 9% 14% 16% 17% 12% 22% 13% 19% bcefghi h bcfhi h h h l n 21% 12% 7% 10% 9% 8% 9% 2% 10% 86% 14% 44% 56% 39% 61% Don't know 6 6 - - - - - - - - 6 - 3 3 - 6 *% 2% -% -% -% -% -% -% -% -% *% -% *% *% -% *% bcdefghi n 100% -% -% -% -% -% -% -% -% 100% -% 54% 46% -% 100% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : All QB1 respondents GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 3612 1766 1846 496 585 1149 1382 639 410 448 680 811 1079 742 980 2264 492 496 360 Effective Weighted Sample 2598 1261 1337 353 431 827 1004 462 306 318 518 585 802 540 713 2010 326 352 316 Total 2655 1291 1364 363 465 909 918 408 286 321 593 709 715 574 657 2236 233 132 54 49% 51% 14% 18% 34% 35% 15% 11% 12% 22% 27% 27% 22% 25% 84% 9% 5% 2% A standard DVD player 1350 657 692 167 205 504 473 183 153 158 307 385 345 307 314 1121 130 75 23 51% 51% 51% 46% 44% 55% 52% 45% 54% 49% 52% 54% 48% 53% 48% 50% 56% 57% 43% cd d g g ln n r r or 49% 51% 12% 15% 37% 35% 14% 11% 12% 23% 29% 26% 23% 23% 83% 10% 6% 2% Video games console connected to a TV (e.g. Sony PlayStation, Nintendo Wii or Microsoft Xbox) 678 392 286 209 188 229 52 82 59 93 180 164 203 153 158 574 52 34 17 26% 30% 21% 58% 40% 25% 6% 20% 20% 29% 30% 23% 28% 27% 24% 26% 22% 26% 32% b def ef f gh gh k op 58% 42% 31% 28% 34% 8% 12% 9% 14% 27% 24% 30% 23% 23% 85% 8% 5% 3% An MP3 player/iPod 614 346 268 130 158 223 102 39 37 75 225 238 178 118 80 526 52 27 8 23% 27% 20% 36% 34% 25% 11% 9% 13% 23% 38% 33% 25% 21% 12% 24% 22% 20% 16% b ef ef f gh ghi lmn n n r r 56% 44% 21% 26% 36% 17% 6% 6% 12% 37% 39% 29% 19% 13% 86% 9% 4% 1% E-reader - digital book reader (e.g. Kindle, Sony Reader, Kobo eReader, Nook eReader) 520 235 285 58 105 213 143 33 41 52 206 211 154 91 64 453 33 25 8 20% 18% 21% 16% 23% 23% 16% 8% 14% 16% 35% 30% 22% 16% 10% 20% 14% 19% 16% cf cf g g ghi lmn mn n p 45% 55% 11% 20% 41% 28% 6% 8% 10% 40% 41% 30% 17% 12% 87% 6% 5% 2% A Blu Ray DVD player 458 268 189 69 82 199 108 36 34 53 165 170 139 94 55 410 23 18 6 17% 21% 14% 19% 18% 22% 12% 9% 12% 17% 28% 24% 19% 16% 8% 18% 10% 14% 11% b f f f g ghi lmn n n pqr 59% 41% 15% 18% 43% 24% 8% 8% 12% 36% 37% 30% 20% 12% 90% 5% 4% 1% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : All QB1 respondents GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 3612 1766 1846 496 585 1149 1382 639 410 448 680 811 1079 742 980 2264 492 496 360 Effective Weighted Sample 2598 1261 1337 353 431 827 1004 462 306 318 518 585 802 540 713 2010 326 352 316 Total 2655 1291 1364 363 465 909 918 408 286 321 593 709 715 574 657 2236 233 132 54 49% 51% 14% 18% 34% 35% 15% 11% 12% 22% 27% 27% 22% 25% 84% 9% 5% 2% Handheld/ portable games player (e.g. Nintendo DS, Sony PSP) 241 132 110 70 70 75 27 26 16 30 69 65 80 50 47 208 17 14 3 9% 10% 8% 19% 15% 8% 3% 6% 6% 9% 12% 9% 11% 9% 7% 9% 7% 10% 5% ef ef f gh n r r 55% 45% 29% 29% 31% 11% 11% 7% 12% 29% 27% 33% 21% 19% 86% 7% 6% 1% A smart watch - a wearable computer that may be compatible with a smartphone. Brands include Pebble, Samsung and Sony, with the Apple Watch due to be released in 2015 51 23 28 12 17 18 5 11 5 4 6 11 20 10 10 45 3 2 * 2% 2% 2% 3% 4% 2% 1% 3% 2% 1% 1% 2% 3% 2% 1% 2% 1% 2% 1% f f f 45% 55% 24% 33% 34% 9% 21% 10% 8% 12% 22% 39% 20% 19% 88% 7% 5% 1% ANY DVD PLAYER 1600 804 796 198 248 615 539 199 170 187 410 485 424 356 335 1344 144 85 26 60% 62% 58% 55% 53% 68% 59% 49% 60% 58% 69% 68% 59% 62% 51% 60% 62% 65% 49% b cdf g g ghi lmn n n r r r 50% 50% 12% 16% 38% 34% 12% 11% 12% 26% 30% 26% 22% 21% 84% 9% 5% 2% ANY GAMES CONSOLE 724 413 311 219 198 244 63 91 62 96 192 177 218 161 168 614 55 37 17 27% 32% 23% 60% 43% 27% 7% 22% 22% 30% 32% 25% 31% 28% 26% 27% 24% 28% 32% b def ef f gh gh kn p 57% 43% 30% 27% 34% 9% 13% 9% 13% 26% 24% 30% 22% 23% 85% 8% 5% 2% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : All QB1 respondents GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 3612 1766 1846 496 585 1149 1382 639 410 448 680 811 1079 742 980 2264 492 496 360 Effective Weighted Sample 2598 1261 1337 353 431 827 1004 462 306 318 518 585 802 540 713 2010 326 352 316 Total 2655 1291 1364 363 465 909 918 408 286 321 593 709 715 574 657 2236 233 132 54 49% 51% 14% 18% 34% 35% 15% 11% 12% 22% 27% 27% 22% 25% 84% 9% 5% 2% None of these 638 272 366 60 99 167 312 155 79 68 75 110 154 140 233 547 51 23 17 24% 21% 27% 17% 21% 18% 34% 38% 28% 21% 13% 16% 22% 24% 35% 24% 22% 17% 31% a cde hij j j k k klm q opq 43% 57% 9% 15% 26% 49% 24% 12% 11% 12% 17% 24% 22% 36% 86% 8% 4% 3% Don't know 11 6 5 * 3 3 5 * 2 5 * 4 1 3 2 6 1 4 * *% *% *% *% 1% *% 1% *% 1% 1% *% 1% *% 1% *% *% *% 3% *% gj opr 53% 47% 3% 30% 23% 43% 3% 21% 42% 2% 36% 11% 31% 21% 56% 9% 34% 2% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : All QB1 respondents ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c d e f g h i j k l m n o Unweighted total 3612 252 258 247 245 249 252 252 251 258 2667 945 1895 1710 1800 1812 Effective Weighted Sample 2598 243 243 238 235 238 243 243 240 247 2175 448 1367 1269 1242 1357 Total 2655 327 371 234 189 231 249 224 113 299 2299 357 1541 1109 1251 1404 12% 14% 9% 7% 9% 9% 8% 4% 11% 87% 13% 58% 42% 47% 53% A standard DVD player 1350 122 190 122 85 114 140 118 70 160 1155 195 775 571 705 645 51% 37% 51% 52% 45% 49% 57% 53% 62% 53% 50% 55% 50% 52% 56% 46% a a a ad a abcdeg a o 9% 14% 9% 6% 8% 10% 9% 5% 12% 86% 14% 57% 42% 52% 48% Video games console connected to a TV (e.g. Sony PlayStation, Nintendo Wii or Microsoft Xbox) 678 74 91 64 52 53 66 70 35 70 602 76 465 210 277 401 26% 22% 25% 27% 27% 23% 27% 31% 31% 24% 26% 21% 30% 19% 22% 29% ae ae k m n 11% 13% 9% 8% 8% 10% 10% 5% 10% 89% 11% 69% 31% 41% 59% An MP3 player/iPod 614 55 103 68 33 56 71 48 33 59 526 88 436 176 314 300 23% 17% 28% 29% 18% 24% 29% 21% 29% 20% 23% 25% 28% 16% 25% 21% adi adgi adi adgi m o 9% 17% 11% 5% 9% 12% 8% 5% 10% 86% 14% 71% 29% 51% 49% E-reader - digital book reader (e.g. Kindle, Sony Reader, Kobo eReader, Nook eReader) 520 47 85 55 40 41 67 40 22 58 440 80 356 164 297 223 20% 14% 23% 23% 21% 18% 27% 18% 19% 19% 19% 22% 23% 15% 24% 16% a a a aegh m o 9% 16% 11% 8% 8% 13% 8% 4% 11% 85% 15% 69% 31% 57% 43% A Blu Ray DVD player 458 38 84 51 28 32 54 47 20 57 390 68 314 141 266 191 17% 12% 23% 22% 15% 14% 22% 21% 17% 19% 17% 19% 20% 13% 21% 14% ade ae ae ae a m o 8% 18% 11% 6% 7% 12% 10% 4% 12% 85% 15% 69% 31% 58% 42% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : All QB1 respondents ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c d e f g h i j k l m n o Unweighted total 3612 252 258 247 245 249 252 252 251 258 2667 945 1895 1710 1800 1812 Effective Weighted Sample 2598 243 243 238 235 238 243 243 240 247 2175 448 1367 1269 1242 1357 Total 2655 327 371 234 189 231 249 224 113 299 2299 357 1541 1109 1251 1404 12% 14% 9% 7% 9% 9% 8% 4% 11% 87% 13% 58% 42% 47% 53% Handheld/ portable games player (e.g. Nintendo DS, Sony PSP) 241 36 32 21 16 22 31 16 14 21 217 25 153 86 107 134 9% 11% 9% 9% 9% 10% 12% 7% 12% 7% 9% 7% 10% 8% 9% 10% gi m 15% 13% 9% 7% 9% 13% 6% 6% 9% 90% 10% 63% 36% 44% 56% A smart watch - a wearable computer that may be compatible with a smartphone. Brands include Pebble, Samsung and Sony, with the Apple Watch due to be released in 2015 51 8 6 5 4 2 5 10 4 2 49 2 34 17 19 32 2% 2% 2% 2% 2% 1% 2% 5% 4% 1% 2% 1% 2% 2% 2% 2% ei ei k 16% 11% 9% 8% 3% 10% 20% 8% 3% 95% 5% 66% 34% 37% 63% ANY DVD PLAYER 1600 141 233 152 106 128 165 147 78 194 1364 235 956 640 853 747 60% 43% 63% 65% 56% 55% 66% 66% 69% 65% 59% 66% 62% 58% 68% 53% a ae a a ade ade ade ade j m o 9% 15% 9% 7% 8% 10% 9% 5% 12% 85% 15% 60% 40% 53% 47% ANY GAMES CONSOLE 724 83 100 67 55 56 71 72 38 73 640 85 490 232 302 422 27% 25% 27% 29% 29% 24% 28% 32% 34% 24% 28% 24% 32% 21% 24% 30% aei m n 11% 14% 9% 8% 8% 10% 10% 5% 10% 88% 12% 68% 32% 42% 58% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : All QB1 respondents ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c d e f g h i j k l m n o Unweighted total 3612 252 258 247 245 249 252 252 251 258 2667 945 1895 1710 1800 1812 Effective Weighted Sample 2598 243 243 238 235 238 243 243 240 247 2175 448 1367 1269 1242 1357 Total 2655 327 371 234 189 231 249 224 113 299 2299 357 1541 1109 1251 1404 12% 14% 9% 7% 9% 9% 8% 4% 11% 87% 13% 58% 42% 47% 53% None of these 638 117 78 45 49 72 47 48 19 72 558 80 299 337 247 391 24% 36% 21% 19% 26% 31% 19% 21% 17% 24% 24% 22% 19% 30% 20% 28% bcdfghi h bcfgh h l n 18% 12% 7% 8% 11% 7% 8% 3% 11% 87% 13% 47% 53% 39% 61% Don't know 11 4 - 1 - - - - - 1 10 1 6 5 2 9 *% 1% -% *% -% -% -% -% -% *% *% *% *% *% *% 1% n 40% -% 10% -% -% -% -% -% 6% 91% 9% 54% 46% 15% 85% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 1687 806 881 368 375 741 203 213 158 243 426 376 538 359 414 1081 213 224 169 Effective Weighted Sample 1240 591 649 265 279 539 157 157 124 171 319 271 403 274 307 970 141 161 150 Total 1302 610 692 272 297 577 156 139 119 168 356 333 376 297 296 1106 104 66 27 47% 53% 21% 23% 44% 12% 11% 9% 13% 27% 26% 29% 23% 23% 85% 8% 5% 2% Nintendo Wii/ Wii U 455 179 276 82 86 238 50 31 35 62 138 131 141 103 80 385 34 28 9 35% 29% 40% 30% 29% 41% 32% 22% 29% 37% 39% 39% 38% 35% 27% 35% 33% 42% 33% a cdf g g n n 39% 61% 18% 19% 52% 11% 7% 8% 14% 30% 29% 31% 23% 18% 84% 8% 6% 2% XBox 360 393 200 192 91 88 187 27 50 27 48 114 101 111 91 90 323 35 27 7 30% 33% 28% 34% 29% 32% 17% 36% 23% 28% 32% 30% 29% 30% 30% 29% 34% 42% 27% f f f h or 51% 49% 23% 22% 48% 7% 13% 7% 12% 29% 26% 28% 23% 23% 82% 9% 7% 2% Nintendo DS/ DSi/ DS Lite/ 3DS 345 142 202 60 74 176 34 27 27 37 107 95 106 82 62 296 25 17 7 26% 23% 29% 22% 25% 31% 22% 19% 23% 22% 30% 29% 28% 28% 21% 27% 24% 25% 26% a cf g n n 41% 59% 18% 22% 51% 10% 8% 8% 11% 31% 28% 31% 24% 18% 86% 7% 5% 2% PlayStation 3 332 155 177 69 93 141 29 40 32 44 80 78 97 70 88 285 26 14 7 25% 25% 26% 25% 31% 24% 18% 29% 27% 26% 23% 23% 26% 24% 30% 26% 25% 21% 27% ef 47% 53% 21% 28% 42% 9% 12% 10% 13% 24% 23% 29% 21% 26% 86% 8% 4% 2% PlayStation 4 158 82 77 35 27 82 13 11 11 29 47 34 53 37 34 126 19 8 6 12% 13% 11% 13% 9% 14% 9% 8% 9% 17% 13% 10% 14% 12% 11% 11% 18% 12% 20% d g o oq 52% 48% 22% 17% 52% 8% 7% 7% 18% 30% 22% 34% 23% 21% 80% 12% 5% 3% PlayStation 2 139 68 71 30 24 70 15 20 9 17 33 32 47 25 35 118 9 9 3 11% 11% 10% 11% 8% 12% 10% 14% 7% 10% 9% 10% 12% 9% 12% 11% 9% 13% 10% 49% 51% 21% 17% 50% 11% 14% 6% 12% 23% 23% 34% 18% 25% 85% 6% 6% 2% XBox One 107 60 47 37 22 43 6 12 7 10 34 22 32 26 27 91 6 7 3 8% 10% 7% 14% 7% 7% 4% 9% 6% 6% 10% 7% 9% 9% 9% 8% 6% 11% 12% b def p 56% 44% 34% 20% 40% 5% 12% 6% 10% 32% 21% 30% 24% 25% 84% 6% 7% 3% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 1687 806 881 368 375 741 203 213 158 243 426 376 538 359 414 1081 213 224 169 Effective Weighted Sample 1240 591 649 265 279 539 157 157 124 171 319 271 403 274 307 970 141 161 150 Total 1302 610 692 272 297 577 156 139 119 168 356 333 376 297 296 1106 104 66 27 47% 53% 21% 23% 44% 12% 11% 9% 13% 27% 26% 29% 23% 23% 85% 8% 5% 2% XBox 99 43 56 22 18 45 14 10 9 10 22 24 26 25 23 85 2 9 2 8% 7% 8% 8% 6% 8% 9% 7% 7% 6% 6% 7% 7% 8% 8% 8% 2% 14% 8% p op p 44% 56% 22% 18% 46% 14% 10% 9% 10% 23% 24% 27% 25% 24% 86% 2% 9% 2% PlayStation Portable (PSP)/ PlayStation Vita 47 21 27 11 11 22 4 5 3 3 11 11 19 6 11 41 4 2 1 4% 3% 4% 4% 4% 4% 2% 4% 3% 2% 3% 3% 5% 2% 4% 4% 4% 3% 5% m 44% 56% 24% 23% 46% 7% 10% 7% 7% 22% 24% 40% 13% 23% 86% 8% 4% 3% Other 19 9 10 4 5 9 2 1 1 2 7 5 9 1 3 17 1 1 * 1% 1% 1% 1% 2% 2% 1% 1% 1% 1% 2% 2% 3% 1% 1% 2% 1% 1% *% m 48% 52% 20% 25% 47% 8% 7% 6% 11% 35% 28% 50% 8% 14% 91% 5% 3% 1% PS3/ PS4/ Wii/ XBox 360/ XBox/ XBox One 1152 551 601 253 262 516 121 123 102 159 319 285 339 261 267 973 96 59 24 88% 90% 87% 93% 88% 89% 78% 88% 86% 95% 90% 86% 90% 88% 90% 88% 92% 90% 89% f f f gh 48% 52% 22% 23% 45% 10% 11% 9% 14% 28% 25% 29% 23% 23% 84% 8% 5% 2% DS/ PSP/ PORTABLE CONSOLE 365 153 212 63 77 187 37 30 28 38 115 100 114 85 67 313 28 17 7 28% 25% 31% 23% 26% 32% 24% 21% 24% 22% 32% 30% 30% 29% 23% 28% 27% 26% 26% a cf gi n n 42% 58% 17% 21% 51% 10% 8% 8% 10% 31% 27% 31% 23% 18% 86% 8% 5% 2% Don't know 44 13 31 7 7 16 15 4 6 4 10 12 7 18 7 39 * 4 1 3% 2% 4% 2% 2% 3% 10% 3% 5% 2% 3% 4% 2% 6% 2% 4% *% 6% 2% a cde ln p p 30% 70% 15% 15% 36% 34% 10% 15% 8% 22% 27% 16% 41% 16% 89% 1% 8% 1% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c ~d e f g h i j k l m n o Unweighted total 1687 118 115 132 97 134 121 114 126 124 1283 404 1110 573 805 882 Effective Weighted Sample 1240 114 109 128 94 129 117 111 121 119 1055 196 809 441 564 676 Total 1302 155 171 128 83 130 124 105 60 149 1143 159 898 402 581 721 12% 13% 10% ** 10% 10% 8% 5% 11% 88% 12% 69% 31% 45% 55% Nintendo Wii/ Wii U 455 53 45 54 ** 52 48 31 26 45 405 50 332 122 223 232 35% 34% 26% 42% ** 40% 38% 29% 44% 30% 35% 32% 37% 30% 38% 32% bgi b bgi m o 12% 10% 12% ** 11% 10% 7% 6% 10% 89% 11% 73% 27% 49% 51% XBox 360 393 29 49 47 ** 31 37 36 28 46 342 51 277 115 196 197 30% 18% 29% 37% ** 24% 30% 34% 46% 31% 30% 32% 31% 29% 34% 27% ae a a abefi a o 7% 12% 12% ** 8% 9% 9% 7% 12% 87% 13% 71% 29% 50% 50% Nintendo DS/ DSi/ DS Lite/ 3DS 345 38 52 40 ** 27 23 26 16 53 301 43 233 109 170 175 26% 24% 31% 31% ** 21% 19% 25% 27% 36% 26% 27% 26% 27% 29% 24% f f ef o 11% 15% 12% ** 8% 7% 8% 5% 15% 87% 13% 68% 32% 49% 51% PlayStation 3 332 38 38 37 ** 34 29 28 14 47 304 28 231 99 141 191 25% 24% 22% 29% ** 26% 24% 27% 22% 32% 27% 18% 26% 25% 24% 26% k 11% 12% 11% ** 10% 9% 8% 4% 14% 91% 9% 69% 30% 43% 57% PlayStation 4 158 12 23 16 ** 23 10 6 7 13 142 16 119 38 68 91 12% 8% 13% 13% ** 18% 8% 6% 12% 9% 12% 10% 13% 9% 12% 13% afgi m 8% 14% 10% ** 15% 6% 4% 5% 8% 90% 10% 75% 24% 43% 57% PlayStation 2 139 21 19 12 ** 14 9 11 7 17 127 12 82 57 56 83 11% 14% 11% 9% ** 11% 7% 10% 11% 11% 11% 8% 9% 14% 10% 11% l 15% 14% 8% ** 10% 6% 8% 5% 12% 91% 9% 59% 41% 41% 59% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c ~d e f g h i j k l m n o Unweighted total 1687 118 115 132 97 134 121 114 126 124 1283 404 1110 573 805 882 Effective Weighted Sample 1240 114 109 128 94 129 117 111 121 119 1055 196 809 441 564 676 Total 1302 155 171 128 83 130 124 105 60 149 1143 159 898 402 581 721 12% 13% 10% ** 10% 10% 8% 5% 11% 88% 12% 69% 31% 45% 55% XBox One 107 8 10 18 ** 5 10 10 8 11 92 15 78 29 55 52 8% 5% 6% 14% ** 4% 8% 9% 13% 7% 8% 10% 9% 7% 10% 7% abe ae 7% 10% 17% ** 5% 9% 9% 7% 10% 86% 14% 73% 27% 52% 48% XBox 99 17 4 9 ** 18 5 10 2 14 89 10 60 39 43 55 8% 11% 3% 7% ** 14% 4% 10% 3% 9% 8% 6% 7% 10% 7% 8% bh bfh b b 17% 4% 9% ** 19% 5% 10% 2% 14% 90% 10% 60% 40% 44% 56% PlayStation Portable (PSP)/ PlayStation Vita 47 8 4 4 ** 2 2 4 6 10 42 5 25 23 23 24 4% 5% 2% 3% ** 2% 2% 4% 9% 7% 4% 3% 3% 6% 4% 3% bcef l 16% 9% 8% ** 5% 5% 8% 12% 22% 89% 11% 52% 48% 48% 52% Other 19 3 2 1 ** 5 2 3 - 1 11 8 13 4 12 7 1% 2% 1% 1% ** 4% 2% 3% -% 1% 1% 5% 1% 1% 2% 1% h j 13% 12% 5% ** 27% 10% 17% -% 7% 57% 43% 67% 22% 65% 35% PS3/ PS4/ Wii/ XBox 360/ XBox/ XBox One 1152 131 137 118 ** 117 113 91 57 135 1017 135 802 348 519 633 88% 85% 80% 92% ** 91% 91% 86% 94% 91% 89% 85% 89% 87% 89% 88% b b b ab b 11% 12% 10% ** 10% 10% 8% 5% 12% 88% 12% 70% 30% 45% 55% DS/ PSP/ PORTABLE CONSOLE 365 44 55 41 ** 28 23 26 18 57 320 45 245 117 180 185 28% 29% 32% 32% ** 22% 19% 25% 29% 38% 28% 28% 27% 29% 31% 26% f f efg o 12% 15% 11% ** 8% 6% 7% 5% 16% 88% 12% 67% 32% 49% 51% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c ~d e f g h i j k l m n o Unweighted total 1687 118 115 132 97 134 121 114 126 124 1283 404 1110 573 805 882 Effective Weighted Sample 1240 114 109 128 94 129 117 111 121 119 1055 196 809 441 564 676 Total 1302 155 171 128 83 130 124 105 60 149 1143 159 898 402 581 721 12% 13% 10% ** 10% 10% 8% 5% 11% 88% 12% 69% 31% 45% 55% Don't know 44 5 13 - ** 4 4 8 1 1 38 6 30 15 14 30 3% 3% 7% -% ** 3% 3% 8% 2% 1% 3% 4% 3% 4% 2% 4% c ci c c ci 11% 29% -% ** 10% 8% 19% 3% 2% 86% 14% 67% 33% 32% 68% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 1687 806 881 368 375 741 203 213 158 243 426 376 538 359 414 1081 213 224 169 Effective Weighted Sample 1240 591 649 265 279 539 157 157 124 171 319 271 403 274 307 970 141 161 150 Total 1302 610 692 272 297 577 156 139 119 168 356 333 376 297 296 1106 104 66 27 47% 53% 21% 23% 44% 12% 11% 9% 13% 27% 26% 29% 23% 23% 85% 8% 5% 2% Online gaming 404 246 158 133 87 161 24 43 38 60 109 95 127 93 89 335 42 16 11 31% 40% 23% 49% 29% 28% 15% 31% 32% 36% 31% 28% 34% 31% 30% 30% 40% 24% 40% b def f f oq oq 61% 39% 33% 21% 40% 6% 11% 9% 15% 27% 23% 31% 23% 22% 83% 10% 4% 3% Watching DVDs/ Blu Ray DVDs 254 141 113 73 70 96 15 33 23 44 60 60 75 53 67 223 17 11 4 20% 23% 16% 27% 24% 17% 10% 24% 19% 26% 17% 18% 20% 18% 23% 20% 16% 16% 15% b ef ef f j 55% 45% 29% 28% 38% 6% 13% 9% 17% 24% 24% 29% 21% 26% 88% 7% 4% 2% Watching TV programmes/ films on catch-up services (e.g. BBC iPlayer, ITV Player, 4OD, Demand 5 or Sky Go 200 117 83 65 52 77 7 19 16 29 50 52 60 50 39 177 12 9 3 15% 19% 12% 24% 17% 13% 4% 13% 13% 17% 14% 15% 16% 17% 13% 16% 12% 13% 10% b ef f f r 59% 41% 32% 26% 39% 3% 9% 8% 14% 25% 26% 30% 25% 19% 88% 6% 4% 1% Browsing the web/ internet 191 107 84 69 52 63 8 25 18 23 42 43 58 39 50 162 15 10 4 15% 18% 12% 25% 17% 11% 5% 18% 15% 14% 12% 13% 16% 13% 17% 15% 15% 15% 16% b def ef f 56% 44% 36% 27% 33% 4% 13% 9% 12% 22% 23% 31% 21% 26% 85% 8% 5% 2% Watching short video clips online (e.g. YouTube or Dailymotion) 137 80 57 45 32 56 4 13 10 20 29 31 42 30 34 116 15 3 2 11% 13% 8% 17% 11% 10% 2% 9% 9% 12% 8% 9% 11% 10% 11% 11% 15% 5% 8% b def f f q q 59% 41% 33% 23% 41% 3% 10% 7% 15% 21% 23% 30% 22% 25% 85% 11% 2% 2% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 1687 806 881 368 375 741 203 213 158 243 426 376 538 359 414 1081 213 224 169 Effective Weighted Sample 1240 591 649 265 279 539 157 157 124 171 319 271 403 274 307 970 141 161 150 Total 1302 610 692 272 297 577 156 139 119 168 356 333 376 297 296 1106 104 66 27 47% 53% 21% 23% 44% 12% 11% 9% 13% 27% 26% 29% 23% 23% 85% 8% 5% 2% Watching purchased TV programmes/ films online or downloads, either via pay per view services (e.g. Playstation Movies, Blinkbox) or via a 'standalone' subscription service (e.g. LoveFilm Instant, Netflix) 124 67 58 42 31 50 1 12 12 16 29 31 33 28 32 106 11 5 3 10% 11% 8% 16% 10% 9% 1% 9% 10% 9% 8% 9% 9% 9% 11% 10% 11% 7% 10% ef f f 54% 46% 34% 25% 40% 1% 10% 10% 13% 23% 25% 27% 22% 26% 85% 9% 4% 2% Watching other free professional TV programmes/ films or video channels online (e.g. on YouTube channels such as Channel 4, Jamie Oliver's Foodtube or on other sites e.g. Vimeo, South Park Studios) 113 63 49 41 29 38 5 11 7 16 25 23 34 32 24 100 6 5 2 9% 10% 7% 15% 10% 7% 3% 8% 6% 10% 7% 7% 9% 11% 8% 9% 5% 7% 7% b def f 56% 44% 37% 25% 34% 4% 10% 6% 14% 22% 20% 30% 28% 21% 89% 5% 4% 2% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home GENDER AGE GROUP HOUSEHOLD INCOME SOCIAL GROUP NATION UNDER £11.5K- £17.5K- ENG Total MALE FEMALE 16-24 25-34 35-54 55+ £11.5K £17.5K £29.9K £30K+ AB C1 C2 DE LAND SCOT LAND WALES NI Significance Level: 95% a b c d e f g h i j k l m n o p q r Unweighted total 1687 806 881 368 375 741 203 213 158 243 426 376 538 359 414 1081 213 224 169 Effective Weighted Sample 1240 591 649 265 279 539 157 157 124 171 319 271 403 274 307 970 141 161 150 Total 1302 610 692 272 297 577 156 139 119 168 356 333 376 297 296 1106 104 66 27 47% 53% 21% 23% 44% 12% 11% 9% 13% 27% 26% 29% 23% 23% 85% 8% 5% 2% Watching 'live' TV programmes/ content via your internet connection 73 43 30 25 21 25 2 5 5 12 17 17 20 20 16 66 5 1 1 6% 7% 4% 9% 7% 4% 1% 4% 4% 7% 5% 5% 5% 7% 5% 6% 5% 1% 4% b ef f q 59% 41% 34% 28% 35% 3% 7% 6% 17% 23% 23% 28% 27% 22% 90% 7% 1% 2% Other * * - * - - - * - - - - * - - - - * - *% *% -% *% -% -% -% *% -% -% -% -% *% -% -% -% -% *% -% 100% -% 100% -% -% -% 100% -% -% -% -% 100% -% -% -% -% 100% -% WATCHING VIDEO CONTENT 415 221 194 125 110 160 20 51 35 61 98 101 130 88 96 356 32 20 6 32% 36% 28% 46% 37% 28% 13% 36% 29% 36% 28% 30% 35% 30% 32% 32% 31% 30% 24% b def ef f j r 53% 47% 30% 27% 38% 5% 12% 8% 15% 24% 24% 31% 21% 23% 86% 8% 5% 2% IPTV 298 164 134 100 71 117 10 31 22 41 74 72 93 67 67 255 25 14 4 23% 27% 19% 37% 24% 20% 6% 22% 19% 24% 21% 22% 25% 22% 23% 23% 24% 22% 15% b def f f r 55% 45% 34% 24% 39% 3% 10% 7% 14% 25% 24% 31% 22% 22% 86% 8% 5% 1% None of these 629 255 374 81 133 308 107 65 58 72 180 165 165 156 144 538 45 34 12 48% 42% 54% 30% 45% 53% 69% 47% 48% 43% 51% 50% 44% 52% 49% 49% 44% 52% 43% a c cd cde l 41% 59% 13% 21% 49% 17% 10% 9% 11% 29% 26% 26% 25% 23% 85% 7% 5% 2% Don't know 41 14 28 6 3 21 11 2 6 3 11 11 13 6 11 34 4 2 1 3% 2% 4% 2% 1% 4% 7% 2% 5% 2% 3% 3% 3% 2% 4% 3% 4% 3% 4% d cd 33% 67% 15% 7% 50% 27% 6% 14% 8% 27% 27% 31% 15% 27% 83% 9% 5% 3% Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c ~d e f g h i j k l m n o Unweighted total 1687 118 115 132 97 134 121 114 126 124 1283 404 1110 573 805 882 Effective Weighted Sample 1240 114 109 128 94 129 117 111 121 119 1055 196 809 441 564 676 Total 1302 155 171 128 83 130 124 105 60 149 1143 159 898 402 581 721 12% 13% 10% ** 10% 10% 8% 5% 11% 88% 12% 69% 31% 45% 55% Online gaming 404 52 48 33 ** 32 42 43 19 39 358 46 266 136 168 235 31% 34% 28% 26% ** 24% 34% 41% 31% 26% 31% 29% 30% 34% 29% 33% bcei 13% 12% 8% ** 8% 10% 11% 5% 10% 89% 11% 66% 34% 42% 58% Watching DVDs/ Blu Ray DVDs 254 32 23 34 ** 14 30 27 13 29 234 21 185 67 103 152 20% 20% 14% 26% ** 11% 24% 25% 22% 20% 20% 13% 21% 17% 18% 21% e be be be e k 12% 9% 13% ** 6% 12% 10% 5% 12% 92% 8% 73% 26% 40% 60% Watching TV programmes/ films on catchup services (e.g. BBC iPlayer, ITV Player, 4OD, Demand 5 or Sky Go 200 23 22 19 ** 17 12 26 17 27 182 19 137 61 80 120 15% 15% 13% 15% ** 13% 10% 25% 28% 18% 16% 12% 15% 15% 14% 17% bef abcef 11% 11% 10% ** 8% 6% 13% 8% 14% 91% 9% 69% 30% 40% 60% Browsing the web/ internet 191 24 28 16 ** 16 17 21 13 15 174 17 120 69 76 115 15% 16% 16% 13% ** 13% 14% 20% 21% 10% 15% 11% 13% 17% 13% 16% i i 13% 14% 8% ** 8% 9% 11% 7% 8% 91% 9% 63% 36% 40% 60% Watching short video clips online (e.g. YouTube or Dailymotion) 137 20 13 20 ** 6 11 13 9 15 125 12 96 39 48 89 11% 13% 8% 16% ** 5% 9% 12% 15% 10% 11% 7% 11% 10% 8% 12% e e e e n 15% 10% 15% ** 4% 8% 9% 7% 11% 91% 9% 70% 28% 35% 65% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c ~d e f g h i j k l m n o Unweighted total 1687 118 115 132 97 134 121 114 126 124 1283 404 1110 573 805 882 Effective Weighted Sample 1240 114 109 128 94 129 117 111 121 119 1055 196 809 441 564 676 Total 1302 155 171 128 83 130 124 105 60 149 1143 159 898 402 581 721 12% 13% 10% ** 10% 10% 8% 5% 11% 88% 12% 69% 31% 45% 55% Watching purchased TV programmes/ films online or downloads, either via pay per view services (e.g. Playstation Movies, Blinkbox) or via a 'standalone' subscription service (e.g. LoveFilm Instant, Netflix) 124 9 11 14 ** 10 9 16 9 21 114 10 86 35 50 74 10% 6% 6% 11% ** 8% 7% 15% 15% 14% 10% 7% 10% 9% 9% 10% ab ab 8% 9% 11% ** 8% 7% 13% 8% 17% 92% 8% 70% 29% 40% 60% Watching other free professional TV programmes/ films or video channels online (e.g. on YouTube channels such as Channel 4, Jamie Oliver's Foodtube or on other sites e.g. Vimeo, South Park Studios) 113 20 14 6 ** 12 9 13 9 13 104 9 76 34 37 76 9% 13% 8% 5% ** 9% 7% 12% 14% 8% 9% 5% 9% 9% 6% 11% c c c n 18% 12% 6% ** 10% 8% 12% 8% 11% 92% 8% 68% 30% 33% 67% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. Base : Those who have access to a games console at home ENGLAND REGIONS URBANITY WORKING DEPRIVATION LEVEL EAST SOUTH SOUTH EAST WEST OF YORKS& NORTH NORTH MEDIUM/ Total LONDON EAST WEST MIDS MIDS ENG HUMBER EAST WEST URBAN RURAL YES NO LOW HIGH Significance Level: 95% a b c ~d e f g h i j k l m n o Unweighted total 1687 118 115 132 97 134 121 114 126 124 1283 404 1110 573 805 882 Effective Weighted Sample 1240 114 109 128 94 129 117 111 121 119 1055 196 809 441 564 676 Total 1302 155 171 128 83 130 124 105 60 149 1143 159 898 402 581 721 12% 13% 10% ** 10% 10% 8% 5% 11% 88% 12% 69% 31% 45% 55% Watching 'live' TV programmes/ content via your internet connection 73 9 7 10 ** 4 6 11 6 12 70 3 45 28 27 46 6% 6% 4% 7% ** 3% 5% 10% 10% 8% 6% 2% 5% 7% 5% 6% e e k 13% 9% 13% ** 6% 8% 15% 8% 16% 95% 5% 62% 38% 37% 63% Other * - - - ** - - - - - * - - * - * *% -% -% -% ** -% -% -% -% -% *% -% -% *% -% *% -% -% -% ** -% -% -% -% -% 100% -% -% 100% -% 100% WATCHING VIDEO CONTENT 415 59 39 46 ** 24 45 40 24 49 379 36 290 123 160 255 32% 38% 23% 35% ** 19% 36% 38% 39% 33% 33% 22% 32% 31% 28% 35% be be be be be e k n 14% 10% 11% ** 6% 11% 10% 6% 12% 91% 9% 70% 30% 39% 61% IPTV 298 40 28 31 ** 19 29 32 20 38 270 28 197 99 116 182 23% 26% 17% 24% ** 15% 23% 31% 33% 25% 24% 17% 22% 25% 20% 25% e be be e n 13% 9% 10% ** 6% 10% 11% 7% 13% 91% 9% 66% 33% 39% 61% None of these 629 57 83 74 ** 78 57 41 28 82 538 91 441 188 314 316 48% 37% 48% 57% ** 60% 45% 39% 47% 55% 47% 57% 49% 47% 54% 44% ag afgh ag j o 9% 13% 12% ** 12% 9% 7% 5% 13% 85% 15% 70% 30% 50% 50% Don't know 41 3 9 2 ** 6 4 4 2 3 36 5 28 13 13 28 3% 2% 5% 2% ** 5% 3% 4% 3% 2% 3% 3% 3% 3% 2% 4% 7% 21% 6% ** 15% 9% 9% 4% 7% 88% 12% 67% 33% 32% 68% Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. ## Qb5 (Qb6) Does Your Household'S E-Reader (Digital Book Reader) Have Built-In 3G Or 4G Access To A Mobile Network? This Means That Books Can Be Purchased Online And Downloaded From Anywhere With A Signal, Without The Need For A Wi-Fi Connection? Base : Those who personally use an e-reader/ digital book reader | GENDER | AGE GROUP | HOUSEHOLD INCOME | SOCIAL GROUP | NATION | |-------------------------------------------------------------|-------------|--------------------|----------------|----------| | UNDER | £11.5K- | £17.5K- | ENG | | | Total | MALE | FEMALE | 16-24 | 25-34 | | SCOT | | | | | | LAND | WALES | NI | | | | Significance Level: 95% | | | | | | a | b | ~c | d | e | | Unweighted total | 656 | 296 | 360 | 81 | | Effective Weighted Sample | 485 | 222 | 263 | 57 | | Total | 520 | 235 | 285 | 58 | | 45% | 55% | ** | 20% | 41% | | Yes | 225 | 110 | 115 | ** | | 43% | 47% | 40% | ** | 43% | | 49% | 51% | ** | 20% | 45% | | No | 256 | 107 | 149 | ** | | 49% | 46% | 52% | ** | 49% | | 42% | 58% | ** | 20% | 39% | | Don't know | 39 | 18 | 21 | ** | | 8% | 8% | 7% | ** | 8% | | 47% | 53% | ** | 23% | 35% | | Columns Tested: a,b - c,d,e,f - g,h,i,j - k,l,m,n - o,p,q,r | | | | | All data have been weighted to ensure they are representative of the UK adult population. Ofcom does not quota or weight by household income, so it may not be representative of the UK population, but it is included for reasons of interest. Any break column with a base size lower than 100 has been removed as margins of error become too great. Data is tested at the 95% confidence level. ## Qb5 (Qb6) Does Your Household'S E-Reader (Digital Book Reader) Have Built-In 3G Or 4G Access To A Mobile Network? This Means That Books Can Be Purchased Online And Downloaded From Anywhere With A Signal, Without The Need For A Wi-Fi Connection? Base : Those who personally use an e-reader/ digital book reader | ENGLAND REGIONS | URBANITY | WORKING | DEPRIVATION LEVEL | |---------------------------|------------|-----------|---------------------| | EAST | | | | | SOUTH | SOUTH | EAST | WEST | | Total | LONDON | EAST | WEST | | Significance Level: 95% | ~a | ~b | ~c | | Unweighted total | 656 | 35 | 56 | | Effective Weighted Sample | 485 | 34 | 53 | | Total | 520 | 47 | 85 | | ** | ** | ** | ** | | Yes | 225 | ** | ** | | 43% | ** | ** | ** | | k | | | | | ** | ** | ** | ** | | No | 256 | ** | ** | | 49% | ** | ** | ** | | ** | ** | ** | ** | | Don't know | 39 | ** | ** | | 8% | ** | ** | ** | | o | | | | | ** | ** | ** | ** | Columns Tested: a,b,c,d,e,f,g,h,i - j,k - l,m - n,o
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Department family Entity Date Expense Type Expense area Supplier Transaction number Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Clinical Other NON RECURRENT PROGRAMMES OXFED HEALTH & CARE LTD 10755017 79,532.24 OXFED013 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector PLANNED CARE OXFORD FERTILITY UNIT 10768203 47,446.00 ORU0814 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector PLANNED CARE BPAS 10768210 37,350.20 855924881 29615 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector PLANNED CARE BPAS 10768267 35,544.26 855924881 29845 Department of Health NHS Oxfordshire CCG 29/02/2016 Other Research Exp NON RECURRENT PROGRAMMES UNIVERSITY OF OXFORD 10784752 (94,727.00) 125506730 210027599 Department of Health NHS Oxfordshire CCG 29/02/2016 Other Research Exp NON RECURRENT PROGRAMMES UNIVERSITY OF OXFORD 10820946 94,727.00 125506730 210024001 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Clinical Other NON RECURRENT PROGRAMMES OXFED HEALTH & CARE LTD 10820960 79,532.24 OXFED014 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector PLANNED CARE INHEALTH ENDOSCOPY LTD 10820992 36,837.83 1150 Department of Health NHS Oxfordshire CCG 29/02/2016 Other Research Exp NON RECURRENT PROGRAMMES UNIVERSITY OF OXFORD 10821042 47,363.50 125506730 210027600 Department of Health NHS Oxfordshire CCG 29/02/2016 External Contractors QUALITY ASSURANCE SUE RYDER CARE 10821205 66,000.00 11605 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING CIRCLEREADING T/A CIRCLE HOSPITAL (READING) LTD 10850918 49,791.36 10Q082015OP Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING CIRCLEREADING T/A CIRCLE HOSPITAL (READING) LTD 10850962 50,669.57 10Q092015OP Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING HORTON NHS TREATMENT CENTRE 10851020 143,576.90 426505170 HOROXFR201507 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING NUFFIELD HEALTH 10851062 51,084.00 564291137 DECEMBER2015006 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING FOSCOTE PRIVATE HOSPITAL (BMI) 10851074 35,157.54 10QFOSM08NOVEMBER15ADDITIONAL Department of Health NHS Oxfordshire CCG 29/02/2016 Accruals <1Yr-NHS Period End Accrual BALANCE SHEET SOUTH WARWICKSHIRE NHS FOUNDATION TRUST 10851097 68,089.99 W0091122 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector NCAS/OATS BMI HEALTHCARE COLLECTIONS 10851328 25,167.39 51906 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING BERKSHIRE INDEPENDENT HOSPITAL & READING NHS TREATMENT CENTRE 10880886 36,475.00 OXD0116 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Non Contract PROGRAMME PROJECTS OXFORD UNIVERSITY HOSPITALS NHS TRUST 10896291 34,986.00 8222113 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING OXFORD UNIVERSITY HOSPITALS NHS TRUST 10896295 24,731,493.00 8222154 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING OXFORD UNIVERSITY HOSPITALS NHS TRUST 10896297 471,528.00 8222155 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec NHS CCG-Contract Baseline ACUTE COMMISSIONING NHS SLOUGH CCG 10896305 271,061.00 7028101268 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline PLANNED CARE OXFORD HEALTH NHS FOUNDATION TRUST 10896313 244,000.00 GB654935896 A0096456 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline COMMUNITY SERVICES OXFORD HEALTH NHS FOUNDATION TRUST 10896320 5,404,166.67 GB654935896 A0096457 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Cost per Case MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 10896320 1,677,333.33 GB654935896 A0096457 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline OUT OF HOURS OXFORD HEALTH NHS FOUNDATION TRUST 10896320 484,333.33 GB654935896 A0096457 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING GREAT WESTERN HOSPITALS NHS FOUNDATION TRUST 10896324 247,341.00 16961102 Department of Health NHS Oxfordshire CCG 29/02/2016 Charges from CSU FINANCE NHS CENTRAL SOUTHERN CSU 10896337 405,516.42 7311703258 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING ROYAL BERKSHIRE NHS FOUNDATION TRUST 10896341 1,635,396.00 654938593 476099 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline Winter Resilience SOUTH CENTRAL AMBULANCE SERVICE NHS FOUNDATION TRUST 10913489 189,788.34 INV00000000041382 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector PALLIATIVE CARE SUE RYDER CARE 10913509 125,000.00 11604 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector PLANNED CARE SPECSAVERS HEARCARE LTD 10931839 32,322.94 159320215 20740089 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline PATIENT TRANSPORT SOUTH CENTRAL AMBULANCE SERVICE NHS FOUNDATION TRUST 10931916 299,198.63 INV00000000041372 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline AMBULANCE SERVICES SOUTH CENTRAL AMBULANCE SERVICE NHS FOUNDATION TRUST 10931922 1,633,265.91 INV00000000041338 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 10931964 2,661,016.50 GB654935896 A0096458 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING CIRCLEREADING T/A CIRCLE HOSPITAL (READING) LTD 10932034 79,866.00 10Q022016 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec NHS Trust-Non Contract NCAS/OATS WESTON AREA HEALTH NHS TRUST 10932063 28,494.67 X0005686 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING NUFFIELD HEALTH 10932085 96,524.00 564291137 FEBRUARY2016001 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING BMI FOSCOTE HOSPITAL 10932106 56,404.00 10QFOSM11FEB16INVOICE Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING GLOUCESTERSHIRE HOSPITALS NHS FOUNDATION TRUST 10932131 32,193.00 1013713 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING CIRCLEREADING T/A CIRCLE HOSPITAL (READING) LTD 10948227 52,788.39 NOINV854 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Cost per Case COMMUNITY SERVICES OXFORD HEALTH NHS FOUNDATION TRUST 11002364 34,884.00 GB654935896 A0096122 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Over/ Under Performance PLANNED CARE OXFORD HEALTH NHS FOUNDATION TRUST 11002389 27,270.75 GB654935896 A0096123 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS OXFORD UNIVERSITY HOSPITALS NHS TRUST 11002434 71,452.07 8223351 Department of Health NHS Oxfordshire CCG 29/02/2016 Other Research Exp NON RECURRENT PROGRAMMES UNIVERSITY OF OXFORD 11002531 60,806.00 125506730 210027994 Department of Health NHS Oxfordshire CCG 29/02/2016 Other Research Exp NON RECURRENT PROGRAMMES UNIVERSITY OF OXFORD 11002600 111,986.00 125506730 210027995 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Non Contract NCAS/OATS OXFORD UNIVERSITY HOSPITALS NHS TRUST 11002704 (71,452.07) CN8223351 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING RETHINK 11041023 46,750.00 9167 Department of Health NHS Oxfordshire CCG 29/02/2016 Other Gen Supplies & Srv PRESCRIBING NORTH WEST OSTOMY SUPPLIES 11041123 107,901.55 391-5320-58 71 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline COMMUNITY SERVICES OXFORD HEALTH NHS FOUNDATION TRUST 11041149 150,000.00 GB654935896 A0096817 Department of Health NHS Oxfordshire CCG 29/02/2016 Other Gen Supplies & Srv PRESCRIBING NORTH WEST OSTOMY SUPPLIES 11041168 84,840.02 391-5320-58 67 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE COMMISSIONING HORTON NHS TREATMENT CENTRE 11041234 428,071.54 426505170 HOROXF201511A Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector PLANNED CARE OXFORD FERTILITY UNIT 11057845 37,421.00 OFU0834 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BAMPTON MEDICAL PRACTICE 11064989 30,467.86 OX000014090 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES BAMPTON MEDICAL PRACTICE 11064989 1,369.40 OX000014090 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BLETCHINGTON ROAD SURGERY 11064993 (44,988.18) OX000014094 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BLETCHINGTON ROAD SURGERY 11064994 93,570.66 OX000014095 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES BLETCHINGTON ROAD SURGERY 11064994 3,411.20 OX000014095 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES COKER CLOSE HEALTH CENTRE 11065004 56,509.67 OX000014105 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Prsc Chrgs Cll&Rmttd by GPs LOCAL ENHANCED SERVICES COKER CLOSE HEALTH CENTRE 11065004 1,746.60 OX000014105 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES CROPREDY SURGERY 11065007 (33,579.66) OX000014108 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES CROPREDY SURGERY 11065008 61,917.29 OX000014109 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES CROPREDY SURGERY 11065008 2,550.20 OX000014109 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES DR A MURPHY & PARTNERS 11065009 (32,175.33) OX000014110 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES DR A MURPHY & PARTNERS 11065010 61,233.91 OX000014111 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES DR A MURPHY & PARTNERS 11065010 2,230.40 OX000014111 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES EARLS LANE HEALTH CENTRE 11065016 (82,509.88) OX000014117 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES EARLS LANE HEALTH CENTRE 11065017 187,552.71 OX000014118 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES EARLS LANE HEALTH CENTRE 11065017 7,757.20 OX000014118 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES EYNSHAM MEDICAL CENTRE 11065019 (50,883.80) OX000014120 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES EYNSHAM MEDICAL CENTRE 11065020 88,654.64 OX000014121 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES EYNSHAM MEDICAL CENTRE 11065020 3,107.80 OX000014121 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES GORING & WOODCOTE MEDICAL PRACTICE 11065023 (43,890.28) 879063483 OX000014126 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES GORING & WOODCOTE MEDICAL PRACTICE 11065024 94,186.26 879063483 OX000014127 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES GORING & WOODCOTE MEDICAL PRACTICE 11065024 3,821.20 879063483 OX000014127 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES MARCHAM ROAD HEALTH CENTRE 11065039 (36,079.93) OX000014142 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES MARCHAM ROAD HEALTH CENTRE 11065040 70,262.35 OX000014143 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES MARCHAM ROAD HEALTH CENTRE 11065040 3,009.40 OX000014143 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES MORLAND HOUSE SURGERY 11065042 (55,878.63) OX000014145 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES MORLAND HOUSE SURGERY 11065043 97,810.94 OX000014146 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Prsc Chrgs Cll&Rmttd by GPs LOCAL ENHANCED SERVICES MORLAND HOUSE SURGERY 11065043 3,271.80 OX000014146 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES NETTLEBED SURGERY 11065046 (31,740.12) OX000014149 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES NETTLEBED SURGERY 11065047 53,520.02 OX000014150 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Prsc Chrgs Cll&Rmttd by GPs LOCAL ENHANCED SERVICES NETTLEBED SURGERY 11065047 2,640.40 OX000014150 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES SONNING COMMON HEALTH CENTRE 11065053 33,504.68 OX000014156 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Prsc Chrgs Cll&Rmttd by GPs LOCAL ENHANCED SERVICES SONNING COMMON HEALTH CENTRE 11065053 1,795.80 OX000014156 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES SHEEP STREET SURGERY BURFORD 11065056 41,267.74 OX000014159 AP Amount (£) VAT registration number Purchase invoice number Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES SHEEP STREET SURGERY BURFORD 11065056 1,927.00 OX000014159 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES SIBFORD SURGERY 11065058 26,036.75 GB879117988 OX000014161 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES SIBFORD SURGERY 11065058 1,549.80 GB879117988 OX000014161 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES VICTORIA HOUSE SURGERY 11065064 36,055.07 OX000014167 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES VICTORIA HOUSE SURGERY 11065064 1,369.40 OX000014167 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WHITE HORSE MEDICAL CENTRE 11065066 (66,294.95) OX000014169 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES WHITE HORSE MEDICAL CENTRE 11065067 4,870.80 OX000014170 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WHITE HORSE MEDICAL CENTRE 11065067 156,629.28 OX000014170 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WALLINGFORD MEDICAL PRACTICE 11065068 (27,358.60) OX000014171 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WALLINGFORD MEDICAL PRACTICE 11065069 55,398.14 OX000014172 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-PMS Prsc Chrgs Cll&Rmttd by GPs LOCAL ENHANCED SERVICES WALLINGFORD MEDICAL PRACTICE 11065069 2,763.40 OX000014172 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WATERY LANE SURGERY 11065071 40,081.64 OX000014174 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES WATERY LANE SURGERY 11065071 2,107.40 OX000014174 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WYCHWOOD SURGERY 11065077 41,383.41 OX000014180 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES WYCHWOOD SURGERY 11065077 1,951.60 OX000014180 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WINDRUSH MEDICAL PRACTICE WITNEY 11065078 (37,956.00) OX000014181 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES WINDRUSH MEDICAL PRACTICE WITNEY 11065079 56,465.70 OX000014182 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES WINDRUSH MEDICAL PRACTICE WITNEY 11065079 2,000.80 OX000014182 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES CHIPPING NORTON HEALTH CENTRE 11065082 (88,432.48) GB186693943 OX000014185 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES CHIPPING NORTON HEALTH CENTRE 11065083 132,994.56 GB186693943 OX000014186 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES CHIPPING NORTON HEALTH CENTRE 11065083 4,247.60 GB186693943 OX000014186 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BLOXHAM & HOOK NORTON SURGERIES 11065575 (41,551.77) GB 879120308 OX000014124 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS PrscrptnChrgsColl&RmttdbyGP LOCAL ENHANCED SERVICES BLOXHAM & HOOK NORTON SURGERIES 11065576 3,271.80 GB 879120308 OX000014125 Department of Health NHS Oxfordshire CCG 29/02/2016 C&M-GMS Cost of Drugs -Dispensing LOCAL ENHANCED SERVICES BLOXHAM & HOOK NORTON SURGERIES 11065576 89,114.26 GB 879120308 OX000014125 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING PRINCIPAL MEDICAL 11069764 55,833.33 2001534 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector LONG TERM CONDITIONS PRINCIPAL MEDICAL 11069776 44,333.33 2001535 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec NHS CCG-Contract Baseline ACUTE COMMISSIONING NHS SLOUGH CCG 11082006 294,062.00 7028101298 Department of Health NHS Oxfordshire CCG 29/02/2016 External Contractors COMMISSIONING NEWTON EUROPE LTD 11099617 54,000.00 781906503 OCCG01001P Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec NHS Trust-Non Contract NCAS/OATS UNIVERSITY HOSPITALS COVENTRY AND WARWICKSHIRE NHS TRUST 11110319 28,453.89 1000039244 Department of Health NHS Oxfordshire CCG 29/02/2016 Cont Care-Physical Disab (65+) CHC ADULT JOINT FUNDED OXFORDSHIRE COUNTY COUNCIL 11110438 3,888,469.00 3920048089 Department of Health NHS Oxfordshire CCG 29/02/2016 Cont Care-Physical Disab (<65) CHC ADULT JOINT FUNDED OXFORDSHIRE COUNTY COUNCIL 11110438 612,099.17 3920048089 Department of Health NHS Oxfordshire CCG 29/02/2016 Continuing Care- Equipment CHC ADULT JOINT FUNDED OXFORDSHIRE COUNTY COUNCIL 11110438 88,416.67 3920048089 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Othe Public Sector LEARNING DIFFICULTIES OXFORDSHIRE COUNTY COUNCIL 11110438 1,090,228.92 3920048089 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline MENTAL HEALTH SERVICES - COLLABORATIVE COMMISSIONING OXFORD HEALTH NHS FOUNDATION TRUST 11110484 160,827.00 GB654935896 A0096823 Department of Health NHS Oxfordshire CCG 29/02/2016 Clinical&Medical-Independent Sector ACUTE ELDERLY SERVICES AGE CONCERN OXFORDSHIRE 11110518 48,723.00 AUKO0000000512 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline ACUTE COMMISSIONING OXFORD UNIVERSITY HOSPITALS NHS TRUST 11110549 24,738,493.00 8224294 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline COMMUNITY SERVICES OXFORD UNIVERSITY HOSPITALS NHS TRUST 11110549 118,583.00 8224294 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec NHS Trust-Contract Baseline ACUTE COMMISSIONING BUCKINGHAMSHIRE HEALTHCARE NHS TRUST 11110640 235,587.87 654 4313 46 BB005016 Department of Health NHS Oxfordshire CCG 29/02/2016 Hcare Srv Rec Fdtn Trust-Contract Baseline AMBULANCE SERVICES SOUTH CENTRAL AMBULANCE SERVICE NHS FOUNDATION TRUST 11110689 1,633,265.92 INV00000000041646
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## 30 July 2015 Offender Management Statistics Bulletin, England and Wales Quarterly January to March 2015 Ministry of Justice Statistical Bulletin Ministry of Justice S Statistical Bulletin ## Introduction This bulletin provides the latest statistics relating to offenders who are in prison or supervised in the community in England and Wales. The statistics are presented in detail, with commentary, and reference to longer term trends, in the following sections of the bulletin. This bulletin covers the prison population as at 30 June 2015 and the probation caseload as at 31 March 2015, and compares them to the same time in the previous year. This bulletin also covers prison receptions and probation starts, as the flows into these services, and releases from prison and probation terminations, as the flows out of these services. For each of these topics this bulletin reports on the quarter January to March 2015, compared to the same period in the previous year. This edition of the bulletin is accompanied by two further documents. The "Statistical Notice and Consultation - Part 4" provides detail on the changes to the reporting of prison population statistics. This principally covers the introduction of more detailed sentence length breakdowns and the transition over to the offence groups that the Office for National Statistics introduced in 2013. The second document is the "Revision of Release on Temporary Licence figures". This provides detail on the revisions made as a result of an error that has been identified in the figures on the sentence type breakdown for individuals released on temporary licence. We are undertaking a short survey alongside this publication. This in order to understand how well our statistics meet user needs, gather feedback on the series, and help determine what areas future improvements should focus on. Users are encouraged to have their say at the link provided: www.surveymonkey.com/s/3RM5K8D Further information about background, data definitions, data quality issues, and users of the statistics are available in the accompanying document. The next edition of this bulletin, covering the period April to June 2015, with prison population figures as at 30 September, will be published on 29 October at 9.30am. ## Key Findings  The prison population has continued to increase, but has grown by less than 1% over the last twelve months. This overall increase was driven by a 2% increase in the sentenced population, the remand and non criminal population both decreased over the last twelve months.  The sentenced prison population continues to shift towards a population serving longer determinate sentences. Over the last twelve months the sentenced population serving determinate sentences of four years or more continued to increase. It can now be reported that 5% of the prison population, is serving a determinate sentence of ten years or more.  The prison population is also increasingly being made up of older prisoners. The numbers in the age groups 50 to 59, and 60 and over, continued to increase over the last year, and now are at their highest ever recorded levels. Taken together, those aged 50 and over, represented 1 in 14 prisoners on 30 June 2002, and as at 30 June 2015, represented 1 in 7 prisoners.  Prison receptions and releases for determinate sentences decreased across all sentence lengths over the last year, apart from receptions for long determinate sentences of four years or more, which increased.  While the total probation caseload rose by 1% between the quarters ending March 2014 and March 2015, that of the court order caseload fell by 1%.  The number of offenders starting community orders fell by 5% over this period, whilst starts of suspended sentence orders with requirements attached increased by 2%. The fall in community order starts is consistent with quarter on quarter trends seen over the past couple of years, and with the trends in court sentencing statistics over the same period.  The proportion of offenders not returned to custody by the end of June 2015, following a licence recall over the whole period 1999 to the end of March 2015, remained constant with only 6 in every 1,000 prisoners not being returned to custody. ## Prison Population The prison population grew rapidly between 1993 and 2008, at an average of 4% a year. This rapid rise was driven by:  Increases in the number of people sentenced to immediate custody from 1993 to 2002;  Increases in the average custodial sentence length and increased use of indeterminate sentences; and  Increases in the number of offenders recalled to prison following breaches of their licence conditions, along with increases in the average length of time these offenders spent in prison once recalled. The rise in the prison population slowed considerably from the summer of 2008, in part due to the introduction of the Criminal Justice and Immigration Act 2008, which changed sentencing and offender management in ways which helped to reduce growth in the prison population. This flatter trend continued until the public disorder seen in UK cities from 6 to 9 August 2011 which had an immediate but temporary impact on the prison population. During 2012 and into 2013, the prison population began to fall due to a falling remand population and a continued decline in the number of under 18s in custody. The falling remand population during 2012 reflected falling volumes going through the courts plus the introduction of the Legal Aid, Sentencing and Punishment of Offenders (LASPO) Act in December 2012. This Act restricted the use of remand for offenders who would be unlikely to receive a custodial sentence. The 'Story of the Prison Population 1993 to 2012' is an in-depth look at what happened to the prison population between 1993 and 2012 and the major factors contributing to the changes. Following the LASPO Act in December 2012, and up until the end of June 2013, the prison population stabilised. In particular, by March 2013 the remand population stopped falling as it had done since August 2011. After settling at a lower level the remand population then began to rise again from August 2013, and contributed to the sharp rise in the prison population seen between the end of August and October 2013. Overall, since June 2013 the prison population has increased, albeit at a slower rate than in previous years, typically growing at around 1% a year. This edition of Offender Management Statistics Quarterly (OMSQ) includes the annual prison population tables. These provide a long run time series for many of the quarterly prison population tables, as well as additional further breakdowns. Growth in the size of the prison population has slowed slightly, growing at less than 1% over the last twelve months to 30 June 2015. This overall increase was driven by a 2% increase in the sentenced population, the remand and non criminal populations both decreased over the last twelve months. Since late 2014, the remand population has steadily decreased to be at just under 12,000 prisoners, which is slightly less than last year. This is consistent with Criminal Court Statistics Quarterly which shows there to be a decreased number of outstanding cases in the Crown Court. It is too early to say if this is a change in the observed trend for the remand population since August 2013. In this edition of OMSQ, as a result of improvements to IT, the presentation of particular prison population statistics has changed. From this quarter onwards more detailed sentence length breakdowns that are more reflective of the current sentencing framework used by the courts have been introduced. These new breakdowns enable better reporting on those prisoners in the population serving longer determinate sentences and Extended Determinate Sentences (EDS). Further information on these changes can be found in the "Statistical Notice and Consultation - Part 4", which is published alongside this bulletin. Whilst the sentenced population only increased slightly, its composition continued to change. The number serving sentences less than four years decreased whereas those serving determinate sentences of four years or more continued to increase. Over the twelve months to June 2015, the number of prisoners serving these long determinate sentences increased by 6%. Much of this increase is attributable to the population serving an EDS; there were 1,946 prisoners serving an EDS on 30 June 2015, which is double the number from 12 months ago (1,043 prisoners on 30 June 2014). On 30 June 2015, a third of the prison population was serving a determinate sentence of four years or more, or an EDS. As part of the more detailed breakdown on sentence lengths introduced, it can now be reported that 4,420 prisoners, representing 5% of the total prison population, were serving determinate sentences of ten years of more. The number of prisoners serving indeterminate sentences (IPP or life) was down 4% on the previous year, to 12,053. This decrease is explained entirely by a decrease in the IPP population. As a result of the abolition of the IPP sentence, offenders are no longer receiving these sentences and prisoners are only being released from this population. Since the IPP sentenced was abolished, the IPP population has fallen by almost a quarter from 6,020 as at the end of September 2012 to 4,614 as at the end June 2015. The number of IPP prisoners who are post-tariff has remained flat over the last year, meaning that the proportion of the population post-tariff has been increasing. For the first time more than three quarters of IPP prisoners are now post-tariff. The number of life sentenced prisoners remained stable at slightly under 7,500. There were 51 whole-life prisoners at the end of June 2015, with five additional life prisoners being treated in secure hospitals. The whole-life population has decreased by one from the last quarter because of a successful appeal to quash a whole-life sentence. This edition of OMSQ also makes, for prison population statistics only, the transition over to the offence groups that the Office for National Statistics (ONS) introduced in 2013. This improves consistency with other National Statistics publications on the Criminal Justice System in the Ministry of Justice, Home Office and the ONS. For this edition of OMSQ, we have also retained the figures on the old offence groups so that comparisons can be made. For more information on how these new offence groups compare to our previous offence groups please refer to the "Statistical Notice and Consultation - Part 4", which is published alongside this bulletin. The rise in the long determinate sentenced population is in line with the increasing number of sentenced sex offenders. At the end of June 2015 there were 11,490 sentenced sex offenders in the prison population, which is 10% higher than twelve months before, and 33% higher when compared to June 2010. Furthermore, when compared to the sentenced populations for other offence groups, the sex offender sentenced population has increased the most over this five year period. This is consistent with the recent 'Crime in England and Wales' bulletin from the Office for National Statistics that reported the highest number of sexual offences recorded by the police since 2002/03, for the year ending March 2015. In contrast, the sentenced population for violence against the person offences has remained stable over the last year, and has decreased by 2% between June 2010 and June 2015. Whilst the sentenced population for violence against the person offences remains the largest sentenced population by offence group, this shows that the violence against the person offence group is no longer the key driver in prison population growth that it has been in the past. There is no clear evidence to explain the growth in the recall population, which has increased by 17% over the year. Whilst the Offender Rehabilitation Act 2014 (ORA) expanded licence supervision, so that anyone sentenced to more than a day in prison will receive at least 12 months supervision on release, this only came into effect for those who committed an offence and were sentenced after 1 February 2015. As at 30 June 2015 there were 157 prisoners recorded as being recalled under ORA, representing only 3% of the recall population. The age composition of the prison population has also changed and is increasingly being made up of older prisoners. The numbers in the age groups 50 to 59, and 60 and over, continued to increase over the last year, and now are at their highest ever recorded levels. Taken together, those aged 50 and over represented 1 in 14 prisoners on 30 June 2002, and as at 30 June 2015, represented 1 in 7 prisoners. In contrast, the populations of those aged 15 to 17, 18 to 20, and 21 to 24 have all decreased over the last year, and have fallen by almost a third compared to their highest level at the end of June 2009. This is consistent with the Youth Justice annual statistics and the Criminal Justice System Statistics on the declining number of first time entrants to the Youth Justice System since 2006/07. Whilst these age group populations have changed the most, the majority of prisoners are still aged between 30 and 39, as has been the case for the last 20 years. There was a decrease in the foreign national population in custody, which was down 3% on the previous year to 10,512 on 30 June 2015 (representing 12% of the prison population). Looking at the longer trend, the foreign national population increased from the year 2002 to its highest value of 11,498 as at the end of June 2008 when they accounted for 14% of the population. There was then a small decrease in the population until March 2011 when it fell to 10,745. Since then the foreign national population has remained stable, representing around 12-13% of the population. ## Prison Receptions First receptions count prisoners the first time they appear in prison from court. A prisoner's reception type is counted each time they are first received into custody as untried, convicted unsentenced, or sentenced prisoners from court. This means that prisoners can be counted in more than one of these categories if their custody status changes as they progress through the Criminal Justice System in the reporting period. A total of 25,555 offenders were received into custody as first receptions in the quarter ending March 2015, a fall of 2% on the same quarter last year. There was no change in the number of untried receptions but there was a 5% fall in convicted unsentenced receptions. Sentenced receptions overall fell slightly (1%), with large decreases in fine defaulter and indeterminate receptions. In contrast there were increases in receptions to longer determinate sentences of between 12 months and four years, and more than four years. There was a continued increase in sentenced receptions for burglary and sexual offences, but decreases in receptions for all other offence groups, in particular, theft and handling and robbery. ## Prison Releases A total of 17,300 offenders were released from custody in the quarter ending March 2015, a fall of 6% on the same quarter last year. This has been driven by decreases in the number of releases across all determinate sentence length bands. In contrast, releases from IPP and life sentences have increased by 6% and 31% respectively. There were 107 prisoners released from an IPP and a further 101 from a life sentence, making up a 17% increase in releases from indeterminate sentences when compared to the same period last year. In addition, 19 indeterminate sentenced prisoners were removed under the Tariff Expired Removal Scheme (TERS) in the latest quarter. This scheme allows indeterminate sentenced foreign national prisoners, who are liable to removal from the UK, to be deported from the country on or after the date of their tariff expiry without referral to the Parole Board. The scheme began in May 2012, and by the end of March 2015 there had been 313 removals in total. The number of releases on Home Detention Curfew (HDC) fell by 6% to 1,999 between the quarters ending March 2014 and March 2015. To be considered for release under HDC an offender must be serving a sentence of less than 4 years, and the number of offenders serving such sentences has been falling (see earlier population section). The decrease of 6% in the eligible population will have a direct impact on the number that can be considered for HDC release and the number that are subsequently released. Alongside this quarter's publication there is statistical notice to advise users that an error has been identified in the figures on the sentence type breakdown for individuals released on temporary licence (ROTL) that are reported in the Offender Management Statistics Quarterly (OMSQ) series. This error was a result of a misclassification for statistical reporting purposes only; locally held data within prisons was unaffected, as was the management of offenders within prisons. Between January and March 2015, there were 89,111 incidences of ROTL from prisons in England and Wales. This is a 29% decrease since the same period in 2014; with all types of licence showing decreases. The number of release incidences for females decreased by 24%, compared to a 29% decrease for males over the same period. The number of individuals given at least one instance of ROTL between January and March 2015 was 3,921, which represents a 29% decrease over the year. Of the individuals given at least one instance of ROTL, 21% were on an indeterminate sentence. There were 32 recorded temporary release failures (TRFs) between January and March 2015, which is less than half of the number of failures seen in same quarter of the previous year. The number of recorded failures has continued to show a decrease in every quarter since April to June 2013. ## Probation Transforming Rehabilitation is a reform programme that is changing the way offenders are managed in the community. Since 1 June 2014, Probation Trusts have been replaced by the National Probation Service (NPS), which manages the most high-risk offenders across seven divisions; and 21 new Community Rehabilitation Companies (CRCs), who manage medium and lowrisk offenders. At the end of March 2015 the probation caseload was still in transition with some cases held, both in the NPS and CRCs, pending transfer to the other organisation for reasons relating to effective risk management. The total annual probation caseload (court orders and pre and post release supervision) increased by 39% between 2000 and 2008 to 243,434. Since then the probation caseload fell year on year, reaching 217,359 at the end of 2014. However, at the end of March 2015, the total caseload stood at 221,738, up 1% on the number one year earlier. The court order caseload (offenders on community orders (COs) and suspended sentence orders (SSOs)) fell slightly by 1%, with the CO caseload falling 2% but the SSO caseload rising by 3% between the quarters ending March 2014 and 2015. The number of offenders *starting* community orders fell by 5% over this period, whilst starts of SSOs with requirements attached increased by 2%. The fall in community order starts is consistent with quarter on quarter trends seen over the past couple of years. In addition, in the quarter ending March 2015 there were 2,392 starts of SSOs without requirements attached. This brings the total number of stand-alone SSOs starts to more than 15,000 since they were introduced under the LASPO Act 2012 (see **Data sources and quality section**). The caseload of offenders supervised before or after release from prison increased by 3% between the quarters ending March 2014 and 2015, whilst the number of pre-release supervision starts has shown a steep rise of 68%, caused by the introduction of the Offender Rehabilitation Act 2014 on 1st February 2015. Under this Act all offenders given custodial sentences are now subject to statutory supervision on release from prison. Previously only adults sentenced to over 12 months in custody and all young offenders were subject to statutory supervision. With regard to the number of requirements started under court orders, there has again been a notable rise in curfews and standalone curfews in particular. This may reflect the continuing impact of a mandatory punitive requirement in every community order, introduced from December 2013 under the Crime and Courts Act 2013. There has also been a significant increase in Prohibited Activity requirements in each of the last two quarters, although these make up only a small proportion (2%) of the total requirements made under orders. Of the court orders terminated in the quarter ending March 2015, 69% of community orders were terminated successfully (they either ran their full course or were terminated early for good progress). For the supervision periods of suspended sentence orders, some 68% were terminated successfully over this period. The number of court reports prepared by the Probation Service continued to fall - a total of 39,684 court reports were prepared in the quarter ending March 2015, 1% down on the quarter ending March 2014, reflecting the continuing downward trend in the number of cases being dealt with by the courts.. In general, courts follow the sentences proposed in Pre-sentence reports (PSRs), particularly where an immediate custodial sentence has been recommended. Around 88% of such proposed sentences in PSRs resulted in immediate custody. ## Licence Recalls A key element of public protection is that offenders released on licence should be effectively supervised in the community and swiftly recalled to custody if they breach their licence or if their behaviour gives cause for concern. It is explained to offenders at the outset that they are liable to be recalled to custody if they breach any of the conditions of their licence. There are various reasons why offenders are recalled to custody for breaching their licence conditions besides committing a further offence. For example, an offender may be recalled if there is any deterioration in behaviour which leads the National Offender Management Service (NOMS) to conclude that there is an increased risk of the offender committing further offences. Between April 1999 and March 2015, 190,714 of those released on licence were recalled to custody for breaching the conditions of their licence, e.g. failing to report to their probation officer. Of all those recalled over the period, 99.4% were returned by the end of June 2015. In the latest quarter there were 4,240 recalls, which included the recall of 112 offenders who were serving custodial sentences of less than twelve months. The ORA expanded licence supervision meaning that it is now possible to recall these offenders to custody. Of all those released on licence and recalled to custody between April 1999 and March 2015, there were 1,135 who had not been returned to custody by the end of June 2015. This includes 4 people who had been recalled after a sentence of less than 12 months. The proportion of prisoners not returned to custody over this period is 0.6% and this is a relatively constant figure when compared to previous years. A further 18 offenders had not been returned to custody as of 30 June 2015 after recall between 1984 and April 1999, meaning the total number of offenders not returned to custody at the end of June 2015 was 1,153. These figures include some offenders believed to be dead or living abroad but who have not been confirmed as dead or deported. Of the 1,153 not returned to custody by 30 June 2015, 147 had originally been serving a prison sentence for violence against the person offences and a further 40 for sexual offences. ## Contact Points Press enquiries should be directed to the Ministry of Justice press office: Tel: 020 3334 3536 Other enquiries about these statistics should be directed to: Nick Mavron Ministry of Justice Justice Statistics Analytical Services 7th Floor 102 Petty France London SW1H 9AJ General enquiries about the statistical work of the Ministry of Justice, or requests for alternative formats of this publication can be e-mailed to: statistics.enquiries@justice.gsi.gov.uk General information about the official statistics system of the UK is available from: statisticsauthority.gov.uk/about-the-authority/uk-statistical-system Ministry of Justice publishes data relating to offender management in England and Wales. Equivalent statistics for Scotland and Northern Ireland can be found at: www.scotland.gov.uk/Topics/Statistics/Browse/Crime-Justice www.dojni.gov.uk/index/statistics-research/stats-research-publications.htm This publication and associated spreadsheet files of the tables contained in this document and detailed information of definitions, sources and key legislative changes are available for download at: www.gov.uk/government/collections/offender-management-statistics-quarterly ## © Crown Copyright 2015 This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk.
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## Draft Council Plan Consultation 2015 Responses From The Four Facilitated Drop In Sessions Run At West Offices To Enable Residents To Give Views On The Draft Council Plan Drop In Session - 24 July 2015 What services are most important to you? How would you protect frontline services? City Centre condition Waste Put available money in right place Schools Car parking too expensive Volunteer Citizens Advice Bureau Bus passes Cheaper parking Volunteer if transport was better Better support for disadvantaged families Public Health Get better value for money in staffing contracts. Invest in training & development. Use existing resources better Waste Adult Social Services Webcasts Would pay for council tax if maintained current services Education Health Environment Lobby against austerity Help less fortunate Already work hard in city Housing Stop cycle raves Do charity work Libraries Adult care Learning disability Train right people to support those with learning difficulties Children's services Affordable housing Living wage Streamline corporate management team Support young people Housing City centre investment Private sector investment, city tax for tourists, charge for those than can afford it What could you do to help achieve the aims for the city? How can the council support the achievement of a prosperous city? Work more with partners Don't empty green bin in winter Road repairs Volunteer Already volunteer Close inequality gap Fairer wages Support businesses to grow and make sure visitors not put off Spend local Focus on upskilling workers and think long term Reduce congestion, build new homes, reduce poverty Back proposals for social housing build | More cycling lanes | Free York Card for residents | Already volunteer | Cleaning | |----------------------------------|--------------------------------|--------------------------------|---------------------------------| | streets | | | | | Bins | Improve rail services | Already volunteer | | | Transport | Housing | | | | benefit | | | | | Social | | | | | housing | | | | | Improve care for vulnerable | Move people off benefits by | | | | providing more jobs for 18 -25s | | | | | Roads | Already volunteer | | | | Protect bus routes | Volunteered | Bins | Traffic | | movement | | | | | Better cleaning | Already volunteer | Youth clubs | Parks | | benefit | | | | | More waste bins in centre | Already volunteer | Housing | | | services | | | | | Put residents and families first | Street cleaning | Nothing, too busy | Adult Social | | care | | | | | Bins | Address homelessness | Would volunteer | | | Waste | Bus services | Education | Lower parking charges and | | encourage people to visit | | | | | Scale back adult learning | Waste | Parking | Road | | maintenance | | | | | Put frontline services before | | | | | bureaucracy | | | | | Develop brownfield sites. | | | | | Improve transport links | | | | | parks | Education | Better paid jobs | Help keep play areas clean | | Waste | | | | | Education | Services for | | | | young people | | | | | Health | Housing | Waste | Fairness in housing allocations | | Housing | Museums | Libraries | Better connect villages | | buses) | | | | | Volunteering but people need | | | | | good jobs first | | | | | Public | | | | | transport | | | | | Protect education | Fair pay | Get unemployed to do voluntary | | | work for expenses | | | | Homeless services Make planning permission easier No increase inc council tax As a landlord offer accommodation to homeless Waste Education Nothing Need well paid jobs. House prices too high Transport Metro card for city. Affordable housing CYC needs to be more efficient and staff work harder Turn up for work HR 1 stop shop for customer services Bins Education Education More things for kids to do Volunteer Volunteer as snow warden Bins Change top heavy management structure Events for residents not just tourists Bus station Bollards Reduce bed blocking, mental health therapy Improve roads Balance between roads, tourists and history Education Welfare benefits Mental health services Children get good standard of education. Apprenticeships Use voluntary work to get people into jobs Joined up care for mental health - quality and quality is poor Adult Social Care Joined up provision - work 7 days a week not Mon- Fri Mental health Spend money on these with least voice. Use early intervention Getting involved. Need to get message out about doing stuff for ourselves. Education, roads, libraries More jobs locally Library volunteers Housing benefit Parking Keep talking to the public about views Citizens Advice Bureau Clean town centre Not a fan of volunteers - services are cut and long term impact Schools Nothing Cycle more Planning Cycle lanes Bins Increase staffing and wages More parking and more park and ride Jobs Kid's activities Education Protect services fro young people Have a revolution against cuts, close tax loopholes Reduce waste and redistribute unused food Ageing Services for older LGBT people Decrease gap between rich and poor. Green renewable. No nuclear. No fracking Education Schools Don't do Lendal bridge Volunteer more Use local firms Traffic Waste Congestion charge for visitors nor residents Encourage living wage of £10 an hour. Affordable housing Services should not be reduced Support schools, keep city Education Health Social care/fostering clean, link schools to parks and gardens Child's voice, keep up swimming, safe areas for children Better roads Benefits Carer support Council tax Provide advice New green bins when one is stolen Already a carer and keep village tidy Already volunteer Bins Education Public transport Support sustainable services Use new technology better. Get a cycling officer More jobs, more mixed nightlife Volunteer in leisure centre Leisure Support Yearlsey pool and housing Housing benefits Advice Protect bin service More jobs are entry levels Community need to support council and police to reduce anti-social behaviour Drop In Session - 4 August 2015 What services are most important to you? How would you protect frontline services? Education Housing Playgrounds Cut funding to libraries and highways Leisure Parking Housing Ensure jobs are kept by using money efficiently Bins Recycling Footpaths Recycle Recycling Roads Bins Street cleaning More use of flexible contracts to manage peaks Street cleaning More local skips, cut street lights Care Schools Health Environment Protect some services Recycling and cycling Housing Waste Highways Housing and Adult Service priority Waste Housing Highways Prioritise Listen to tax payers Bins Housing repairs Parking Street cleaning Use volunteers and target resources better Bins Contact Centre Benefits Word of mouth More help for York residents on housing Transport Waste Not fiddling (Lendal Bridge) Attend residents meetings Housing repairs Bins Tackle empty shops and give shops lower rates What could you do to help achieve the aims for the city? How can the council support the achievement of a prosperous city? Better paid jobs Up to council to provide it all not me Work with others Give feedback Encourage manufacturing Listen to taxi and bus drivers Reduce council to tax for people on benefit Improve Wi-fi Volunteer Act as carers already Not waste money on vanity projects Help friends trying to get council house Bring people into city centre | Take a decision on the walls | Police | NHS | Housing | Make people work longer hours | |---------------------------------|--------------------------------|----------------------------------|---------------------------------|----------------------------------| | & variable shifts | | | | | | Community work in Fulford | Contact | | | | | Centre | | | | | | Put people in local areas | Community organisations to | | | | | work more together | | | | | | Police | Stop wasting money on roads | Education | Social | | | Services | | | | | | Community | | | | | | Safety | | | | | | Control bad behaviour | Help people to start their own | | | | | business | | | | | | Houseswap scheme | Housing | Transport | Parks | Give people less choice, be | | strict on rules | | | | | | Promote York | Not be negative about the city | All | All | All | | possible | | | | | | Give feedback | Housing | Reduce council tax benefits | More focus on residents, don't | | | charge for Art Gallery | | | | | | Watching in neighbourhood | Housing | | | | | repairs | | | | | | Resident | | | | | | parking | | | | | | Stop paying for art gallery and | | | | | | museums | | | | | | Waste | Street | | | | | cleaning | | | | | | Buses | More local services for older | | | | | and young people | | | | | | Recycling | Adult | | | | | Services | | | | | | Education | Citizens | | | | | Advice Bureau | | | | | | Stop wasting money and use | | | | | | more volunteers | | | | | | Reduce rents for city centre | | | | | | shops. Encourage pop up | | | | | | shops | | | | | | Leisure | Prioritise funding | Increase minimum wage | Fundraising for charity (local) | Housing | | services | | | | | | Housing | More ring fenced funding | Invest in skills of young people | | | | Better planning | Better planning | Already volunteer | Bins | Housing | | repairs | | | | | | Use more online services | Cycling lanes Roads | Waste | Prioritise funding | Promote York and Yorkshire | | more | | | | | | Planning | Support & help where needed | Create jobs | Business | | | Advice | | | | | | Recycling | Museums | Encourage visitors | | | | | | Housing | Youth Offending Team | Get homeless people off streets | |---------------------------------|---------------------------------|---------------------------------|---------------------------------|-----------------------------------| | NHS | GPs | Less agency workers | Invest in jobs for young people | Already work in community | | Too busy | Benefits | Bins | Housing | Protect all | | businesses into York | | | | | | All | Cut out waste and managers | Support others | Recycle | | | Bins | Green bin all year round | Recycle and shop locally | | | | Street lights | Dog mess | Nothing else York is doing fine | Keep things tidy | Street | | cleaning | | | | | | Doing Ok | Buses | Pressure government for more | | | | money | | | | | | Drug misuse | Waste | Transport | Tax the wealthy and big | | | business | | | | | | Work better with community, | | | | | | support local businesses | | | | | | Get involved in community led | | | | | | projects | | | | | | Give feedback | Waste | Open spaces Clean streets | Increase council tax | Develop brownfield sites, | | encourage shops in city centre | | | | | | Volunteer with York Carers in | | | | | | future | | | | | | Schools | Oppose academies | Digital City offer needs to be | | | | improved and service from | | | | | | Make it York | | | | | | Make suggestions to council | Police | Be more active | Restrict stag and hen parties | | | and arrest drunks | | | | | | Parking | Bins | Pay council tax that's enough | | | | Housing | | | | | | benefits | | | | | | Citizens | | | | | | Advice | | | | | | Bureau | | | | | | More for residents not visitors | Waste | Contact | | | | Centre | | | | | | Better response from contact | | | | | | centre | | | | | | Children's | | | | | | Centres | | | | | | Do more online, walk to | | | | | | schools. Use the services | | | | | | Schools | Reading cafe | Protect school places so people | | | | can get siblings in same school | | | | | | and walk to it | | | | | | Think about schools and health | | | | | | services when building new | | | | | | houses | | | | | | Housing | Protect large employers in city | Voluntary work. Use allotments | | | | Buses | Less bureaucracy | More opportunities for young | |----------------------------------|-----------------------|---------------------------------| | people | | | | National Citizenship | | | | Programme | | | | Marketing | Bins | Move CYC staff to cheap | | offices in Clifton Moor | | | | Don't know | Buses | Residents first | | to change buses. Do less for | | | | students | | | | Fit solar panels and recycle | Police | Health | | more on recycling | | | | Improve wages for carers, | | | | focus less on tourists | | | | Put English people first | Housing | | | benefits | | | | Youth clubs | Leisure | Living wage for care workers. | | Live concerts | | | | Buses | Transport | More money | | Make sure people use services | Children's | | | Centres | | | | Family | | | | Learning | | | | Libraries | Ensure enough staff | Concentrate on quality not | | quantity | | | | Prevention | Early | | | Intervention | | | | Infrastructure | Use SMART measures to | | | prioritise cost benefit analysis | | | | Tree planting, use local | | | | services, increase recycling | | | | Living wage across all sectors. | | | | Showcase city centre for | | | | tourism | | | | Education | Bins | Parking | | homelessness problem | | | | Bins | Health | Don't understand question | | No benefit cuts | Housing | Contact | | Centre | | | | Citizens | | | | Advice Bureau | | | | More staff, get school leavers | | | | into council jobs | | | | Bins | Buses | Better management | | Ward Committee meetings | Allotments | Recycling | | residents. Bring tourists in | | | | Ok as now | Is fine as it is | Health walks | | repairs | | | | Get York Central Built | Support food bank | Strategic | | Support | | | | Do things jointly with other | | | | councils. Don't bother with | | | | Ward Budgets | | | Nothing else York is doing fine Buses All Investigate who deserves services Buses More buses Look after your own Help young people more Sheltered Housing Cut waste and cut privileges for those that don't need them Bins Job creation Start up a business Parks Reduce bureaucracy Invest in public realm Join friends group Street cleaning Drop In Session - 12 August 2015 What services are most important to you? How would you protect frontline services? What could you do to help achieve the aims for the city? How can the council support the achievement of a prosperous city? Bus services Cheaper entry to attractions for locals Everyone should be able to afford to live Better co-ordination between people helping York Learning Childcare support to enable people to take up training Road safety Cycle lanes Reform council tax and business rates Grit less in winter All on road safety ideas passed to Road Safety officer Social care For those on low income Limiting the time it takes people to get to and from work Enabling business to prosper and provide jobs for young people Attend local events and initiatives to encourage neighbours to keep in touch Volunteering Street cleaning Support volunteer groups, gain more grants if possible Bus services Protect reputation of city. Prioritise the most needs, homeless /disadvantaged/elderly Bins Keep City and villages clean Clean streets Waste Recycling Flexible job roles. Prioritise Attract businesses to the city Fine householders for blocking footpaths Bus passes Education NHS Recycling - not enough money for roads and street lights Too many people in customer centre. Need to be able to measure council plan and judge success Parking Waste Buses More police Getting rid of council officials Nothing Housing Fair rents Managing Manage the roads and more flower beds Keep city centre clean Learning More information on how they operate Unlock jobs from key sites such as York central Emergency services Keep council tax as it is Better parking Don't litter put bins by road for drivers | Reduce council tax | Keep York tidy | Benefits | |-----------------------------------|------------------------------------------------------|----------------------------------| | support | | | | More housing | Benefits | | | support | | | | Homelessnes | | | | s service | | | | Focus on financial inclusion, try | | | | and mitigate welfare reforms | | | | Waste | Planning | Contact | | Centre | | | | Change the website it does not | | | | give information like the old one | | | | did | | | | Litter picking. Promoting events | Social care | Litter | | tight rein on capital projects | | | | Promote tourist industry, | | | | support business to do more - | | | | especially small businesses let | | | | York retain individuality | | | | Police | Youth | | | Services | | | | Road | | | | maintenance | | | | Feedback, volunteering and | | | | attending consultations | | | | Use volunteers, limit | | | | unnecessary excessive | | | | maintence | | | | Few meetings and more action. | | | | Not wasting money buying new | | | | equipment for events every | | | | time | | | | Housing | | | | benefit | | | | Focus on residents more in | | | | relation to social housing | | | | Better pedestrian access and | | | | public loos. Cleaning city centre | | | | streets | | | | Bins | Drugs and | | | related crime | | | | Keep complaining until things | | | | are right. Keep reporting anti- | | | | social behaviour | | | | Street lighting | Shame cuts need to be made | Drugs 3 strikes and out, get rid | | of rough sleepers near station, | | | | move homeless people to | | | | somewhere more appropriate | | | | Buses | Do a better job | Keep it clean for everyone | | Transport | Better performance information More medium level and | | | graduate jobs | | | | Colourful planting | Graffiti | Fountain | | apartments. Improve Piccadilly | | | | Adult Care | Attract new residents and | | | students | | | | Buy local, keep pubs going, use | | | | independent shops | | | Support services benefits and accommodation Arts funding Libraries Improve street cleaning in Micklegate and centre More decent tubs. More jobs for skilled people. Jobs fairs. Do less on disabled access Schools Social care Need good performance and strategy measures Unlock key employment sites like York central Cut services like fortnightly bin collections less important than social care. Parking Parks Social Care Good quality performance information to direct resources Good quality jobs Get involved in ward committees Buses Safety in city Recycling Does a good job anyway Everything works well Local plan Social services Bus user group. Volunteer for National Trust. Village Plan Rail infrastructure - look at Haxby? Strensall site. Use British Sugar site and include rail halt. Get large inward investors to stop York becoming an dormant commuter city ## Drop In Session - 13 August 2015 What services are most important to you? How would you protect frontline services? Local Plan Protect environment City Environmental plan Waste Litter City Centre Deal with crime and disorder Deal with crime and disorder Bins Daily waste collections Lower taxes Do enough already Transport Manage race meetings better Social Services Benefits Not spending on projects like Kings Square Sheltered housing Art Gallery Health Improve things for residents not tourists. Address gap between rich and poor. Need housing not hotels. Residents shouldn't pay fro art gallery Crime Council tax Too many drunks on the streets, stag and hen parties Bins Street lights health Reduce back office staff and managers Transport Police Better resident parking Waste Adult Social Care Community facilities Waste Safety Better collaborative working between departments to stop duplication Buses Housing Less for students, help small business What could you do to help achieve the aims for the city? How can the council support the achievement of a prosperous city? Positive about ward funding Improve night time economy - too much drinking and too much visible street homelessness Weekly waste collection for all Work on community activities Try to get local communities on site and be more open to explaining what is happening and why Used to volunteer to old now Not keen on leadership in CYC and councillors Adult Education Libraries Mental health Go back to core services but libraries are important Address anti-social behaviour. Improve provision for cyclists Buses Cycle routes Waste Staff already helpful Benefits Buses Youth activities Focus on frontline staff Improve congestion. Invest in arts, health and wellbeing Mental health Specialist housing for vulnerable Mental health should be at front in relation to housing Not including mental health is discriminatory Transport Planning Buses Green collection Close Lendal Bridge. Social Services Tourism Tourism - pays for services and economy Housing Roads Invest in highways maintenance Buses Street Cleaning Clean the city better. Keep York money in York Police Transport Police Too much drinking in city centre at night makes it unsafe Buses Recycling Waste City centre not safe at night due to too much drinking Switch off street lights from 12 - 5am Libraries Already efficient Children's Centres Buses Children's Centres Libraries Don't feel safe in centre at night because of anti-social behaviour Buses Waste Home helps Don't give housing to pregnant girls More jobs for young people, more apprenticeships Bins Recycling Manage race meeting better Waste Scrap bedroom tax Waste Anti-social behaviour Information Residents taking action - need to know opportunities Residents taking action - need to know opportunities ## Comments Left In Reception Over Consultation Period What services are most important to you? How would you protect frontline services? SMEs Put children at the centre focus on local businesses Transport Sack people for wrongdoing Think of residents first Residents do enough already Bins Septic tanks Street lights Get rid of managers Promote York Early intervention and prevention to reduce demand ASB Clean streets Buses reduce consultants Get Local Plan in place Housing Jobs Real wages Build more council houses charity fairs Bins Roads Buses Invest in training more Training of staff Art Gallery Museums Cut staff salaries Highways Planning Business & economy Be efficient do fewer things well. Outsource where possible. Generate income Police support businesses stop benefit cheats Care Dementia support smart working but recognise huge government cuts Infrastructure recycling congestion make inner ring road priority route Waste Environment Buses stop wasting money stop allowing events residents don't like Care Act Disabilities Nothing on health and social care integration in plan Parking Children's Services Public Health Animal Welfare green space Use volunteers, use vol sector, more online services Schools Parks Realistic taxes Can't be isolated What could you do to help achieve the aims for the city? How can the council support the achievement of a prosperous city? Growth needs to be sustainable and resident businesses Volunteer, promote York Have a Local plan, work with businesses don't forget those living in poverty 1990 3 stage congestion solution and extra flood defences take party politics out of it Free parking fro residents clamp non residents vehicles Contract to small community & voluntary services Give further views, already volunteer York is becoming too expensive to buy or renta home. Stop people buying and renting out for a profit or not to be lived in. Affordable Housing Green waste Better energy efficiency in council buildings improve parking in Heslington Lane
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# Civil Justice Statistics Quarterly, England And Wales, April To June 2016 (Incorporating Privacy Injunction Statistics, January To June 2016) Ministry of Justice Statistics bulletin Published 1 September 2016 ## Contents | Contents | 2 | |--------------------------------------------------|-----| | | | | Introduction | 3 | | | | | Changes in reporting | 4 | | | | | Users of the statistics | 4 | | | | | Next publication | 4 | | | | | Key Findings | 5 | | | | | 1: Civil (excluding family) cases | 6 | | | | | 2: Judicial Reviews at the Administrative Court | 13 | | | | | 3: Privacy Injunctions | 19 | | | | | Annex A: Planned upcoming changes to publication | 22 | | | | | Annex B: List of Accompanying Tables and CSV | 23 | | | | | Annex C: Timeline of changes to civil procedures | 24 | | | | | Annex D: Explanatory notes | 25 | | | | | Further information | 27 | | | | ## Introduction This statistical bulletin presents statistics on three key areas of civil and administrative justice:  County court civil (non-family) cases that took place in England and Wales in April to June 2016;  Judicial review cases processed by the administrative court in England and Wales up to June 2016;  Privacy Injunction cases, dealt with by the High Court or Court of Appeal, for the six month period, January to June 2016. The figures give an overview of the volume of cases dealt with by these courts over time and are used to monitor court workloads, assist in the development of policy and their subsequent monitoring and evaluation. Civil cases covered by this publication are those that do not involve family matters or failure to pay council tax. These cases are mainly dealt with by county courts and typically relate to debt, the repossession of property, personal injury, the return of goods and insolvency. Particularly important, complex or substantial cases are instead dealt with in the High Court. Judicial reviews (JRs) are a process by which individuals, businesses and other affected parties can challenge the lawfulness of decisions or actions of the executive, including those of ministers, local authorities, other public bodies and those exercising public functions. It is a largely judge-developed procedure and can be characterised as the rule of law in action, providing a key mechanism for individuals to hold the executive to account. It is, however, intended to operate quickly and proportionately. Certain protections are in principle provided against spurious claims: only those with sufficient interest are able to bring a case and they must first obtain permission for their case to be heard. Privacy injunctions are used when a person or organisation who wishes to prevent the publication or dissemination of private or confidential information applies to the High Court for an injunction to stop this from occurring. Prior to March 2015, these statistics were previously published as a separate publication entitled 'Statistics on Privacy Injunctions'. Information about the systems and data included in this publication can be found in 'A Guide to Civil Court and Administrative Justice Statistics' which is published alongside this report. www.gov.uk/government/statistics/guide-to-civil-and-administrative-justicestatistics There is also a separate **glossary** published alongside this which provides brief definitions for the terms used in this report. Information regarding the symbols and conventions used in the bulletin are given in the explanatory notes section. Previous editions of Civil Justice Statistics Quarterly can be found here: www.gov.uk/government/collections/civil-justice-statistics-quarterly ## Changes In Reporting From 6 April 2016, debtor petitions (whereby an individual files for bankruptcy) moved from the courts to an online system, and as a result are no longer recorded in these statistics. For numbers of debtor petitions and a more detailed breakdown of insolvency petitions in general, please see www.gov.uk/government/collections/insolvency-service-official-statistics. This bulletin includes for the first time an annual breakdown of the number of Judicial Reviews classed as 'Totally Without Merit' since 1 October 2012 (Table 2.4). Previous publications provided a cumulative figure from 1 October 2012. Due to data quality concerns, the **judges sitting days statistics** (judiciary chapter) for 2015 were not available at the time of the last publication (2 June 2016) - these are now available and have been included in the previous quarter's report within the Royal Courts of Justice tables, at the following link: www.gov.uk/government/statistics/civil-justice-statisticsquarterly-january-to-march-2016-and-the-royal-courts-of-justice-2015. ## Users Of The Statistics The main users of these statistics are ministers and officials in central government responsible for developing policy with regards to civil and administrative justice. Other users include lawyers and academics, other central government departments such as the Department for Communities and Local Government, and non-governmental bodies, including various voluntary organisations with an interest in civil and administrative justice. ## Next Publication The next publication of Civil Justice Statistics Quarterly is scheduled to be published on **1 December 2016**, covering the period July to September 2016. ## Key Findings Civil Cases  In April to June 2016, courts dealt with around 397,500 claims, up 8% on the same quarter in the previous year, driven by an increase in specified money claims (up 12% over the same period).  During the same quarter there were around 227,000 judgments, a 17% increase on the same quarter in 2015. This is driven by the increase in specified money claims, which have the greatest likelihood of reaching the judgment stage of any claim type (usually default judgments).  Non-money claims are at their lowest quarterly level since January to March 2000, when the quarterly breakdowns began. This has been driven by a continued drop in mortgage and landlord possession claims, which stood at around 38,500 in April to June 2016 (down 6% on the same quarter last year).  In April to June 2016, both the claimant and defendant had legal representation in 56% of all defences and neither had representation in 18% of defences (both down one percentage point on the same quarter last year). Defences where only the claimant had representation accounted for 22% (an increase by two percentage over the same period).  There were 1,940 insolvency petitions in April to June 2016. This shows a 62% decrease on the same quarter last year, which has been caused by debtor petitions moving to an online system on 6 April 2016, and are no longer heard in court Judicial reviews at the Administrative Court  During the first half of 2016, there were around 2,220 applications lodged in the administrative court, a 4% increase on the same period of 2015.  In the first half of 2016, around 1,000 cases (45% of all cases lodged) reached the permission or oral renewal stage. Of those that reached these stages, 20% were found to be totally without merit. This is level with the proportion seen annually in 2015 (where 78% of all cases lodged reached the permission or oral renewal stage) ## Privacy Injunctions  During January to June 2016, there were two applications for new interim privacy injunctions and no applications for continuation of an injunction or applications for a final privacy injunction.  Two appeals were heard in the Court of Appeal against a grant or refusal of an interim or final injunction and one appeal was heard by the Supreme Court. All three appeals relate to the same interim privacy injunction case, which took place in the same period (January to June 2016). ## 1: Civil (Excluding Family) Cases A civil claim against a person or a company (the defendant) starts when a person or company (the claimant) completes and submits a claim form to the county court. This can be done either in person or online (for money and possession claims only). A copy of the claim form along with a response pack is sent to (served on) the defendant who has 14 days to respond to the claim. For money claims, if the defendant disputes (defends) the claim (in full or part) and mediation fails, the case is allocated by a judge to one of three case-management tracks (small claims track (for claims with a value less that £10K), fast track or multi track). Allocated cases which are not settled or withdrawn generally result in a small claim hearing or trial. A judgment regarding the claim can be made at various stages of the process. There are various methods of enforcing a judgment through the county courts including warrants and charging orders. As supplementary information, we also provide the percentage of claims issued in a quarter or year that have already resulted in a defence, allocation or hearing or trial. Caution should be exercised when interpreting these figures for recent years. The information contained in the bulletin is based on the available data when the database was extracted; consequently a proportion of claims made in more recent quarters are still awaiting progression to the next stage of court action. Claims from earlier periods will have had longer for the case to be processed than those from more recent periods so a lower proportion of these earlier claims are likely to be still awaiting a defence, allocation or hearing or trial. ## Number Of Claims Issued In April to June 2016, a total of 397,504 claims were issued, an 8% increase on the same quarter last year (see Table 1.1 and Figure 1.1). This is the highest second quarter total since 2006. Looking at the longer term annually, there was a general downward trend in the total number of claims between 2006 and 2012, which has since reversed (albeit with a slight decrease of 2% in 2015 compared to 2014). Figures for the first half of 2016 suggest a continuation of the increasing trend. In April to June 2016, 83% of all claims were money claims, an increase of two percentage points on the same quarter in 2015. Of these money claims, 90% (294,181) related to claims for specified amounts of money (two percentage points higher than the same quarter last year). The sharp increase in the number of specified money claims (up 12% from the same quarter last year) has driven the increase seen in total claims this quarter. The remaining 10% of money claims related to unspecified money claims, down two percentage points from the same quarter last year (Table 1.2). Unspecified money claims include personal injury, which make up the overwhelming majority of these claims. In April to June 2016, 94% of unspecified money claims were for personal injury, around the same level seen in April to June 2015. This proportion has been consistent since the second quarter of 2012, when the County Court Money Claims Centre (CCMCC) took over the processing of the money claims and more accurately recorded personal injury claims (Table 1.2). Personal injury claims were down 5% on the same quarter of 2015. In April to June 2016, there were 69,071 non-money claims, down 2% on the same quarter in 2015, and at its lowest quarterly total since 2000. Annually, this figure dropped from an average of just under 400,000 between 2000 and 2008 to an average of just under 329,000 between 2009 and 2014. In 2015, the number of non-money claims fell further to 299,104. This decrease can be partially explained by the fall in mortgage and landlord possession claims; there were 38,438 such claims in the most recent quarter, also the lowest quarterly total since 2000, and a 6% decrease on the same quarter in 2015. This coincided with lower interest rates, a proactive approach from mortgage lenders in managing consumers in financial difficulties, and various interventions, such as introduction of the Mortgage Pre-Action Protocol1 that encouraged more pre-action contact between lender and borrower (Table 1.2). There were 1,941 insolvency petitions2 (excluding in the Royal Courts of Justice) in April to June 2016. This shows a 62% decrease on the same quarter last year, which has been caused by debtor petitions moving to an online system on 6 April 2016, and are no longer heard in court3. ## Number Of Defences, Allocations, Trials And Judgments In April to June 2016, there were 69,968 defences made, 7% more than during the same quarter in 2015. Looking at the longer term, there has been a general downward annual trend since the peak of just under 340,000 in 2007, with the 2014 figure being 264,701. Since 2014, the annual number of defences has remained stable, with 264,545 defences in 2015. For money claims, if the claim is defended, further information is usually provided by each of the parties, after which the case is allocated by a judge to one of three case-management tracks. In April to June 2016, a total of 35,873 allocations were made, only 132 more than the same period last year (Table 1.3). Of the allocations made;  Just under half (16,511, or 46%) were to the small claims track, three percentage points less than in the same quarter of 2015. This track is generally for cases with a claim value of up to £10,0004 which require less preparation by the parties involved than the more complex cases allocated to the fast or multi track. The trials are designed to be accessible to people who do not have representation by a solicitor or counsel, and are dealt with in about an hour.  45% (16,051) of claims were allocated to the fast track, an increase of five percentage points from the same quarter in 2015. This track is generally for cases with a claim value of between £10,000 and not more than £25,000, with issues not complex enough to merit more than a one day trial.  9% (3,311) of claims were allocated to the multi-track, compared with 12% on the same quarter of 2015. This track is generally for cases with a claim value exceeding £25,000 with more complex issues. They generally last more than one day at trial. In April to June 2016, a total of 227,205 judgments were made, up 17% on the same period last year. This is primarily driven by the increase seen in specified money claims, which have the greatest likelihood of reaching the judgment stage of any claim type (usually default judgments). Annually, the number of judgments fell between 2009 and 2012, but this has since begun to show an increase. In 2015, there were 867,665 judgments made, an increase of 4% compared to 2014 (Table 1.4). Defended cases which are not settled or withdrawn generally result in a trial (Table 1.5). In total, there were 12,109 trials (of all types) in April to June 2016, up 5% on the same quarter in 2015. In April to June 2016, 8,367 small claims trials took place, level with the same quarter in 2015. On average, these trials occurred 31.7 weeks after the claim was originally made. This is similar to the average time taken in April to June 2015 (31.8 weeks). Fast and multi-track trials (of which there were 3,742 in April to June 2016, an increase of 20% on April to June 2015) occurred on average 54.3 weeks after the claim was originally made (Table 1.5). ## Enforcement There are various methods of enforcing a judgment through the county courts. The most common method of enforcing a monetary judgment is the warrant of execution against a debtor's goods. This is where, unless the amount owed is paid, items owned by the debtor can be recovered by a bailiff acting on behalf of the court and sold. The number of warrants issued has followed a generally decreasing trend since 2000, until mid-2014 to mid-2015 when numbers increased. Since Q3 2015, the number of warrants issued per quarter has remained relatively stable until this quarter. During April to June 2016, there were 77,422 warrants issued, representing a 4% increase on the same quarter last year (Table 1.4). Alternatively, various types of court orders can be obtained:  Attachment of earnings orders enable payment through the debtor's employer.  Third party debt orders enable payment by freezing and then seizing money owed by a third party to the debtor.  Charging orders obtain security for the payment against the debtor's assets. This may be followed by an order for sale which forces the sale of these assets. In April to June 2016, 24,687 enforcement orders were made, a decrease of 24% compared to the same period last year. This figure has been generally falling since 2008. ## Legal Representation Figures on the legal representation of parties in civil (non-family) related court cases are shown in Table 1.6. This gives the number of claims defended during each quarter, for specified money claims, unspecified money claims, mortgage and landlord possession and other non-money claims, and, according to whether the applicant(s), respondent(s), both, or neither had legal representation during the case. In April to June 2016, both the claimant and defendant had legal representation in 56% of defences, whilst neither the respondent nor the claimant had representation in 18% of defences (compared with 57% and 19% respectively compared to the same quarter in 2015). Defences with either the claimant or defendant only represented were 20% and 4% of all defences respectively in this most recent quarter, compared to 22% and 4% respectively in the same period last year. Changes to legal aid came into effect as of April 2013, and removed legal aid eligibility for some civil cases. Figures show that the proportion of defences with legal representation for both parties initially fell during 2013, but had recovered back to levels seen prior to the legal aid eligibility changes by July to September 2014. Since then a downward trend can be seen, corresponding with an increase in proportion claimant only representation defences. The Legal Aid Agency (LAA - formerly the Legal Services Commission) collects statistics on those applying for legal aid, and figures on the number of applications received and certificates granted by various civil categories. These are published in their quarterly statistical report which can be found here: https://www.gov.uk/government/collections/legal-aid-statistics The proportion of legal representation for defences is dependent on the type of claim. For example, in almost all unspecified money claim defences (97%) both the respondent and claimant had legal representation. For the other types of defences, legal representation status was more evenly distributed, although mortgage and landlord possession defences were more likely to have no legal representation for either the respondent or the claimant. ## Civil Proceedings In The Magistrates' Courts Magistrates' courts deal with criminal and some civil cases, and cases are dealt with either by justices of the peace, who are unqualified and who are paid only expenses, or by District Judges who receive some payment. Magistrates can deal with a limited number of civil cases such as arrears of income tax, national insurance contributions, council tax or payments of child maintenance. There were 15,375 completed civil proceedings in the Magistrates' Court in April to June 2016, a 4% increase on the same period last year (Table 1.2). It should be noted that a proceeding can either relate to a single case or multiple cases, so the numbers of cases completed is greater than the number of completed proceedings. ## 2: Judicial Reviews At The Administrative Court Judicial reviews (JRs) are a process by which individuals, businesses and other affected parties can challenge the lawfulness of decisions or actions of the Executive, including those of ministers, local authorities, other public bodies and those exercising public functions. It is a largely judge-developed procedure and can be characterised as the rule of law in action, providing a key mechanism for individuals to hold the Executive to account. This chapter tracks the progress of JRs lodged at the Administrative Court between 1 January 2000 and 30 June 2016. The figures presented in this chapter exclude Judicial Reviews that are dealt with by the Upper Tribunal Immigration and Asylum Chamber (UTIAC), unless otherwise stated; however they are publicly available in a separate publication5. As the information included in this chapter has been extracted from a live database, all figures are refreshed each quarter and therefore there are minor revisions between the information presented here and in previous publications. Information for all years is provided in the supporting tables and CSV that accompany this publication. Please note for later years, cases may not have progressed to the end of the process, so the progression and timeliness figures for these cases should be treated with caution, in particular for applications lodged during the year 2015 and also 2016 to date, where a larger proportion of cases will not have been concluded. For more information on the Judicial Review process, including how topics are allocated to Immigration/Asylum and Other, please see the A Guide to Civil and Administrative Justice Statistics6. ## Applications For Permission To Apply For Judicial Review During the first six months of 2016, there were 2,222 applications for judicial review, a 4% increase on the same period of 2015. The overall annual trend (to 2013) in judicial review applications received had been steadily increasing, with the exception of a dip in 2004. In 2000, there were 4,238 applications for permission to apply for a JR and by 2013, this had risen to an annual intake of 15,594 (over a threefold increase) (Table 2.1). JR Civil (Immigration and Asylum) cases had been driving this increase, up from 2,151 in 2000 to 13,141 in 2013. However, in 2014 there was a trend change and a sharp decrease to 4,063 JR cases being lodged (down 74%). This was due to a change implemented7 in November 2013, in which the Upper Tribunal for Immigration and Asylum Chamber (UTIAC) took over responsibility for the majority of Civil Immigration and Asylum Judicial Review cases. The reduction in Immigration and Asylum JR cases has resulted in a subsequent increase in Immigration and Asylum tribunal cases. In 2014/15, there were 15,179 JR receipts at the UTIAC, giving a total number of JRs across the Administrative Court and UTIAC of around 20,000. More detailed figures on the number of JRs taking place in the UTIAC are published in the Tribunal and Gender Recognition Statistics Quarterly Publication. In the first half of 2016, 1,269 cases (57% of all JRs) were Civil Immigration and Asylum cases and 15 cases have been subsequently transferred to the UTIAC. JR civil (other) cases have remained stable at around 2,000 cases annually, from 2005 to 2014. In 2015 there were 1,749 civil (other cases). JR criminal cases remained fairly stable from 2000 to 2011, fluctuating between 280- 370 cases each year. In 2012 it reached a peak of 384 cases and has since fallen to an all-time low of 261 cases in 2015. In April to June 2016, there have been 108 new cases for JR criminal and 845 for JR (civil) other. ## Case Progression (Table 2.2) Once a judicial review has been lodged, it then progresses through the process until it is concluded; the time this process will take will be different for each case9. The three main stages of the Judicial Review process once a case has been lodged are:  Permission stage - where the Court's permission is required for a JR claim to proceed. This can be in the form of an oral or paper hearing.  Oral renewal stage - In cases where the Court refuses permission to proceed on the papers (either in full or in part); this is where the claimant requests that the decision be reconsidered at a hearing.  Final hearing - Where permission is granted for a case to proceed at either the permission or oral renewal stage, this is the point where cases are heard and a judgment is made. Please note, case progression figures can be affected by the case mix, which has changed over time and thus any previously observed trends should be viewed with caution. As an example different case types can have different mean lengths of timeliness. Civil judicial reviews for immigration and asylum rose from 51% of all cases in 2000 to 84% of all cases in 2013, and stood at 57% in 2015 - this type of case takes longer to complete, therefore overall mean timeliness will increase the greater proportion of these cases within the case mix. Also, the case progression figures will change each quarter as time allows for more cases to progress through the system. ## Permission Stage  In 2000, 85% of judicial reviews lodged reached the permission stage and 29% were granted permission to proceed. These proportions decreased gradually over time to an all-time low in 2013 of 54% JRs reaching permission stage and 9% being granted permission to proceed.  Since the transfer of IA cases to the UTIAC (from November 2013) the proportion reaching the permission stage has increased, to 79% in 2014 and 78% in 2015. Those granted permission to proceed were 16% and 13% of cases lodged in 2014 and 2015 respectively.  In January to June 2016, the proportion reaching the permission stage stood at 45%, with 7% being granted permission to proceed to date. ## Oral Renewals  In 2000, 18% of all cases lodged were granted an oral renewal. This rose to 26% in 2001 and has fallen steadily to 10% in 2015, with the exception of 2012 where there was an increase to 17%.  A fee to renew the claim for an oral renewal was introduced in April 2014 - this may be a contributing factor to the continuing downward trend in the number of claims progressing to the oral renewal stage.  Not all claims in which permission to apply for judicial review is refused are eligible for renewal. Where a claim is considered by a judge to be totally without merit, the application for permission cannot be renewed to an oral hearing. Similarly, where permission to apply for judicial review is refused in a case brought to challenge a decision of the Upper Tribunal to refuse permission to appeal, the application for permission cannot be renewed to an oral hearing.  In terms of those granted an oral renewal in 2000, 4% of all cases lodged received an oral renewal and were granted permission to proceed. This proportion has remained essentially stable ever since, and has been at 3% every year from 2008 to 2015, with the exception of 2013 (when the proportion was 2%). In January to June 2016, 83 cases to date have reached the oral renewal stage, of which 27 have been granted permission to proceed. ## Final Hearing  The proportion of cases eligible for a final hearing (granted permission to proceed at permission stage or oral renewal) has steadily reduced over time, from 33% in 2000 to 10% in 2013. The rate stood at 16% in 2015. To date 9% of cases have been eligible for final hearing in the first half of 2016.  The proportion of all cases lodged found in favour of the claimant at a final hearing has reduced from 12% in 2000 to a low of 1% in 2013. In 2014 it stood at 4% and then decreased again to 2% in 2015. In the first half of 2016, only 18 cases to date have reached the final hearing phase, and 7 of these were found in favour of the claimant. ## Timeliness (Figure 2.2 And Table 2.3) Timeliness figures are based on the date the judicial review is lodged to the date of various stages of the process. It is not a measure of the time the Administrative Court takes to deal with a judicial review as it also includes time taken for parties to the JR to provide evidence and any adjournments or postponements requested. Caution must be taken when interpreting the most recent data, particularly that for 2015 and 2016 to date, as not enough time has passed for all cases to reach each stage and those that have will be cases that are shorter in length - the average will therefore be lower than the true figure (97% of cases lodged in 2014 are classed as 'Closed', compared with 88% of cases lodged in 2015, and only 42% of those lodged so far in the first half of 2016). The mean time taken from lodging a case to the permission decision stage has remained relatively stable between 2006 and 2013 where the number was 118 and 126 days respectively (reaching a low of 89 in 2008 and 2010); prior to this, the number was stable at approximately 65 days. For those cases lodged in 2015 classed as closed (88% of cases lodged), the mean time taken has reduced back to pre-2006 levels, at 65 days. This may be driven by the reduced caseload, due to most of the Immigration and Asylum cases moving to the UTIAC. The mean time taken from lodging a case to the oral renewal stage decision has fluctuated over the years. From 2000-2004, the average time was 130 days. This increased rapidly, up to a peak of 267 days in 2007. The figure then fell sharply to 180 days in 2008 before rising to an average of 229 days from 2009 to 2013. For those cases lodged in 2015 classed as closed (88% of cases lodged), the number has fallen to 138 days. The mean time taken from lodging a case to the final hearing decision showed a similar pattern; 205 days in 2000 peaking to 425 days in 2006 and fluctuating since then. The 2013 figure stood at 374, while the 2014 figure fell considerably to 254 days. For the 88% of cases lodged in 2015 classed as closed, the mean timeliness has fallen to 209 days. Please note that prior to 2014, the timeliness analysis includes cases that were transferred to the Upper Tribunal of the Immigration and Asylum Chamber. These cases were effectively closed on the COINS database in November 2013. ## Totally Without Merit (Table 2.4) In refusing permission for judicial review, a judge can certify a case to be totally without merit (TWM). As part of the Government's reforms to judicial review procedures, for cases issued on or after 1st July 2013, a case refused permission and certified as totally without merit cannot be renewed at the oral renewal hearing stage. A claimant can however appeal against this decision, which would be dealt with at the Appeals Court (in criminal JRs, there is no appeal route from a refusal of permission if TWM). The outcomes of such cases are not recorded in these figures. Of the 2,222 cases lodged in the first half of 2016, 999 have so far reached the permission or oral renewal stage at the time the data was extracted in July 2016. Of these cases, 20% were found to be TWM. Annually, the proportion of cases reaching the permission or oral renewal stage that are classed as TWM has seen a slight decline, from 28% in 2013 to 22% in 2014 and then to 20% in both 2015 and the first half of 2016 (note that the 2013 figure involves cases that would now be transferred to the Upper Tribunal of the Immigration and Asylum Chamber). ## 3: Privacy Injunctions This chapter presents statistics on privacy injunctions dealt with at hearings at the High Court or Court of Appeal at the Royal Courts of Justice (RCJ) in London up to January to June 2016. In general terms, the injunctions covered by these statistics are those dealt with in any civil proceedings in the High Court or Court of Appeal where the court considers either:  an application for an injunction prohibiting the publication of private or confidential information;  the continuation of such an injunction; or  an appeal against the grant or refusal of such an injunction. The injunctions covered by these statistics will be termed "privacy injunctions" throughout this report. They include, but do not exclusively relate to, super-injunctions. Specifically, the statistics relate to applications concerned with data protection and rights to respect for private and family life protected by Article 8 of the European Convention on Human Rights (ECHR), whether the injunction is sought by an individual, a public authority, or a company. When an injunction is sought, section 12 of the Human Rights Act is engaged, meaning that the injunction might, if granted, affect the exercise of the right to freedom of expression contained in Article 10 of the ECHR. The ECHR can be found on the following website: human-rights-convention.org/ The statistics do not cover injunctions arising from proceedings dealing with family issues, immigration or asylum issues, those which raise issues of national security, or most proceedings dealing with intellectual property and employment issues. The statistics also relate only to those injunctions dealt with at the RCJ in London. They exclude, for example, cases dealt with at District Registries of the High Court. In practice, however, the vast majority of, if not all applications for such injunctions will be dealt with at the RCJ. Data have been collected via statistical returns completed by the hearing judge and forwarded to the Ministry of Justice statistics team. The judge in the case therefore determines whether an injunction has met the criteria for inclusion in these statistics. See the Guide to Civil and Administrative Justice Statistics for more details. ## Proceedings Where Applications For Privacy Injunctions Were Considered In January to June 2016, there were two proceedings where the High Court in London considered an application for a **new** interim injunction prohibiting the publication of private or confidential information. No proceedings were considered at the High Court on whether to continue or **amend** an interim injunction or to issue a **final** permanent injunction. Two appeals were heard in the **Court of Appeal** against a grant or refusal of an interim or final injunction and one appeal has been heard by the Supreme Court. All three of these appeals relate to the same interim privacy injunction proceeding, one of the two new cases reported in January to June 2016. Figures for July to December 2015 published in March 2016 have been revised as additional forms were received for this period after publication. Figure 3.1 below includes the revised figures for July to December 2015. ## New Interim Privacy Injunctions (Table 3.1)  Of the two proceedings at the High Court that took place in January to June 2016, one case was granted and the other was refused, compared with four proceedings that took place during July to December 2015, in which three were granted and one was refused. ## Continuation Of Existing Interim Injunctions (Table 3.2)  There were no proceedings during January to June 2016 at the High Court in which the court considered whether to continue or vary an existing interim injunction from previous periods compared with two proceedings that took place during July to December 2015. ## Final Privacy Injunctions (Table 3.3)  There were no proceedings at the High Court in which the court considered an application for a final privacy injunction in January to June 2016, as was the case during July to December 2015. ## Appeals Against Privacy Injunctions In addition to the published figures, two appeals relating to one privacy injunction case were heard at the Court of Appeal in January to June 2016. The first appeal by the appellant against the original refusal of the interim privacy injunction, resulted in the interim injunction being granted. The second appeal was made by the respondent and led to the interim injunction being discharged. However, this decision was immediately appealed to the Supreme Court, which upheld the decision for the interim injunction to be continued until trial or further order. ## Annex A: Planned Upcoming Changes To Publication There are currently no planned changes to the publication. ## Annex B: List Of Accompanying Tables And Csv Accompanying this publication are the following tables: ## Chapter 1 - Civil Courts: 1.1 County court activity, England and Wales, annually 2000 - 2015, quarterly Q1 2009 - Q2 2016 1.2 Number of claims issued in the county and magistrates' courts, by type of claim, England and Wales, annually 2000 - 2015, quarterly Q1 2009 - Q2 2016 1.3 Claims defended and allocations to track, England and Wales, annually 2000 - 2015, quarterly Q1 2009 - Q2 2016 1.4 Case progression in the county courts, England and Wales, annually 2009 - 2015, quarterly Q1 2009 - Q2 2016 1.5 Number of trials and small claim hearings and the average time to reach trial/hearing, England and Wales, annually 2000 - 2015, quarterly Q1 2009 - Q2 2016 1.6 Number of defended claims by case type and details of legal representation, England and Wales, annually 2013 - 2015, quarterly Q1 2013 - Q2 2016 ## Chapter 2 - Judicial Reviews In The Administrative Court: 2.1 Number of case applications for permission to apply for Judicial Review by topic, at the Administrative Court, 2000 - Q2 2016 2.2 Case Progression: number of Judicial Review cases that reach permission stage, oral renewal stage and final hearing by cases lodged, at the Administrative Court, 2000 - Q2 2016 2.3 Timeliness (in days) of Judicial Review cases started at the Administrative Court, by staged reached, 2000 - Q2 2016 2.4 Number of Judicial Reviews at the Administrative Court classed as 'Totally Without Merit' annually, October 2012 - Q2 June 2016 ## Chapter 3 - Privacy Injunctions 3.1 Applications at the High Court in London for new interim privacy injunctions, August 2011 to June 2016 3.2 Proceedings dealing with the continuation or variation of interim injunctions at the High Court in London, August 2011 to June 2016 3.3 Final privacy injunctions dealt with at the High Court in London, August 2011 to June 2016 ## Annex C: Timeline Of Changes To Civil Procedures  Brooke reforms - April 2013, changed the value limits for money claims allocated to each track.  Jackson reforms - April 2013, changed the process for managing multi track claims.  Implementation of the tribunals, courts and enforcement act - April 2014, various changes to the procedures for enforcement of judgments.  Single county court - April 2014, changed the way in which claims are issued.  Introduction of secure data transfer (SDT) - November 2014, allowed customers issuing bulk claims to do so more easily.  Fee enhancements, March 2015 - increased the fee required to issue money claims.  Debtor petitions (whereby an individual files for bankruptcy), from 6 April 2015 - moved from the courts to an online system and therefore no longer recorded in these statistics. ## Annex D: Explanatory Notes The United Kingdom Statistics Authority has designated these statistics as National Statistics, in accordance with the Statistics and Registration Service Act 2007 and signifying compliance with the Code of Practice for Official Statistics. Designation can be broadly interpreted to mean that the statistics:  meet identified user needs;  are well explained and readily accessible;  are produced according to sound methods, and  are managed impartially and objectively in the public interest. Once statistics have been designated as National Statistics, it is a statutory requirement that the Code of Practice shall continue to be observed. Breakdowns of many of the summary figures presented in this bulletin, e.g. split by case type or by HMCTS area, are available in the comma separated value (csv) files that accompany this publication. In the civil section of the publication the terminology 'hearings or trials' had previously been used to describe civil claims reaching this stage. We now use the term 'trials', as this is a more accurate reflection of what the figures represent. This does not change the historical or current figures reported. ## Data Quality And Revisions Revisions to the statistics for the latest quarter may be made when the next edition of this bulletin is published. Further revisions may be made when the figures are reconciled at the end of the year. If revisions are needed in the subsequent year, these will be clearly annotated in the tables. The Judicial Review figures are taken from the Administrative Court Office COINS database. As the Judicial Review figures are extracted from this live database, all figures are refreshed each quarter - as a result, there may be minor revisions between the new information presented in the latest bulletin and data published previously. From September 2015, a small number of cases from the Technology and Construction Court and the Mercantile Court (a sub-division of the Chancery Division of the Royal Courts of Justice) were logged as cases within the County Court Case Management System and therefore were being included in the civil county court caseload figures. This has now been corrected and caseload figures for the relevant quarters in 2015 and 2016 in the accompanying tables have been revised accordingly. Following a review of data processing methodology, the average time figures (in Table 1.5) from Q1 2012 onwards have been revised. The average timeliness calculation now include claims originating in the Northampton County Court Business Centre, which had been excluded in previous publications. ## Symbols And Conventions The following symbols have been used throughout the tables in this bulletin: .. = Not applicable (r) = Revised data (p) = Provisional data ## Further Information Earlier editions of this publication can be found at: www.gov.uk/government/collections/civil-justice-statistics-quarterly For information on Court judgements (including Privacy Injunctions) please see: www.bailii.org/databases.html#ew Statistics on Tribunals (including Judicial Reviews dealt with by the UTIAC) can be found at: www.gov.uk/government/collections/tribunals-statistics Statistics on the use of interpreters and translation services in courts and tribunals can be found at: www.gov.uk/government/collections/statistics-on-the-use-of-languageservices-in-courts-and-tribunals Information on Civil County Court Mortgage and Landlord Possession Statistics can be found at: www.gov.uk/government/collections/mortgage-and-landlord-possessionstatistics Information on publicly funded legal services is now published by the Legal Aid Agency and can be found here: www.gov.uk/government/collections/legal-aid-statistics Information on civil justice in Scotland can be found here www.gov.scot/Topics/Statistics/Browse/Crime-Justice/civil-judicial-statistics/ Information on civil justice in Northern Ireland can be found here A detailed analysis of county court judgments by region produced by Registry Trust Ltd can be found at the link below. This data gives aggregated detail on judgments that have been made by the county courts and recorded on the judgments register. www.data.gov.uk/publisher/registry-trust-limited The total number of CCJs differs from that published in Civil Court Statistics Quarterly, because Registry Trust manually checks the details of each judgment. More detail on Registry Trust can be found at: www.registry-trust.org.uk/ ## Contacts Press enquiries on the contents of this bulletin should be directed to the MoJ or HMCTS press offices: Sebastian Walters (MOJ) Tel: 020 3334 3529 Email: Sebastian.walters@justice.gsi.gov.uk Camilla Marshall (HMCTS) Tel: 020 3334 3531 Email: camilla.marshall@justice.gsi.gov.uk Other enquiries about these statistics should be directed to the Justice Statistics Analytical Services division of the MoJ: Tara Rose Ministry of Justice 102 Petty France London SW1H 9AJ Email: statistics.enquiries@justice.gsi.gov.uk General enquiries about the statistics work of the MoJ can be emailed to statistics.enquiries@justice.gsi.gov.uk General information about the official statistics system of the UK is available from statisticsauthority.gov.uk/about-the-authority/uk-statistical-system © Crown copyright Produced by the Ministry of Justice Alternative formats are available on request from statistics.enquiries@justice.gsi.gov.uk
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## The Survey On Inclusive Reopening Gave Us Many Responses From Individuals Who Are Affected By The Current Situation. Here Are Some Further Examples Of Key Concerns. You May Like To Consider How Your Service Would Respond To Each. How To Use This Worksheet: 1. Read the scenarios which have been inspired by, not extracted from, the survey results from the inclusive re-opening survey we ran in June. 2. Discuss:  What might the person detailed in this scenario be feeling? What might be affecting the way they are feeling?  What barriers or exclusions to access might they be subject to?  Can these be removed or limited by you or someone within your service?  Do you already have policies/procedures in place to deal with this scenario?  What concerns do you have around the themes mentioned in this scenario?  What might you need to convey to the person in question? 3. Are there any steps you need to put in place to mitigate against any exclusions or barriers to users or staff in a scenario such as this? ## Scenario 1: Response to blanket policy statements The following was a common theme in survey responses, particularly from older people: "I have been deemed 'vulnerable' under Government policy due to my age. However, I feel this is discriminatory; I have no ongoing medical conditions, and am comfortable venturing outside. I had been undertaking research prior to lockdown, and have exhausted all online resources. I wish to continue my research on-site, but fear I may be discouraged due to my age. I also volunteer at a local archive, and would like to continue to do so physically rather than digitally - I understand the concerns of archive staff around keeping everyone safe, but I believe it is my decision to make." Possible discussion points:  How might this person be feeling as they engage with the archives?  Why might they be discouraged from involvement as an onsite volunteer or researcher? Are any of these reasons based solely on age?  When someone is in a vulnerable group and actively deciding to undertake more activities, whose risk is it to manage? How can this be discussed and made transparent to the individual and the organisation?  How can you meet this person's needs and expectations while managing the health and anxieties of other users, volunteers and staff? Scenario 2: Physical disability, support for carers and safe travel Another common theme in survey responses was from people concerned that covid-19 risks and precautions would negatively interact with their physical disability. Other examples included problems with queueing for long periods or with using self-service models with reduced personal support. "I'm a wheelchair user, and I have a carer who will accompany me on my prebooked visit. We'd like to travel in the safest way possible way by public transport. "My main concerns are around accessibility and taking public transport. As a wheelchair user I'm unclear on the current advice around 2 people travelling together in a taxi especially with regards to face covering requirements, and cashless payment methods. Will there be recommendations of trusted taxi ranks across the UK who I might be able to contact with any concerns before the day of my visit?" Possible discussion points:  How might this person be feeling as they engage with the archives?  How might persons who are vulnerable due to disability best approach accessibility under current guidelines?  What barriers or exclusions to access might they be subject to?  Can these be removed or limited by you or someone within your service?  They are reliant on public transport to visit the archives. Considering socio-economic barriers if encouraging private transport/use of personal vehicles, what sort of travel advice might you offer potential visitors?  What support is likely to be available? What is a reasonable expectation of support from the archives concerned? Scenario 3: Increased cleaning and use of face masks A number of survey responses were concerned at the effect of increased cleaning provisions, particularly the chemicals involved. "Having reopened to the public we have implemented a cleaning rota within the team to ensure search room tables are cleaned after each visitor and the documents have quarantined safely. "We have provided appropriate PPE to each member of staff but one colleague who suffers from asthma has raised issues around face masks and the chemicals used to clean the space."  What barriers or exclusions to access might the staff member be subject to during the pandemic?  Can these be removed or limited by you or someone within your service?  What is your approach to staff members with different health and personal needs?  Have you reviewed your provisions to take account of staff health issues and concerns, including where new chemical agents are being used or in greater quantities?  Have you similarly reviewed the impact on health issues of your new provisions for site visitors?  How are you balancing staff members' individual needs with delivering the service?  Can people clearly declare exemptions to mask wearing? ## Scenario 4: Managing Covid-like symptoms: the effect of rules and policies Another recurring theme in responses was from people who have health conditions with similar symptoms to Covid. Some are concerned about the impact of this on other people's perceptions as well as whether they may be treated as potentially infected. Several suggested ways of coping. "A researcher has made an appointment to view some material in the search room. When they arrive they advise me they have a chronic condition which can lead them to cough and are anxious about disturbing other visitors. They ask if they could bring hard boiled sweets into the search room to help ease their cough. Our preservation policy does not allow food or drink in the search room."  How does the researcher feel in this scenario?  How does the staff member feel?  How do their different perspectives interact?  How might other researchers respond to this person's coughing, regardless of the cause of it?  Have you considered altering preservation policies in response to the pandemic? Is this an example of a time when you should consider it?  Can people clearly declare exemptions to mask wearing? ## Scenario 5: Volunteering post/ during Covid Hello, **I'm Ben.** I have been volunteering at the archives once a week for six years now, since losing my job. To get there I have to catch two buses each way. I am not very good at using computers. I particularly enjoy making archival folders and numbering documents. I get on well with the staff and other volunteers, and really look forward to the sessions. The tasks are interesting, but I also enjoy the chance to chat and have a cuppa. I feel that my work is useful and appreciated. I have really missed going to the Archives. Am I going to return to my old routine, or are things going to be very different from now on? What's in it for me if I'm not going to enjoy myself?  How might Ben be feeling?  What are the knowns and unknowns of this scenario?  What are the barriers/ exclusions they might be facing?  Are staff/spaces available for volunteering activities on site at the moment, given social distancing and priority of keeping search room open?  They are reliant on public transport to visit the archives. Consider socioeconomic barriers if encouraging private transport/ use of personal vehicles, what sort of travel advice might you offer potential visitors?  Have you begun work to restart non- digital volunteering?  What support is likely to be available? What is a reasonable expectation of support from the archives concerned? ## Scenario 6: Childcare For Employees You Are Managing A Small Archives Team, And Two Members Are Mothers Of School-Age Children. One has told you that they won't be able to come in to reopen the archive, as there is no early years' provision in their area. They would like to continue working from home and don't want to miss out on key decisions. The other has confided that they're worried they might have to stop working as they earn less than their partner and can't see how this will be sustainable in the long term. ## How Can You Provide Support For Your Team, Those With And Those Without Childcare Responsibilities, As The Service Reopens? How might the individual staff members be feeling? How might you as the manager be feeling? What are the barriers or exclusions they may be experiencing? What is your approach to staff members with different health and personal needs? Does your organisation have a flexible working policy?
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## LEPT eBulletin - July 2019 Welcome to the LEPT eBulletin! SPOTLIGHT ON The **two policy briefs** we published in June. If you want to find out more about how TfL are counting passengers to help with their understanding of London mobility patterns, what European projects are working on urban vehicles access regulations or how LB Hackney has put in place a number of school streets, please take a look! If there are any topics you are particularly keen on hearing more about, **email us** with your suggestions. EU FUNDING & LEARNING OPPORTUNITIES Learning and exchange opportunities European Road Safety Summer School Taking place in Belgium from 26 to 30 August 2019, this week is dedicated to professionals working in the field of road safety. It will be an opportunity to learn about awareness raising, links with urban planning and to hear about European case studies and best practice. 2019 European Mobility Week The event will be taking place from 16 to 22 September 2019. Registrations are now open for cities. The chosen theme is 'Safe walking and cycling', and European local authorities are encouraged to take this opportunity to test out solutions and showcase achievements. September POLIS Working Groups meetings European network POLIS is organising new Working Groups (WG) meetings. Two WG will be meeting in September: Parking and Clean Vehicles & Air Quality. The Parking WG will focus on parking and electro-mobility, and the Clean Vehicles group on developing an integrated vision for the roll-out of charging infrastructure. If you are a borough representative, please get in touch if you want to hear more about these. Funding opportunities There are no current funding opportunities open. In September 2019, Urban Innovative Actions will launch its fifth call for proposals, with a strand focusing on air quality. Some Horizon 2020 'Smart, green and integrated transport' opportunities will also be opening on 3 September 2019. We will publish a briefing about the calls later this month. Awards 8th SUMP Award This year's edition focuses on the integration of safe active mobility in sustainable urban mobility planning. Applications are welcome until 31 July 2019. Last year, Greater Manchester brought the award home for its work on multimodality and mobility planning. ## CIVITAS Awards 2019 Call Four categories are open: Bold Measure (innovative and daring approach), Citizen and Stakeholder Engagement, CIVITAS Legacy and Transformation. Cities can apply until 19 July. If your borough is not yet a CIVITAS Forum member, you can join by signing the Network Declaration. Sustainable Cities Platform Transformative Action Award 2019 The European sustainability award will be given out to a local authority or civil society organisation implementing the 15 pathways as per the Basque Declaration, which sets out ways to achieve the Sustainable Development Goals and the Paris Climate Agreement. The winner will receive €10,000 Applications will close on 31 July 2019. NEWS British Cycle to Work scheme revised: e-bikes now included The British national Government revised in June its Cycle to Work scheme, which allows employees to purchase bicycles tax-free through their organisation. In addition to removing the £1,000 cap, the Government announced the scheme would now also cover e-bikes. EU sets out new steps to achieve Vision Zero The EU recently published a working document detailing how it plans to support its Vision Zero strategy. New key performance indicators have been established to measure results across the union, including driver distraction, use of safety belts or post-crash care. European rail operators join forces to demand the end of tax exemption of aviation fuel European rail operators have come together to demand the end of tax exemption for aviation, as cross-border aviation is exempted from VAT across Europe. On the contrary, passenger rail is subject to VAT in seven members states Parking spaces: potential for greener cities The C40 group is calling for a conversion of parking spaces into cycle lanes and planted areas. London has already been leading the way with parklets across boroughs, for example in Hackney, where residents can apply for a community parklet. London takes action on electric vehicle infrastructure The Mayor of London launched mid-June a new strategy for the electrification of vehicles in London, focusing on rapid chargers. This is part of a wider strategy to clean up London's air, in close collaboration with boroughs through -among others- the Go Ultra Low City Scheme. Institute publishes their ranking of the most bike-friendly cities in the world The Copenhagenize Institute published its newest ranking during the 2019 edition of Velo-City conference in Dublin. Copenhagen is still rated first, followed by two Dutch cities, Amsterdam and Utrecht. The ranking does not feature any British cities. EU court of justice rules against Brussels' monitoring of air quality Invoking the EU's Air Quality Directive, citizens and NGOs brought the Belgian city to court. The EUCJ ruled that regional authorities cannot average out pollution levels across their districts, as it does not reflect the true level of emissions in some of the most polluted areas. After Germany, Belgium is the second EU country to make use of that ruling possibility. WHAT LEPT IS READING ## SUMP 2.0: Guidelines for developing and implementing a Sustainable Urban Mobility Plan - Rupprecht Consult The draft second edition of the SUMP guidelines was published during the SUMP Conference in June 2019. A feedback survey is available until 9 July, and the final version of the document will be published in October 2019 during the CIVITAS Forum Conference. Safer Roads, safer cities: How to improve urban road safety in the EU? - European Transport Safety Council This report is an analysis of the latest EU data on road safety and presents the case for its full integration in local sustainable urban mobility planning. It also includes some key recommendations for cities, member states and EU institutions (see page 9). Physical activity of electric bicycle users compared to conventional bicycle users and non-cyclists: Insights based on health and transport data from an online survey in seven European cities - Transportation Research interdisciplinary Perspectives An academic paper studying the health effects of e-bike usage. It appears from the results that physical activity gains are similar for e-bikers and cyclists, as most trips are substituted from private cars or public transport. The Future of Cities - Joint Research Centre and DG REGIO This interactive platform has a section focused on urban mobility issues, outlining the main challenges that cities will be facing tomorrow. As mobility technologies progress rapidly, governance and legislative issues are highlighted, with the necessity for cities to integrate new services into their sustainable urban mobility planning. Walking and Cycling portrayed negatively in over 60% of media articles - new research reveals - Sustrans Analysing 600 hundred articles for a year, Sustrans Scotland has shown that cycling and walking are widely portrayed as negative. But findings are not only negative: 'health' for example is mentioned in 93% of articles portraying active modes positively. International Transport Forum Transport Outlook - OECD Similarly, this document outlines challenges for local authorities and provides them with policy insights to help reduce CO2 emissions from transport and respond to disruptive solutions in an efficient manner. EVENTS ATTENDED LEPT attended the launch of the HARMONY ("Holistic Approach for Providing Spatial & Transport Planning Tools and Evidence to Metropolitan and Regional Authorities to Lead a Sustainable Transition to a New Mobility Era") project in London. HARMONY is led by the Maas-Lab at UCL and will be looking at creating new tools for authorities to lead mobility into the low-carbon era. LEPT representatives also attended the POLIS Management Committee Meeting in Brussels. If you wish to receive information on what was discussed, contact us. UPCOMING EVENTS Details of both free and paid upcoming events can be found on LEPT's website.
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ADULT COMMUNITY LEARNING IN THE CONTEXT OF LONDON'S VISION FOR SKILLS Executive Summary The Mayor of London takes over responsibility for adult skills from 2019. In anticipation of this the draft of a new Skills and Adult Education Strategy, Skills For Londoners, was published in November 2017. This sets out what will be required to address skills gaps and shortages in order to enhance London's economic and social prosperity over the coming years. The three key commitments outlined in *Skills for Londoners* are to:  Empower all Londoners to access the education and skills to participate in society and progress in education and in work;  Meet the needs of London's economy and employers, now and in the future; and  Deliver a strategic city-wide technical skills and adult education offer. This Project has been commissioned by London Councils on behalf of the four London-sub-regional partnerships and the Greater London Authority (GLA). It takes forward specific recommendations arising from the recent Area Review of London focusing on three particular areas:  The future role and distinct focus of Adult Community Learning in London  How outcomes and impact of ACL should be measured  Commissioning arrangements for ACL when the Adult Education Budget (AEB) is devolved to the Mayor. The context Education and training for adults aged 19+ is provided by London Boroughs, further education colleges and private providers. It includes a wide range of qualification based courses, Maths, English and ESOL and, in some cases, apprenticeships funded through a range of sources, including the Adult Education Budget. A distinctive part of this work has been community learning, which focuses on working within communities and engaging individuals in learning and its benefits. Learning may include the basic skills necessary to function in society and at work; English; digital skills; numeracy and budgeting; health education; creative arts; and citizenship. It may also include pre-employability training, for example the behaviours, attitudes and expectations required by London's employers. Community learning is local. It is often short in duration, and may be supported by volunteers, and other local public services, including those leading on childcare, social services and healthcare. The benefits of community learning are considerable. It can transform people's attitudes and ambitions about the future for themselves and their families, deliver long-term economic benefit, build personal confidence and independence, and ease pressure on other public services. Following widespread consultation, we believe that community learning within the context of *Skills for Londoners* should be focused on seven priority groups: 1. Those furthest away from being ready to take up work (with provision planned in partnership with DWP) 2. Those working in very low paid work or insecure employment, and those falling outside the parameters of the benefit system and seeking a return to work. (Provision for low-paid workers should be planned with reference to DWP services). 3. Residents who would benefit from training in English for Speakers of Other Languages (ESOL), with a focus on those who are not literate in their first language 4. Mental health service users. 5. Adult with learning difficulties and disabilities. 6. Those who are socially isolated or at risk of becoming so, including some older learners (50+). This might include people with chronic health problems. 7. Residents with multiple support needs including those living in areas identified as a priority by Boroughs and including family learning. Skills for Londoners is clear that learning must be focused on delivering relevant outcomes. A key task for those providing community learning is how better information can be collected and collated to illustrate impact for London and its residents. In the short-term, our view is that the focus should be on measuring engagement of learners from priority groups, tracking educational and/or employment-related progression, and developing current work on social metrics to demonstrate improvements in attitudes, confidence and wellbeing. In the longer-term, Ofsted reports and pan-London data on economic activity, earnings and levels of education will be important pan- London sources of information to demonstrate valuable outcomes. A key issue to resolve is how adult community learning should be commissioned in order to drive positive change. As a principle, we fully endorse the recommendation of the London Area Review that the current 'block grant' for community learning should be retained. At this stage, we believe that an allocations methodology using current Index of Multiple Deprivation (IMD) data is too crude an approach to bring about change in London quickly and effectively. Community learning provision has been externally inspected with most services gaining an overall rating of 'good'. Initial modelling shows that, even with safeguarding a percentage of each borough's current allocation, several boroughs would experience very sharp increases or reductions in funding. The unintended consequences of this would mean a focus on reducing provision, restructuring and redundancies rather than ensuring that Boroughs work closely in partnership with others to continue to improve quality and develop new, innovative provision. An alternative approach is to implement the requirement for Boroughs to produce business plans for their community learning, showing how they meet needs, which would be subject to approval and periodic scrutiny by the Greater London Authority (GLA). Such an approach would not rule out a change to how money is distributed at a later point, when firm data on outcomes and impact is secure. Our recommendations are: 1 That the GLA adopts the definition of community learning set out in this paper, together with the allocation of a 'block grant' to boroughs and current community learning providers, who will plan and deliver provision. The block grant will enable rapid 'integrated' action to tackle social and economic inequalities, help communities with complex and multiple support needs in learning, and directly contribute to the aims set out in *Skills for Londoners*. As an important part of the wider FE sector we expect that, in addition, Boroughs would continue to access the wider Adult Skills Budget alongside colleges, voluntary organisations, and the private sector. 2 That the GLA adopts a model of business planning rather than artificially adjust allocations at this stage. We believe that a model of business planning will produce results more quickly, it will provide continuity, and will focus providers on supporting priority groups. It will avoid the major disruption to community learning likely in the event of systemic redistribution of funding allocations. 3 That the GLA supports providers in developing pan-London arrangements to measure the value of community learning using social metrics, taking account of national developments. These should enable providers to benchmark both regionally and nationally and to exchange good practice. It will also provide clear evidence about the types of programmes and delivery styles which promote significant improvements in health and wellbeing, confidence, empowerment and which foster positive social relationships. 4 That pan-London arrangements are put in place by the GLA to track actual individual progression from community learning activities to higher levels of education and training, and/or employment as a key measure of the success of all adult learning provision. This to include working with HMRC to agree an MoU to cover data sharing. The government should share this data with the GLA as soon as possible. 5 That the GLA liaises with Ofsted and the Education and Training Foundation (ETF). A specific focus within the Ofsted framework commenting on the quality of community learning outcomes would provide a valuable additional evidence base to the other methods and approaches proposed in this paper. The ETF is the leading organisation driving continuous professional development for the post-16 sector and should be a key partner in supporting London's providers in curriculum innovation, quality improvement and the leadership of change. INTRODUCTION This is the second of two reports produced for London Councils. The first report the 'Initial Proposition' sought to define the role of adult community learning in London. The second part of this work which has culminated in the production of this report takes forward specific recommendations arising from the recent Review 1 of Adult Community Learning (ACL) services across London, approved by the Area Review Steering Group in November 2016. This report can be found here. The work has focused on three specific aspects:  Refining the definition of adult community learning and the target beneficiary groups (taking account of the London's new Skills and Adult Education Strategy, *Skills for Londoners*).  Specifying the outcomes and impact measures for community learning which are practical to implement, and which are able to demonstrate its value.  Identifying options in relation to future commissioning arrangements following the devolution of adult skills funding to the Mayor of London in 2019/20. The Context Annual funding for community learning is provided to each of the 32 London boroughs, the City of London, the Institutes of Adult Learning (IALs)2 (City Lit, Morley College, Working Men's College (The Camden College), Mary Ward Settlement and the Workers' Education Association), and to a small group of other providers3 as a 'block' grant. To date, this has given those in receipt of funding freedom to determine both what was offered, and how it is delivered (for example, as a directly-delivered service, sub-contracted, fully outsourced, or as a combination of these). Block grant funding has also enabled providers to establish an infrastructure for 'outreach', capacity building, and for focusing intensively on 'hard to reach' individuals and groups within deprived communities. This is not the only funding that London Boroughs, IALs and others received for adult skills4. Most providers in receipt of a block grant for their current community learning also offer qualification-based courses in line with national priorities and in competition with the wider FE sector of colleges and private providers, overall doubling their allocations for community learning. These include GCSEs in Maths and English, ESOL and first Level 2 qualifications for adults in areas such as health and social care, business administration and customer service. In addition to this, some Boroughs have diversified into providing apprenticeships and have been successful in gaining entry to the new Register of Apprenticeship Training Providers5. This work, delivered through Boroughs and by the wider FE sector, will continue into the future and is an important part of encouraging progression from community learning through to high-level courses and ultimately employment. The London Skills and Adult Education Strategy In November 2017, a draft of London's Skills and Education Strategy, Skills For Londoners6 was published. This sets out a vision for adult education and training and what it should seek to achieve in a challenging international marketplace. The three key commitments outlined in the document are to:  Empower all Londoners to access the education and skills to participate in society and progress in education and in work;  Meet the needs of London's economy and employers, now and in the future; and  Deliver a strategic city-wide technical skills and adult education offer. Underpinning these commitments, the Strategy draws attention to stark contrasts in equality and opportunity. It emphasises the need to drive forward London's skills base rapidly to meet both current and emerging demand, and to fill the employment gaps anticipated post-Brexit. Some of this is about the promotion of skills at higher levels. The document also makes a firm commitment to reducing inequalities. For people without skills or in low skilled employment, it recognises the critical importance of ESOL, digital literacy (for both work and to access public services) and the role played by volunteering. It acknowledges the difficulties some people face in moving forward from very low-paid roles and the benefits which would be forthcoming should social mobility be improved. Emphasis is also placed on the value of participating in society, and on the benefits of learning to health, wellbeing and social integration7. Meeting these priorities will require education and training providers across London to build on their strengths. This will inevitably mean changes in focus and provision as London seeks to address its own economic and social priorities rather than abide by those set at a national level. The process we have adopted in undertaking this work has involved a review of relevant documents and widespread discussions with Boroughs, providers and key stakeholders who have an interest in the future role and focus of community learning. This has included:  A series of workshops (with the four sub-regional partnerships and the Institutes of Adult Learning).  Individual discussions with a wide range of stakeholders.  Modelling of changes in allocations using the Index of Multiple Deprivation (IMD), the size and age of the adult population.  A London-wide analysis of the current community learning catchments of boroughs and a number of direct providers. The work has been overseen by a pan-London Steering Group8 , which met three times during the course of the Project. This report is structured in 4 sections; 1 Defining (publicly funded) community learning 2 Measuring outcomes and impact 3 Commissioning 4 Key recommendations ## An Explanation Of Social Metrics Is Included As An Appendix To This Report. Data On Modelling And Maps Which Illustrate The Present Distribution Of Community Learning Beneficiaries Is Available Separately. 1 Defining (Publicly Funded) Community Learning The majority of adult education and skills training provided by FE colleges, London boroughs and private providers leads to recognised national qualifications and involves enrolment on a formal course of study, typically of at least nine months. Adult community learning is different. It may not involve qualifications, but it focuses on building confidence and skills - inspiring people from a wide range of backgrounds to engage in what they feel motivated to learn and encouraging them to be ambitious about their next steps. A borough's portfolio of community learning may include programmes to help people acquire positive behaviours and the interpersonal skills appropriate to both work and social situations; it may also include training in digital skills, basic literacy, numeracy and ESOL. Community learning is typically planned, structured and delivered in conjunction with other local borough-based support services, which may include health, housing and social services. Evidence that community learning is beneficial is widespread, and is captured periodically in summary publications such as the BIS Research Paper No 909. It is particularly valuable in improving health and wellbeing, in changing attitudes and behaviours and in building confidence. From our first report, we recognise that community learning can:  Deliver long-term economic benefit, particularly by improving attitudes to progression and to obtaining paid employment. For individuals, this may mean progression to higher-level studies, straight to a job, or to a volunteering role.  Encourage those who are parents to support their children in realising their potential in school, and in optimising their children's attitudes, values, health and wellbeing.  Enable individuals to be more confident and more independent about 'self help', and therefore less reliant on any available external support, for example, other public services, including health services.  Improve physical and mental wellbeing by motivating participants to make positive changes to their lives.  Help vulnerable and marginalised learners rebuild their lives and better integrate in society.  Facilitate communication with service providers (health, housing, schools, early years support) for those with poor English language skills. There are a number of particular characteristics of high-quality community learning, and how it seeks to address the needs of these identified target groups and beneficiaries:  It is delivered locally, at a time and place to suit learners, including at weekends, evenings, within school hours, and across holiday periods.  Most provision is at Pre-Entry and Entry level, which ensures that learning is accessible for those with very little education or any formal qualifications.  Group sizes vary, but there is no established minimum size.  Learning may last for a few hours to a few months, but it is always parttime.  Learning is carefully designed and structured to deliver results, but it is not primarily about examinations or qualifications.  Progress is generally assessed using a national system termed 'RARPA 10,' where learners are supported to identify their personal objectives and to produce evidence that they have been achieved. RARPA is recognised by Ofsted and the ESFA as a rigorous method of measurement.  In many cases it makes effective use of volunteers, additional support provided through other funding streams, and partners' premises and equipment without incurring direct additional costs (known as 'pound plus').  Some of this learning can be anticipated, planned and publicised because demand is known and understood, and there is sufficient data on potential demand to be clear what is needed (the 'universal' offer). In other cases, learning needs to be planned in coordination with other services as a specific intervention (the 'client led' offer) and be able to respond rapidly to identified needs. London boroughs are in a strong position to identify local priorities. They have the potential to offer a closely integrated service which identifies the barriers to change for local target groups and individual beneficiaries, and effective wrap-around support, which might include actions from health, education, social services, learning and employment. Content: Content is often planned in conjunction with other public services and with the target group, but we recommend that it should focus (in no particular order) on one or more of:  Pre-employability (for example, the behaviours and general skills which an employer would expect a new member of staff to adopt).  Confidence building  Literacy and English language skills.  Numeracy, including practical budgeting, managing family finances and/or banking.  Basic digital skills, applicable to the home and the workplace.  Health education, diet and exercise, caring support, accessing health services and more specific advice and guidance.  Re-engagement in learning, developing literacy and English skills and increasing confidence via stimulating and interesting courses in, for example, creative arts.  Citizenship ## 2 Measuring Outcomes And Impact A key feature of the current landscape is demonstrating value and impact of public funding, and how this can be measured accurately and cost-effectively. Skills for Londoners makes it clear that the GLA intends to move to commissioning on the basis of quality and outcomes11. All providers currently measure aspects such as learner numbers, attendance, and retention to the end of the programme of study, achievement of individual objectives through use of RARPA12, and actual progression (where data is available). A number of providers use additional evidence to capture the impact of their programmes on learners, including telephone surveys. The role of Community Learning outlined in this paper is too broad to fall neatly into one single impact measure such as an employment outcome. In Community Learning positive impact for individuals may be paid work, volunteering, improved health and wellbeing, better long-term social integration through improved skills in English and an understanding of citizenship, or improved skills and welfare of the next generation of family members. Our view, based on consultation, is that measuring outcomes must be proportionate to the funds available for community learning. The outcomes themselves should be relevant, and capable of being aggregated to produce a pan-London picture of performance. In the short-term (the lead time through to 2019/20), there are four key measures which will be of value in seeking to provide a contribution towards providing more evidence on impact: a) **Reporting on the proportion of learners** supported against relevant priority groups of beneficiaries as this will contribute to the measurement of impact. b) **Measuring educational progression** (particularly important in relation to maths, English, ESOL, and to those preparing for work progressing to accredited vocational provision). The complexity of progression and learner travel patterns, combined with the number and variety of providers offering qualification-based courses, suggests that comprehensive educational progression should be tracked pan-London over a period of 1-2 years, with learners assigned unique identification (for example, using the ILR). c) **Measuring social metrics.** By this we mean collecting robust data which measures improvements in health and wellbeing, levels of confidence and attitudes to progression, and social relationships. An outline of the social metrics work led by the Learning and Work Institute (LWI) is contained in the Appendix, and it now needs developing and refining further in the context of a wider roll-out across London and potentially nationally. Workshop participants and sub-regional partners consulted expressed a firm commitment to work together to agree how current pilot activities might be taken forward into a London-wide programme. A consistent model, which gives confidence about the value of those programmes which are not necessarily intended to lead directly and immediately to employment or higher levels of learning will be crucial to demonstrating value. Work to pilot social metrics consistently across London should take place in 2018. d) There are judgements about outcomes made by external inspectors, primarily Ofsted. Ofsted inspectors typically review providers on a rolling programme every four years, but a 'risk-based' approach is adopted should performance decline. In the period to 2020, it is anticipated that more London community learning providers will be inspected, adding to an already positive evidence base about quality of provision. Inspection methodology includes observing learning, talking to learners, staff and external stakeholders, and reviewing a wide range of self-assessment documentation and data. In relation to London, their published judgements, which have been subject to moderation processes, comment favourably on learners' growing levels of skill and confidence13, the positive impact of joined-up public sector partnerships in reaching communities and individual learners, and in the value of providing learning locally. We would recommend that discussions take place between Ofsted and the GLA to ensure that inspectors consistently review and publish judgements about community learning, commenting specifically on attitudes to learning, the impact of community learning, and how effectively learning contributes to meeting London's priorities. These are short term proposals, based on available data, and therefore do not cover the all possible impact measures. In the longer term (2019-2022): a) Assessing the value and the barriers to achieving accurate long-term tracking of community learning beneficiaries, through for example, national data provided through HMRC or other public services such as health. HMRC and DWP are currently working on a national system of tracking individuals who progress from learning to work, and collectively how much they subsequently earn. A Memorandum of Understanding is in place between DWP, HMRC and DfE to share data currently. Government should share such data with the GLA via a data-sharing agreement so that the GLA can assess the wider impact of the whole of the AEB. Immediate progression to employment or selfemployment is not always a primary outcome of community learning. However, progression to work within a 2-3 year timescale for some beneficiaries will be realistic and achievable. Any national system is therefore relevant in measuring the medium-term impact of those community learning programmes aimed at helping people gain work. b) Recognising the contribution made by community learning through periodic review of borough NOMIS and IMD data. NOMIS provides access to comparative statistics in several forms about the population engaged in economic activity, those on benefits, average earnings, qualification levels and a breakdown of employment locally. IMD ranks areas of the country by seven key domains by Lower Super Output Area (LSOA). Finally, successfully addressing local issues through joint working with other public services is intended to deliver improvements in the key indicators reported through IMD and NOMIS. The ultimate measure of successful outcomes should be phased, sustainable improvements in absolute levels of employment, income, education, health and crime. However, in developing this as a robust measure of impact, account needs to be taken of the transience and mobility of London's population, which at Borough level may artificially distort absolute results. ## Beneficiary Groups - Community Learning Those Consulted Over The Project Identified Seven Key Beneficiary Groups Of Community Learning:  Those furthest away from work  Those working in very low paid work or insecure employment, and those falling outside the parameters of the benefit system and seeking a return to work. (Provision for low-paid workers should be planned with reference to DWP services).  English for speakers of other languages (ESOL)  Mental health service users  Adults with learning difficulties and disabilities  Older learners  Residents with multiple support needs. The impact of learning on each of these seven categories of learners varies, and the following tables summarise the expected focus, purpose and outcome for each of the seven categories of priority beneficiary: 1 Those furthest way from work (for example, those who would be unlikely to be ready for work within 12 months, unlikely to be referred to the Work and Health programme), but who have the motivation and intention to seek employment14. It is likely that such provision would be planned in close consultation with DWP/JCP. | | FOCUS OF | |-------------------------------------|------------------| | LEARNING | | | PRIMARY PURPOSE | PRIMARY OUTCOME/ | | MEASUREMENT | | | | | | | | | 1 | | | Confidence building, | | | empowerment | | | activities. | | | To build the 'enabling' skills | | | underpinning successful | | | employability, including listening, | | | Progression through to a | | | more advanced course, to | | | accredited provision, or | | reducing worklessness and improving health and wellbeing show statistically significant increases in life satisfaction, mental well-being, locus of control and self-esteem. In addition, around three-quarters of those with children felt more able to help their children with homework and almost all of these attributed this to their learning. | | FOCUS OF | |-----------------------------------|------------------| | LEARNING | | | PRIMARY PURPOSE | PRIMARY OUTCOME/ | | MEASUREMENT | | | Numeracy and | | | literacy, basic digital | | | skills. | | | Finance and | | | budgeting activities. | | | Pre-employability | | | activities | | | questioning, working with others | | | and employers' expectations. | | | Managing and expressing feelings, | | | emotions and behaviours. | | | Engendering positive attitudes | | | about learning and progression to | | | work. | | 2 Those working in very low paid work or insecure employment, and those falling outside the parameters of the benefit system and seeking a return to work. (Provision for low-paid workers should be planned in partnership with DWP). For many, childcare support is a major barrier to participation. | PRIMARY PURPOSE | |--------------------------------| | LEARNING | | 2 | | Confidence building | | and empowerment. | | Digital skills (web | | browsing, digital | | security, transactions, | | accessing public | | services). | | Numeracy and literacy | | Pre-employment | | support activities | | To re-engage people who have | | taken a break from work in | | learning which will help them | | achieve employment. | | To update people on | | expectations of employers in | | the modern workplace and the | | skills required. | | To engender positive attitudes | | to gaining and maintaining | | employment. | 3 ESOL Those with very poor spoken and/or written English (including those in work on very low incomes). Community learning in particular focuses on those who are not literate in their first language1516. FOCUS OF LEARNING PRIMARY PURPOSE PRIMARY OUTCOME/ MEASUREMENT 3 The Pre-Entry Level ESOL curriculum may cover skills such as recognising and writing letters, basic symbols/signs and/or numbers, answering questions designed to obtain To enable people to gain confidence in their ability to: (1) successfully apply for and learn at a higher level, working towards accreditation; 15 210.000 working age Londoners cannot speak English well and 25,000 cannot speak English at all (ESFA localities "cube" data, GLA Economics analysis 16 A disproportionate number of those from Afghanistan, Pakistan, Bangladesh and Sri Lanka are without paid work. (London's Poverty Profile 2017). Changes in public funding of ESOL in 2011/12 excluded those in low paid work, those with very low levels of literacy and language and those not available for work. (English Language for All, NIACE, 2012). through to JCP. Social metrics (confidence and progression, empowerment, social relationships). MEASUREMENT Progression to an accredited programme, to part-time or full-time paid employment, self-employment or volunteering roles. Successful reference to adult careers guidance services. Social metrics (particularly confidence and progression). Progression from Pre- Entry to Entry Level ESOL measured through London-wide ILR data matching. Social metrics (confidence and progression) (2) benefit socially and economically from acquiring spoken and written English skills; basic personal information, writing their name, address, and telephone number and following basic verbal instructions. 4 Mental Health Service Users17 FOCUS OF LEARNING PRIMARY PURPOSE PRIMARY OUTCOME/ MEASUREMENT RARPA (to demonstrate skills acquired and improvements in current skills). Social metrics (confidence and progression, empowerment and social relationships). Actual progression to further education, training, volunteering or employment. 4 Creative subjects Confidence and empowerment Digital skills (web browsing, digital security, transactions, accessing services, social media). Health and wellbeing Basic employability To engage/re-engage people with learning, to raise aspirations about how they can contribute to an economically and socially prosperous London. To promote positive behaviours and attitudes about further learning and exploring options for employment. 5 Adults with learning difficulties and disabilities. FOCUS OF LEARNING PRIMARY PURPOSE PRIMARY OUTCOME/ MEASUREMENT 5 Creative subjects Confidence building and empowerment Digital skills Health and wellbeing Numeracy and budgeting activities Advocacy RARPA (to demonstrate skills acquired and improvements in current skills). Social metrics (confidence and progression, empowerment and social relationships). To optimise the participation of adults with learning difficulties in society through maintaining current skills, acquiring new skills and instilling willingness to engage successfully with others. To support improvements in health and wellbeing, employability and social engagements according to needs. Promote/maintain independent living and support carers. 6 Those who are socially isolated or at risk of becoming so including some older learners (50+). This might include people with chronic health problems. FOCUS OF PRIMARY PURPOSE PRIMARY OUTCOME/ 17 London Boroughs generally produce their own Mental Health Needs Assessment which will act as a planning tool for decisions about how adult learning can help prevent but also support individuals with poor mental health. ## LEARNING MEASUREMENT 6 Creative subjects Digital skills (web browsing, digital security, transactions, accessing public services, engaging with social media). Health and wellbeing education and activities To address issues of social isolation and loneliness, and to promote health and wellbeing, active community participation, and enable access to support services necessary to ensure positive lifestyle choices. Social metrics (social relationships) Engagement in volunteering. Establishment of selforganised groups or clubs. Successful reference to adult careers guidance services. 7 Residents with multiple support needs including those living in areas identified as priority by Boroughs and including family learning. FOCUS OF LEARNING PRIMARY PURPOSE PRIMARY OUTCOME/ MEASUREMENT RARPA (digital skills) Social metrics (confidence and progression, empowerment, social relationships) To raise the aspirations and ambitions of people of all ages living in deprived circumstances by giving them the practical skills and tools to engage in society and the economy, to support and encourage all family members, and to break down barriers between communities. 7 Digital skills (web browsing, digital security, transactions, accessing public services). Family learning activities (with parents, wider family members and children) Health education Courses to re-engage people in learning Literacy and language development ## 3 Commissioning Current block grant allocations for community learning are historic18. They bear no direct relationship between the current notional sum granted through the ESFA, or the numbers of learners who might potentially benefit from participation in the types of learning identified. Any significant change in allocation methodology (such as a move to a more traditional output based model) would require the use of extensive mitigation measures to reduce turbulence and minimise unintended consequences. A Retention of the Block Grant for Community Learning Community learning allocations to boroughs currently account for approximately £34 million of the Adult Education Budget and are provided by way of a 'block' grant. The block grant is a flat rate allocation (as opposed to an alternative formuladriven approach which funds providers primarily on numbers and hours of learning delivered). It provides a secure base for ensuring continuity, and in particular, that community learning develops in an integrated way with other public services (including health, police, housing, social services, and education) to address issues of economic and social prosperity at both borough and pan-London levels, and in accordance with local priorities. We consider that the block grant should be retained for community learning based on the following:  Current public service networks are well integrated. There are many examples of Community Learning working jointly to tackle 'big picture' aims such as addressing poverty, safety, equality, heath and housing (for example in Islington, the City of London19 and in Tower Hamlets).  Specific expertise and strong local networks are required to plan and deliver community learning effectively and respond to referrals, which means extensive use of learning advisers and community workers. In the best examples, programmes of learning are targeted to residential areas and streets where they will have greatest impact, are well embedded with other agencies, and intelligence about needs is derived from a wide range of local public services.  Services can be responsive. They can adapt and bring on line new provision in-year in response to newly emerging issues or opportunities in priority communities/groups or the local or wider economy.  Almost all providers have means-tested fees policies in place which require those who are able to pay for or contribute to the cost of their learning to do so. Overall, fees have increased in recent years and, for many providers, fees subsidise and support provision funded from public sources. ## B Future Models A key issue within *Skills for Londoners* is the targeting of funding, and at one level it is logical to propose that allocations to boroughs for community learning should be a computation, using validated data, which divides the funding available between Boroughs and direct providers according to need. London boroughs and the GLA hold significant data on issues relevant to planning community learning activity. This includes employment, qualification levels of residents, age, ethnicity, disability, the homeless and troubled families. If new arrangements for commissioning means that providers in receipt of community learning funding are required to focus on specific beneficiary groups, then targeted coordinated data sets will be needed to enable them to do so. Specifically, this will require readily-accessible statistics and background information at 'lower super output area' about employment, age, ethnicity, income levels, health, disability, crime and family circumstances, to enable targeted action. Our consultations favoured two broad approaches:  **changing allocations** now between boroughs to more fairly reflect their population of priority groups, or  developing a clear, consistent process of rigorous **business planning**, which requires every borough and community learning provider to prepare and submit a plan on how they intend to deliver community learning to priority beneficiaries, in some cases both within and beyond their borough boundaries. Boroughs and providers would submit their plans to the GLA for discussion and approval. Progress against the commitments in the Plan would need to be reported and monitored at agreed intervals. These two approaches are not mutually exclusive. One option would be to start with business planning, and move to a process of adjusting allocations once pan-London data has been assembled and validated, and key evidence about beneficiaries, costs and outcomes is available. It is of course recognised that the GLA as commissioner will determine the allocation methodology. A Changing current allocations In the course of this Project, we have undertaken **illustrative** work on modelling changes in allocations for community learning using different assumptions. In all cases we have focused our work on Lower Super Output Areas (LSOAs), which are sub-ward groupings, used for comparative purposes comprising approximately 1400 people. This is not intended to be a comprehensive list of options. Published statistical indicators which could be used to model allocations include the Index of Multiple Deprivation (IMD) which is comprised of weighted rankings relating to income, employment, education skills and training, health and disability, crime, barriers to housing and services and living environment. The most recent published data is 2015, but some of the components of the IMD related to 2010 and 2012. Other important data sources can be accessed via NOMIS (produced by the Office for National Statistics and updated regularly) which produces national and local profiles on the size of the adult population, employment, economic activity, qualifications, earnings, benefit claimants and the availability of local jobs. There are also a wide range of other data sources about health, disability and ESOL needs, but these do not necessarily provide a full picture of needs which is capable of being analysed and presented at Borough level. The modelling undertaken, available separately, consisted of three initial sets of parameters: 1. **A straight allocation on adult population of London only**20. At extremes, this would mean changes in allocations for 3 boroughs (Barking and Dagenham, Ealing, Enfield) of 100%+ and a reduction for 8 boroughs (City of London, Greenwich, Hackney, Hammersmith and Fulham, Kensington and Chelsea, Lewisham, Tower Hamlets and Westminster) of 30%+. 2. Allocations based solely on lower super output areas which fall into the lowest three deciles of IMD ranking. Again, at extremes, this would mean changes in allocations of 100%+ for 3 boroughs (Ealing, Enfield and Islington) and reductions of 30%+ for 13 boroughs (Bexley, City of London, Greenwich, Hammersmith and Fulham, Harrow, Hounslow, Kensington and Chelsea, Kingston-upon-Thames, Merton, Redbridge, Richmond-upon-Thames, Sutton and Wandsworth). 3. Allocations weighted towards the lower super output areas in the bottom three deciles of the IMD, but with a proportion of funding relating to the more prosperous LSOAs21. This is on the basis that within all LSOAs, there will be some priority beneficiaries. This would mean a change of 100%+ for 3 boroughs (Barnet, Ealing, Enfield) and reductions of reductions of 30%+ in 7 boroughs (Bexley, City of London, Greenwich, Hammersmith and Fulham, Kensington and Chelsea, Wandsworth and Westminster). To demonstrate the effect of changing allocations, but retaining a proportion of current funding to ensure service continuity across London, we modelled three further allocations: 4. Retention of 50% of each borough's current community learning funds, with 25% modelled on the number of people aged 50+ and a weighting for the number of LSOAs in the bottom three deciles. This would mean changes for one borough (Enfield) of 100%+ and reductions in one borough (City of London) of 30%+. 5. A 'flat rate' grant of 50% of the total community learning funding pot to be divided equally between all boroughs, with 25% allocated in accordance with the number of LSOAs in the bottom 3 deciles of IMD, and 25% based on the population aged 50+. This gives 3 boroughs (Barnet, Ealing and Enfield) increases of 100%+ and 6 boroughs (Greenwich, Hammersmith and Fulham, Lewisham, Tower Hamlets, Wandsworth and Westminster) reductions of 30%+. 6. As (5) but with a 25% flat rate grant, and the remaining two categories modelled on 37.5% each. This again benefits 3 boroughs (Barnet, Enfield, Ealing) to the tune of 100%+ and 7 boroughs (City of London, Greenwich, Hammersmith and Fulham, Lewisham, Tower Hamlets, Wandsworth and Westminster) reductions of 30%+ The detailed results of this modelling are available separately. Whichever parameters we use, applying IMD and population to the figures (in an attempt to make adjustments) results in major changes to current funding allocations. There are of course a range of other potential factors which might be used in combination with IMD which are relevant to meeting priority groups, but could create further complexity and may not produce significantly different results. It is important to remember that any adjustment to allocations would not deal neatly or precisely with the complete picture:  Most boroughs do not restrict use of community learning funding to their own residents. In the interests of serving learners and ensuring access remains local, they operate across local boundaries. We have modelled the catchment for each borough's community learning to demonstrate the present patterns of provision.  There are other providers offering community learning under a direct contract. For example, the Institutes of Adult Learning are active across London, with high concentrations of learners in Camden, Lambeth and Southwark, and the Workers' Education Association and London Learning Consortium deliver across several boroughs. This makes robust calculations and the concept of 'fairness' much more complex to achieve. Changes in allocations, even if they are phased in over a period of time would be disruptive to provision22, and there are other important considerations:  Significant costs would be incurred in reshaping provision on the scale required.  Addressing the issues outlined in *Skills for Londoners* means changes to provision. We want providers to focus leadership and management of community learning on developing new and innovative provision, enhancing quality, and working together to meet the economic and social needs of London - not on restructuring and redundancies.  Providers are generally 'good'. Funding reductions to good provision which meets the needs of priority beneficiaries may be challenging to achieve politically and practically. Should any change in funding allocations be considered in the future, they should be phased in over a period of time to mitigate the impacts outlined above and the option to base these on more precise data that better reflects need across the borough and the specific priority groups identified in this report should be explored. B Driving Change Through Business Planning Boroughs already produce annual plans of proposed provision, but there are significant differences in format and expectations between those receiving community learning funding. During workshops, several participants expressed the view that the quality of a borough's plan should be a determining factor in deciding allocations. We consider therefore that an alternative approach to driving change is to maintain the current pattern of allocations in the short term, and to place the emphasis on the production of a high-quality, borough-based business plan which:  Outlines how community learning funds will be used to support priority groups, and to plan and report against how this has been achieved.  Explains how the commissioning Borough/provider will work jointly with others to improve quality, develop a London-wide system of measuring outcomes, develop new curricula to meet needs, share expertise, and improve efficiencies.  Provides clarity on the purpose of funds for community learning and what can be classified as legitimate expenditure (which might include, for example, guidance on maximum recharges for business services and any sub-contracting arrangements).  Includes a clear programme of monitoring to ensure that these changes take place, within agreed timescale. These plans could be used to cover all AEB funding for the ACL service and would apply to the boroughs, IALs and other providers such as the London Learning Consortium. We would advise that the business plan forms part of the contract with the GLA. A failure to meet outcomes within pre-agreed tolerances would result in clawback, or in a reduced allocation for the following year. This is a decision for the GLA. Persistent or significant failure to meet outcomes would result in material reduction, or in some cases withdrawal, of the contract. Possible content of a 'business plan' to cover AEB funding over the period 2019-2022, updated annually: A brief overview of the service and type of delivery (direct, partnerships, subcontracted). The planned curriculum offer 2019+, and how it relates to the needs of London and to relevant local priority groups. Marketing and internal partnerships - focusing on how target beneficiaries will be engaged and supported. Other partnership arrangements (JCP, other boroughs and sub-regional partnerships (including pan-London), health services, providers, social housing, voluntary sector etc), focusing on what these arrangements will achieve and how their value will be assessed. Targets for engagement and retention of learners. The expected outcomes for learners, and how these outcomes will be assessed and reviewed. Quality (including for example, key points from the Quality Improvement Plan which accompanies the Self-Assessment Report). Value for money, including use of Pound Plus, matched funds from other sources. Ideally, this would be in the form of a 3-year plan, with annual reviews of performance, and confirmation of allocation for the following period in line with the wider Devolution agreement. Arrangements would be put in place to transfer funds in the case of underperformance beyond agreed levels of tolerance. In time, this computation may be adjusted to recognise the quality of outcomes, and other related factors, for example:  quality of provision (which should be at least 'good'). Given that community learning is *local* and is an important first step for many in reengagement, we believe that quality of provision is more critical than offering a choice of providers.  curriculum innovation, in particular responsiveness to current priorities and emerging local needs in the pursuit of outcomes  efficiency/value for money in producing positive outcomes. ## 4 Recommendations 1. That the GLA adopts the definition of community learning set out in this paper, together with the allocation of a 'block grant' to boroughs and current community learning providers, who will plan and deliver provision. The block grant will enable rapid 'integrated' action to tackle social and economic inequalities, help communities with complex and multiple support needs in learning, and directly contribute to the aims set out in *Skills for Londoners*. As an important part of the wider FE sector we expect that, in addition, Boroughs would continue to access the wider Adult Skills Budget alongside colleges, voluntary organisations, and the private sector. 2. That the GLA adopts a model of business planning rather than artificially adjust allocations at this stage. We believe that a model of business planning will produce results more quickly, it will provide continuity, and will focus providers on supporting priority groups. It will avoid the major disruption to community learning likely in the event of systemic redistribution of funding allocations. 3. That the GLA explores with providers developing pan-London arrangements to measure the value of community learning using social metrics, taking account of national developments. These should enable providers to benchmark both regionally and nationally and to exchange good practice. It will also provide clear evidence about the types of programmes and delivery styles which promote significant improvements in health and wellbeing, confidence, empowerment and which foster positive social relationships. 4. That pan-London arrangements are put in place by the GLA to track actual individual progression from community learning activities to higher levels of education and training, as a key measure of the success of all adult learning provision. This to include working with HMRC to agree an MoU to cover data sharing. The government should share this data with the GLA as soon as possible. 5. That the GLA liaises with Ofsted and the Education and Training Foundation (ETF). A specific focus within the Ofsted framework commenting on the quality of community learning outcomes would provide a valuable additional evidence base to the other methods and approaches proposed in this paper. The ETF is the leading organisation driving continuous professional development for the post- 16 sector and should be a key partner in supporting London's providers in curriculum innovation, quality improvement and the leadership of change. ## Appendix: Adult Community Learning, Social Metrics OUTCOMES FOR ADULT COMMUNITY LEARNING SOCIAL METRICS : Traditionally community learning has been quality assured through a national process, fully recognised as valid in Ofsted inspections, known as RARPA (Recognising and Recording Progress and Achievement). In broad terms, RARPA expects community learners, with support from their tutors as appropriate, to identify and record their learning goals, and periodically to determine progress towards achieving them. The potential range of outcomes arising from community learning programmes is very wide. It might include progression to more advanced studies or to work. In other instances, community learning contributes to improved health and wellbeing (potentially placing less pressure on public services), increased personal confidence to combat issues such as social isolation, or community and civic engagement Recently the Learning and Work Institute (LWI), commissioned by the DfE, has undertaken work on social metrics and their application to community learning. The intention of this work is that it should help to provide more secure, validated data for demonstrating the impact of community learning. The social metrics used were fully validated and tested. They fall into three broad categories: Confidence and Progression - questions seek to establish how positive people feel, whether they are able to make decisions, resolve problems, think more clearly and think more optimistically about their life. For the progression element (derived from LWI's work with DWP), questions focus on people's attitude to work, and how they view their readiness to take up employment. Empowerment, which includes questions about anxiety, confidence in managing and completing tasks and overcoming challenges. Social Relationships asks questions such as the breadth of friendships (including those about age and racial origin and religion), levels of trust in others, and people's sense of 'belonging'. There are some important lessons in how these tools should be applied successfully, including careful preparation, spending time with tutors explaining their potential value, administering them at a point in a course where learners feel able to engage fully in the process, and embedding social metric questions alongside other evaluative questions to relieve the burden of multiple surveys. A standardised approach to their use across London boroughs would enable valuable data to be collected about impact, and enable some benchmarking to take place. In London, Boroughs of Hackney, Lewisham, Lambeth, Westminster and Camden have been involved in small-scale pilots.
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Guidelines for market investigations: Their role, procedures, assessment and remedies April 2013 Guidelines for market investigations: Their role, procedures, assessment and remedies ## Contents | Introduction | 5 | |----------------------------------------------------------|------| | | | | Enterprise and regulatory reform 6 | | | | | | A brief note on terminology | 6 | | | | | Part 1: The promotion of competition in the UK 7 | | | | | | Threats to competition 7 | | | | | | Responding to the threats to competition | 8 | | | | | The market investigation regime | 8 | | | | | The making of references to the CC 9 | | | | | | Public interest issues 10 | | | | | | Terms of reference and the statutory questions | 10 | | | | | An AEC | 11 | | | | | Features 11 | | | | | | Remedial action 12 | | | | | | Part 2: The conduct of a market investigation 12 | | | | | | 1. | | | | | | The gathering and analysis of evidence 12 | | | | | | Range of analysis 12 | | | | | | Qualitative and quantitative analysis 13 | | | | | | 2. | | | | | | Processes and procedures 13 | | | | | | A. Statutory obligations and rules for Inquiry Groups 14 | | | | | | B. Appointment of Inquiry Groups and staff | 15 | | | | | C. Overarching procedural issues 16 | | | | | | D. The main stages of an investigation 18 | | | | | | Part 3: The AEC test | 24 | | | | | Part 3: Section 1—Market characteristics and outcomes 24 | | | | | | Market characteristics | 24 | | | | | Market share data | 25 | | | | | Other background market characteristics | 25 | | | | | Market outcomes | 26 | | | | | A. Prices and profitability | 26 | | | | | B. Quality, innovation and other non-price indicators 30 | | | | | | Part 3: Section 2—Market definition 30 | | | | | | The role and determinants of market definition 31 | | | | | | Assessing substitutability 32 | | | | | | Dimensions of the market 32 | | | | | | Product market 33 | | | | | | Geographic market 33 | | | | | | Other issues 34 | | | | | | Customer groups 34 | | | | | | Temporal dimensions | 34 | | | | | Grouping markets together 35 | | | | | ## Introduction 1. Market investigations were introduced by the Enterprise Act 2002 (the Act). In June 2003, the Competition Commission (CC) published CC3, Market Investigation References: Competition Commission Guidelines as one of the series of documents which it is required to publish under section 171(3) of the Act. Since the inception of the regime the CC has learnt much from its practical experience of conducting cases, and has progressively refined its policies, practices and procedures. These Guidelines distil the lessons the CC has absorbed since the introduction of the new regime and replace the 2003 version. 2. The Guidelines are in four parts, plus two annexes: - Part 1 outlines the nature of competition and sets market investigations within the context of the overall regime for the promotion of competition within the UK. It describes how references are made to the CC and the statutory questions the terms of reference put to the CC. - Part 2 provides guidance on the way the CC gathers evidence and the range and depth of its analysis, and outlines the processes and procedures the CC typically follows in conducting a market investigation and, if necessary, implementing remedies. - Part 3 addresses the three issues the CC looks at in applying the AEC test: - the characteristics of the market and the outcomes of competition within it; - the definition of the market; and - the state of competition in the market; specifically, whether there are any features harming competition. - Part 4 discusses the remedial action the CC may prescribe, if it has found there to be an AEC; this may include divestiture, behavioural remedies or recommendations for action by Government or other agencies. - Annexes: A: Market characteristics and outcomes: 1. Measuring market shares and concentration. 2. Measuring profitability. B: Remedial action. 3. The types of markets referred to the CC vary widely, making it impossible to cover in these Guidelines all issues and aspects that might be encountered during investigations. The CC's assessment of markets has inevitably to be case-specific. The Guidelines cannot therefore be applied in a rigid and mechanistic way. While the CC will always have regard to these Guidelines in conducting market investigations, it will apply them flexibly and may sometimes depart from them, explaining its reasons for doing so, if it considers that the particular circumstances of the case (including the information available and the time constraints applicable) justify doing so. Past case references are included in the Guidelines for illustrative purposes only and do not constrain the CC's approach. 4. The Guidelines reflect the views of the CC and the competition regime in place at the time of publication. However, markets, economic theory, the legal background and best practice may develop and these Guidelines may be revised from time to time to reflect such developments. ## Enterprise And Regulatory Reform 5. The enactment of reforms along the lines proposed in the Enterprise and Regulatory Reform Bill, introduced into Parliament on 23 May 2012, will have a significant impact on the structure of the competition regime, especially by transferring functions of the CC and the Office of Fair Trading (OFT) to a new body, the Competition and Markets Authority (CMA). 6. The prospective legislation, as introduced in parliament, would bring some changes to the market investigation regime. The CMA could be asked to investigate issues that affect different markets ('cross-market practices') and the Secretary of State would be able to ask it to consider defined public interest considerations during market investigations by the CMA. Some changes are also contemplated to the CC's remedy powers. The time limits for investigations would be tightened, with a proposed time limit of 18 months for investigations (with the possibility of a six-month extension) and statutory time limits for remedies implementation (see paragraph 89). In due course, these Guidelines will be updated to reflect these legislative changes. ## A Brief Note On Terminology 7. All references to statute, unless otherwise stated, relate to the Enterprise Act 2002— referred to throughout as 'the Act'—and all references to 'section(s)', unless otherwise specified, relate to the Act. The term 'referring body' refers to the body making the reference (see paragraph 22). 8. Several terms used in the context of market investigations are 'terms of art', having specific and limited, rather than literal, meanings: notably, 'theory of harm' (see paragraph 163), 'relevant market' (see paragraph 26), 'efficiencies' (see paragraph 174) and 'a well-functioning market' (see paragraphs 30 and 320). 9. Throughout this publication also: - unless otherwise specified, the term 'price' is used as shorthand for all aspects of a supplier's competitive offer; a change in price should be read as incorporating any comparable change in any element of the competitive offer; - the term 'customers' includes 'consumers';1 - the term 'products' is used to apply to goods and/or services; - 'market participants' are sellers, buyers and intermediaries, such as distributors, agents and platforms in multi-sided markets; - the term 'market power' is used to denote the ability of a firm to influence aspects of competition (see paragraphs 178 to 204: unilateral market power); there are gradations of market power, with many firms having limited or transitory market power but only some having 'significant market power' which endures over time and gives them the ability to maintain prices above the competitive level, or restrict output or quality below competitive levels, without the consequent loss of sales becoming unprofitable; and - the phrase 'to harm' competition is often used in the Guidelines as shorthand for the statutory language of 'prevents, restricts or distorts' competition. ## Part 1: The Promotion Of Competition In The Uk 10. Competition is a process of rivalry as firms seek to win customers' business. It creates incentives for firms to meet the existing and future needs of customers as effectively and efficiently as possible—by cutting prices, increasing output, improving quality or variety, or introducing new and better products, often through innovation; supplying the products customers want rewards firms with a greater share of sales. Beneficial effects may also come from expansion by efficient firms and the entry into the market of new firms with innovative products, processes and business models, and the exit of less successful ones. 11. In some instances firms compete for a market, rather than in a market, for example, by competing to be the first to claim a patent in a key area, the first to achieve scale in a new market, or to win a public procurement contract or franchise to supply a public service. 12. Vigorous competition between firms also fosters economic growth, as firms respond to competitive pressure by striving for efficiency and directing their resources to customers' priorities. Customers have an important part to play in stimulating rivalry between suppliers by making informed decisions which reward those firms that best satisfy their needs or preferences. Markets work best when both the supply side (the firms) and the demand side (the customers) interact effectively. ## Threats To Competition 13. There are many different ways—and combinations of ways—competition may be impeded in a market. Some instances are given in the following two paragraphs. 14. One or more firms may exhibit significant market power2 when the market is highly concentrated, potentially adversely affecting not only price, cost and profits levels but also competition in the more dynamic sense of innovation and product development. There may be barriers to entry and expansion of various kinds, giving incumbent firms an advantage over potential market entrants as a result of, for example, scale economies, technological expertise, a strong customer network or regulatory requirements. 15. Other ways in which competition can be threatened include: rival firms may adopt, in some cases only tacitly, a coordinated approach to the market; vertical relationships among firms may enable them to foreclose markets or customers to rival firms, or otherwise to exert a dampening effect on competition; and customers may lack information about what product to choose, may not be able to judge between different products on offer or may be locked into one supplier and unable to switch to another. ## Responding To The Threats To Competition 16. Regulators, competition authorities and governments have an important role to play in making sure competition is as effective as possible. They do so in various ways. Sometimes the Government may intervene directly in specific markets with this aim (for example, in the programme of liberalizing public utilities in the 1980s and 1990s). The merger control regime limits the ability of firms to avoid competing with their rivals by gaining control of them. Economic regulation of certain sectors involves measures to assist customers to make informed choices and to encourage new entry and investment, promoting the emergence of competition in markets where it has been historically weak. Regulators can also intervene directly to prevent or mitigate the harmful effects of a lack of competition in the short term. 17. Legal prohibitions play a particularly important role in limiting the extent to which firms are able to restrict competition between them or win customers in noncompetitive ways. Specifically, the prohibitions under the Treaty on the Functioning of the European Union (TFEU)3 and the Competition Act 1998 (CA98)4 are designed to prevent and penalize collusive conduct among rival firms or abusive practices by a dominant firm.5 Enforcement of these prohibitions falls, not to the CC, but to the European Commission and the OFT together with certain ('concurrent') sectoral regulators,6 respectively. ## The Market Investigation Regime 18. The CC's market investigation regime sits within the broad spectrum of competition law, operating alongside other regulatory mechanisms, including prohibitions (see paragraph 17), by allowing the competition authorities the opportunity to assess whether competition in a market is working effectively, where it is desirable to focus on the functioning of the market as a whole rather than on a single aspect of it or the conduct of particular firms within it. A market investigation may examine any competition problem and identify the feature causing the problem. It aims only to see Regulation 1/2003/EC. Under Article 1 of that regulation, where national competition authorities apply national competition law to agreements, decisions by associations of undertakings or concerted practices within the meaning of Article 101(1) which may affect trade between member states or to any abuse prohibited by Article 102 they shall also apply Article 101 or 102 respectively. Under Article 2 the application of national competition law may not lead to the prohibition of agreements, decisions by associations of undertakings or concerted practices which may affect trade between member states but which are not prohibited under Article 101(1) or which fulfil the conditions of Article 101(3) or are covered by an EC block exemption, although they may prohibit or sanction unilateral conduct engaged in by undertakings which is not prohibited by Article 102. Article 3 of the regulation provides that, without prejudice to the general principles and other provisions of Community law, Articles 1 and 2 do not preclude the application of provisions of national law that predominantly pursue an objective different from that pursued by Articles 101 and 102. In the context of a market investigation these provisions do not affect the exercise by the CC of its powers of investigation, but may be relevant at the remedies stage (ie the CC would have to consider whether it was limited or prevented from taking remedial action). If during the course of its investigation the CC uncovered a potential breach of Article 101(1), it would consider whether that matter should be referred to the authorities responsible for enforcing Article 101 but would also expect to continue with its investigation and then take the application of Regulation 1 into account when determining whether to take remedial action and if so, what action to take. If the CC found evidence suggesting a breach of Article 102 it would normally continue its investigation and, when appropriate, implement remedies under the Act. The OFT would then be able to take such action into account when carrying out any Article 102 investigation it considered appropriate. if competition within the particular market under review is working well or can be improved and is not seeking to establish general rules and obligations for firms. 19. Its overarching framework allows the investigation to tackle adverse effects on competition (AECs) from any source. As well as being able to look into the conduct of firms, the CC can probe for other causes of possible AECs, such as structural aspects of the market (including barriers to entry and expansion) or the conduct of customers. However, the focus of an investigation is always on competition. There may be other problems in the market—for example, 'externalities', such as air or water pollution, the cost or benefit of which is not transmitted through prices—which fall outside the ambit of a market investigation. 20. Having established a competition problem, and identified its causes, the CC is able to impose a wide range of legally enforceable remedies that typically focus on making the market more competitive in the future and make recommendations for remedial action by other public bodies. 21. The identification of anticompetitive features in a market investigation or the imposition of remedies does not mean that market participants7 have infringed the law. The process is investigative and inquisitorial, not accusatorial. To be required to give evidence in a market investigation or be subject to remedial action following an investigation does not imply that market participants are suspected of wrongdoing. The making of references to the CC 22. The CC does not select markets for investigation. The referring bodies—the OFT, a sector regulator8 or, exceptionally, a Minister9—make market investigation references to the CC when they have reasonable grounds for suspecting that a feature or combination of features of a market in the UK is preventing, restricting or distorting competition.10 However, once a reference is received, the CC proceeds wholly independently of the referring body; a CC market investigation casts a 'fresh pair of eyes' able to look more deeply at new evidence and analysis of the market. Regardless of the views of the referring body, it may conclude that there are no adverse effects in the market. 23. Before a case reaches the CC the referring body will have looked into the market in question, either on its own initiative or in response to a complaint, which may include a 'super-complaint' from certain designated consumer bodies. 11 The Act12 allows the OFT to study markets that appear not to be working well for customers. There is no statutory definition of a 'market study' but it was envisaged from the inception of the Act that the OFT should use market studies as a way to promote competition. The Enterprise White Paper *A World Class Competition Regime* (July 2001) said that the OFT 'should scrutinize markets to assess whether strong competition pressures are at work … in some cases … it will need to refer the market to the Competition Commission for further study'. The other sectoral regulators having powers concurrently with the OFT (see paragraph 22) can also study markets coming within their purview. Where a market study suggests that a market is not working well, the referring body has several options open to it. It may recommend legislation, or actions by customers; it may proceed to investigate any suspected breaches of consumer protection legislation or the competition law prohibitions; and/or, where it has reasonable grounds for suspecting there are features which prevent, restrict or harm competition, make a market investigation reference. (But the referring body may also accept undertakings in lieu of making a reference if appropriate undertakings are offered.) Where a market study leads to a reference to the CC, it thus serves as the first phase in a two-phase investigation process. 24. When faced with a choice on how to deal with a perceived competition problem, the approach the OFT or sectoral regulator takes will depend on many factors, some of which may suggest that a market investigation reference is the appropriate course:13 - A market investigation might be preferred when, for example, the facts and issues underlying a perceived competition problem are complex and other forms of intervention by the Government or regulatory body might have to be too tightly focused to benefit the overall operation of the market. - The range of remedies available under the market investigation regime can also make a market investigation a more appropriate instrument than relying on the system of prohibitions (see paragraph 17). Prohibitions on using market power to exploit customers or exclude rivals, or on coordinating with the few rivals that remain, may not be sufficient to address issues in a market whose characteristics and structure limit the ability or incentive of firms to compete effectively. There are markets, for example, in which the root cause of a problem lies within the regulatory framework; or it may lie within the way the market operates, with weak competition resulting, for example, from network effects,14 customer inertia or imperfect information flows between market participants. ## Public Interest Issues 25. Although market investigation references are generally only concerned with competition issues, in the first four months after a reference has been made, the Act allows ministers to ask the CC to consider the implications of its competition analysis for any public interest consideration Parliament may identify in the case. Correspondingly, in those four months, the CC is under a duty to bring to the attention of the Secretary of State any case that it believes raises a public interest consideration specified in the Act.15 (But it has not done so in any case before the issue of these Guidelines.) Substantial changes to the framework for the consideration of public interest issues are included in the Enterprise and Regulatory Bill currently (March 2013) before Parliament (see paragraph ). 6 ## Terms Of Reference And The Statutory Questions 26. In its terms of reference (ToR) for the CC investigation, the referring body describes the goods or services in the UK that the CC is to investigate. The ToR will indicate the sources (the feature or features, see paragraph 28) the referring body suspects are giving rise to an AEC (see paragraphs 19 and 29). When making the reference, the referring body may also require the CC to confine its investigation to either the supply or the acquisition of the goods or services described in the ToR, in particular by reference to the place where the goods and services are supplied or acquired or the persons by or to whom they are supplied or acquired or by or from whom they are acquired.16 The 'relevant market' is defined in the Act to mean the market for the goods or services described in the ToR given to the CC for investigation.17 130 The market definition(s) used by the CC (see paragraphs to 153) need not always correspond with the 'relevant market(s)' as used in the Act.18 It will also be for the CC to reach its own conclusions on whether or not there is any AEC. 19 27. The Act enables the ToR to be varied, either at the instigation of the referring body, after consultation with the CC, or at the request of the CC. In principle this could be to widen or narrow the scope of the investigation while it is in progress, although it would be likely to raise procedural and timing issues. A variation would not affect the statutory timetable. ## An Aec 28. The CC is required to decide 'whether any feature, or combination of features, of each relevant market prevents, restricts or distorts competition in connection with the supply or acquisition of goods or services in the United Kingdom or a part of the United Kingdom'.20 29. If that proves to be the case, under the Act this constitutes an AEC (see paragraphs 19 and 26).21 The CC interprets the phrase 'prevents, restricts or distorts' in the Act broadly to cover any adverse effect on competition, whether actual or potential. It will therefore consider features that affect potential competition in a market (for example, by preventing entry and expansion) as well as those that affect the existing market situation. 319 and 30. The Act does not specify a theoretical benchmark against which to measure an AEC. In its market investigation reports the CC uses the term 'a well-functioning market' in the sense, generally, of a market without the features causing the AEC, rather than to denote an idealized, perfectly competitive market. The criteria the CC applies in coming to a view on the existence of an AEC are discussed in paragraphs 320, below. ## Features 31. The Act states that the following may be taken to be a 'feature' of a market:22 (a) the structure of the market concerned or any aspect of that structure; (b) any conduct (whether or not in the market concerned) of one or more than one person who supplies or acquires goods or services in the market concerned; or (c) any conduct relating to the market concerned of customers of any person who supplies or acquires goods or services. 32. How the CC identifies features that prevent, restrict or distort competition is described in paragraphs 155 to 162. ## Remedial Action 33. Where the CC decides that there is an AEC, it is required to decide additional questions relating to remedial action, which are set out in paragraph 325. ## Part 2: The Conduct Of A Market Investigation 34. This part of the Guidelines begins by outlining the ways the CC gathers evidence and the range and depth of the analysis it conducts (paragraphs 35 to 41). A second section outlines the processes and procedures typically followed in the conduct of market investigations and in the implementation of remedies (paragraphs 42 to 93); the latter section discusses: (A) statutory obligations and rules for Inquiry Groups; (B) the appointment of Inquiry Groups and staff; (C) overarching procedural issues; and (D) the main stages of an investigation. 1. The gathering and analysis of evidence 35. In collecting and analysing evidence on the way the market under investigation operates, the CC will particularly try to assemble evidence on the impact possible features have on the market's operation. ## Range Of Analysis 36. The CC only carries out analysis that it considers necessary so as to reach a decision on the statutory questions. As the CC scrutinizes evidence, it will prioritize the uses of its resources to undertake as wide and as deep analyses as appropriate.23 37. The CC's analysis covers all relevant aspects of competition. It often assesses the ability or incentives firms have to offer better prices or terms to customers and to strive for efficiency, better ways of operating and improved products. 38. Whatever forms competition takes, the CC considers its effects and expected development over time. Although there may be circumstances in which analysis can be conducted only on the basis of the current state of the market, the CC always considers how a market may evolve. The prospect of gaining a lasting advantage over rivals can be a spur to competition, and the CC may in some circumstances consider assessing the effectiveness of competition for the market as well as, or rather than, within the market (see paragraph 11). ## Qualitative And Quantitative Analysis 39. The CC applies a range of analytical techniques, both qualitative and quantitative, so as to understand the nature of competition in the market under investigation as well as the impact of any features. The CC will seek data and information about a range of factors, including the pricing and quality of goods and services supplied in the market under investigation. It often commissions surveys, normally on customer behaviour and attitudes, at an early stage of an investigation (see paragraph 67). It will use various other means of collecting evidence, including questionnaires to parties, requests for internal company documents (including management information), and discussions with customers, investors and other market participants. (See paragraphs 63 to 69 on the procedures for information-gathering). 40. Parties may also choose to provide the CC with any information they consider relevant to the investigation. When making submissions involving technical economic analysis, parties should adhere to the principles set out in the CC's publication Suggested best practice for submissions of technical economic analysis from parties to the Competition Commission.24 A joint CC/OFT good practice guide for parties wishing to submit evidence based on consumer surveys in merger inquiries25 is also relevant to market investigations. 41. The extent to which the CC will seek to quantify particular effects (eg on the adverse effects on competition or the effects of remedies)—and the degree of precision with which this is attempted—is likely to vary from case to case. Relevant considerations in determining the extent and nature of quantification that the CC will carry out in a particular case may include: (a) The scale of any particular effect: if it is clear from an initial assessment that a particular effect is unlikely to be material, it may not be necessary to quantify its magnitude with great precision to reach a view about the scale of any harm to competition. Similarly, when it considers that the harm is material, the CC may decide that quantification would not add value to its assessment. (b) The practicality of conducting quantitative analysis: whether reliable data is available and the extent to which it is possible to quantify a particular effect with any degree of accuracy. (In general, it is likely to be more straightforward to estimate the effects on prices in the shorter term than to quantify the longer-term effects on dynamic and non-price competition.) (c) The resource implications: the costs in terms of time and resources to acquire and process the data, to apply a suitable methodology and to test the robustness of the results would not be justified if the outcome would not significantly help the CC to reach a decision on the statutory questions. ## 2. Processes And Procedures 42. The procedures the CC follows in market investigations have been developed to fulfil and balance different demands. It is imperative that investigations are concluded within the statutory time limit, and the time and resources of both the CC and the parties must consequently be used efficiently. At the same time, the CC recognizes that market investigations can result in significant interventions in markets and that its investigations must not only be thorough and disciplined but also fair. The requirement for fairness includes giving the parties opportunities to understand the CC's analysis affecting them; the CC accordingly aims to be open and transparent in its work.26 43. The following sections: A. outline the statutory obligations and rules with which Inquiry Groups must comply (paragraphs 44 and 45); B. explain how Inquiry Groups and staff teams are appointed (paragraphs 46 to 49); C. discuss some of the overarching procedural issues in conducting a market investigation (paragraphs 50 to 61); and D. provide a guide to the main stages in a typical investigation (paragraphs 62 to 93). ## A. Statutory Obligations And Rules For Inquiry Groups 44. The CC has a statutory duty to consult on its proposed decisions on the AEC test and the remedy questions when it considers a decision likely to have a substantial impact on any parties' interests.27 The Chairman of the CC is also required to issue Rules of Procedure for market reference Inquiry Groups. The current Rules of Procedure28 are published on the CC website and may be revised from time to time. The Rules include requiring Inquiry Groups to: (a) draw up and notify the parties of the administrative timetable for each investigation (and to prepare a revised timetable if required); (b) decide the forms of hearings (public or private, joint or individual) and who should attend them; (c) notify the main parties of their provisional findings on the statutory questions (on the AEC issue) and allow them at least 21 days to comment on the provisional findings; and (d) notify main parties of actions which may be taken to remedy the AEC and give the parties the chance to make representations about the Inquiry Group's proposed actions. 45. Subject to complying with the Rules of Procedure, and having regard to any guidance issued by the CC Chairman, Inquiry Groups are free to decide how they conduct a market investigation.29 ## B. Appointment Of Inquiry Groups And Staff 46. Market investigations are performed by Inquiry Groups of independent CC members30 (commonly between four and six), normally chaired by the Chairman of the CC or by one of the Deputy Chairmen.31 An Inquiry Group conducting an investigation provides its strategic direction, weighs the evidence and considers the arguments from parties, both received in writing and given orally, and directs and assesses the analysis produced by the staff team. It makes the final decisions on whether or not there are features of a market that give rise to an AEC and if so on the remedies to be applied. ## Appointment Of Inquiry Groups 47. As soon as practical after receiving the reference, the CC Chairman identifies and appoints an Inquiry Group. The composition of the Inquiry Group and biographical details of its members are sent to parties and published on the CC inquiry webpage. The appointment of the Inquiry Group is made for the duration of the investigation, up to the point at which the reference is 'finally determined.'32 48. Before deciding to appoint a member to a particular Inquiry Group, the CC will consider whether there might be a risk that a member's outside interests could affect, or could be perceived as affecting, the impartiality of the CC. 33 In some cases the CC may inform parties of specific interests and give them the opportunity to comment before deciding whether to make a proposed appointment. Relevant outside interests of appointed members are disclosed on the CC website. In addition, the CC may take action to deal with any relevant and significant changes in members' interests that may arise during the course of the investigation.34 ## Staff Team 49. Each Inquiry Group is supported by a staff team. The team is led by an Inquiry Director and includes both inquiry management and specialist staff. The inquiry management team is responsible for the day-to-day running of the investigation; the key point of contact at the CC for the parties is likely to be the Inquiry Manager. The specialist staff provide advice to the Inquiry Group in their areas of expertise 29 CA98, Schedule 7, paragraph 19 (see paragraph 17 above). (including economics, law, business and finance). They conduct the analysis on the substantive issues that arise during the investigation and develop remedies where needed. The staff team may sometimes be supplemented by academic specialists or other advisers. ## C. Overarching Procedural Issues 50. The following paragraphs provide an overview of the procedures for a market investigation. In practice some detailed aspects of the procedures used in a particular case may vary from those set out below. This is inevitable because no two market investigations are alike in all respects. The sectors under investigation can range in size from small, highly specialized industries to large-scale multi-faceted markets. Some references can encompass both upstream and downstream markets.35 Moreover, the numbers of parties with an interest in the investigation may vary from a few to several hundred. ## Managing Investigations With A Large Number Of Parties 51. All providers of the goods or services in a market under investigation are potentially main parties to an investigation. However, the degree of each party's engagement with the CC may vary, particularly where there are substantial numbers of main parties. The CC may need more information and evidence from some than from others. Some firms may choose to engage more with the CC than others. Differences in communication by the CC with different main parties may consequently reflect the different levels of party engagement. 52. In addition, there will be parties which are not providers of the goods or services in the market but which may be materially affected by the investigation (including supercomplainants,36 customers and consumer groups, upstream suppliers, and trade and professional bodies). Levels of engagement with these parties will also vary. For example, the CC may seek information from some of them, while others may volunteer information and views to the CC. 53. The CC makes extensive use in market investigations of its website to communicate or to make disclosures, enabling any number of parties to follow the progress of an investigation (as far as possible the CC alerts parties when relevant material is posted). While the detail of its processes might vary, the CC will ensure that its procedures are fair and give parties the opportunity to participate appropriately in an investigation. ## Timescales 54. The Act requires the CC to publish its report on a market investigation within two years of the reference.37 However, while its largest and most complex investigations will take two years, the CC aims to complete a 'standard' investigation within 18 months. 55. The timescales for the different stages of a market investigation cannot be exactly prescribed. The following timetable illustrates the progressive stages of procedures for an 18-month investigation. But in practice, some of the stages may overlap and on occasions developments in the investigation, for example a revision of the provisional findings and a consequent need for additional consultations, will require adjustments to the timings and procedures. | Stage of process | 18-month process | |------------------------------------------------------------------------|------------------------------------------------------------------------------------| | Reference | Pre-reference sharing of | | appropriate information with | | | the CC by the referring body | | | 'First day letter'/initial information requests | Months 1–2 | | Publication of initial issues statement (setting out theories of harm) | | | Initial submissions from main and third parties | | | Site visits | Month 3 | | Publication of relevant working papers | Months 5–9 | | Publication of annotated issues statement | | | Hearings with parties | | | Final deadline for all parties' responses before provisional findings | | | Publication of provisional findings | Months 11–12 | | Publication of remedies notice (if relevant) | | | Months 13–15 | Consideration of responses to provisional findings and consultation | | on remedies (if needed). | | | Response hearings with parties | | | Publication of provisional decision on remedies (if needed) | Month 16 | | Final deadline for all parties' responses before final report | | | Publication of final report | Month 18 | | | | | 56. | The CC draws up and publishes an administrative timetable at an early stage in the | | investigation. A draft is first sent to main parties for comment. | | | 38 | | | The administrative | | | timetable is updated as necessary during the investigation. | | ## Information Provision And Disclosure 57. While the time taken to conclude a market investigation depends on several factors, including the complexity of the investigation and the number of parties involved, a key factor is timely provision of information. The CC aims to be fair and reasonable in its requests for information and the deadlines it sets for parties to respond to such requests. It expects parties to meet the timescales set. The CC is empowered to require information and the attendance of witnesses.39 It will use its mandatory powers if necessary to ensure that its information requests are answered completely and in a timely fashion. The provision of false or misleading information to the CC is a criminal offence, regardless of whether that information has been provided voluntarily or in response to a statutory notice.40 58. In pursuing its aim to conduct investigations in a fair and transparent manner, the CC discloses its key documents, mainly by publishing them (in particular an issues statement, an annotated issues statement, provisional findings, Notice of possible remedies—if needed, provisional decision on remedies—if needed, and final report). Typically, it also publishes a large amount of other documentation, for example nonconfidential versions of key submissions from parties, including their submissions on the issues statement and responses to other publications, key submissions of third parties, hearing summaries, survey reports and some working papers. 59. The Act provides for the protection of confidential information relating to individuals and businesses.41 But the CC may disclose information under certain circumstances and having taken into account the considerations specified in the Act.42 43 60. Where issues arise as to the confidentiality of some information in the CC's possession that underlies a decision or a piece of analysis, but the CC nevertheless considers that disclosure of some sort is necessary to allow a party to comment on it, the CC may decide on some form of limited disclosure. 44 61. For further details on the statutory provisions relating to the information obtained during the course of an investigation and to its disclosure, see the Chairman's guidance to Groups and Chairman's guidance on disclosure. ## D. The Main Stages Of An Investigation 62. The following paragraphs describe the main stages of a market investigation and outline the key interactions which the CC has with parties and their advisers in the course of a typical investigation.45 This procedural guidance is not intended to be binding and may be adapted to take account of the particular circumstances of an investigation, in which case parties will be notified of the reasons for departures from usual procedures. ## Information-Gathering 63. The CC begins preparatory work on an investigation on a contingency basis shortly before the formal reference arrives. It identifies any relevant information that is publicly available and makes use of any market or company information that can be shared by the referring body46 so as to avoid duplication of effort by the parties or the authorities between the first phase (typically a market study by the OFT or other referring body47 22 ) and the second-phase market investigation. (But, as noted in paragraph , the CC's decisions are reached wholly independently of the referring body.) 64. Once the reference has been received, the CC formally launches its investigation with a 'first day letter' from the CC Chairman to key main parties. The letter includes information on the terms of the reference, the statutory deadline for the CC's report, relevant guidance material, the key CC staff working on the investigation, and the next steps to be taken. (Subsequently the CC, having consulted the key main parties, prepares the administrative timetable, see paragraph 56). The first day letter also takes forward the information-gathering process by requesting specified initial factual and financial information. 65. At an early stage, informal meetings are held between the staff team and selected main parties (and, where relevant, with other parties such as the supercomplainant).48 Such meetings usually cover the procedures to be adopted for the conduct of the investigation, and often seek information and views on the market. In addition, the CC holds 'data meetings' with appropriate main parties to discuss the organization and availability of technical data. (There may be subsequent staff meetings as the investigation progresses—see, for example, paragraph .) 73 66. A detailed market and financial questionnaire is next sent to the main parties; and, in many cases, other information is collected from a wider range of parties. The information-gathering will be informed by the developing 'theories of harm' (see paragraph 163). When practicable, parties are consulted on questionnaires to facilitate efficient collection of useful and consistent information, whilst as far as possible minimizing the burden to business. 67. The CC may decide to conduct one or more surveys as part of the informationgathering process (see also paragraph 39).49 If the decision is taken to conduct a survey, relevant parties are consulted on the draft survey design and content. In some cases, so as to construct the sample for questioning, parties may be required to provide contact details for some or all of their customers or suppliers. 68. In many cases, the CC organizes early site visits to several parties. These are designed to be helpful to both the CC and the parties involved. A site visit offers a chance for the Inquiry Group members and staff to gain a greater understanding of the party's business by visiting key facilities and meeting key operational staff. A party receiving a site visit is encouraged to organize a short presentation, and take some questions, on its business so as to explain its nature and the market context in which it is operating. ## Issues Statement 69. An issues statement is released by the CC at an early stage in the investigation process. This generally discusses the theories of harm framing the analysis the CC intends to pursue (see paragraph 163). Parties are invited to provide submissions commenting on the issues set out in the statement. ## Assessment 70. Using the information gathered and the theories of harm postulated the competition assessment gets under way. The issues addressed will be diverse, covering the many aspects raised by the investigation: for example, background on the market, the operation of the market or the performance of parties, market definition and assessments of the relevant competition issues set out in the issues statement. 71. The staff and the Inquiry Group work together on these issues, and many internal working papers are typically prepared on the various aspects of the investigation. Generally, internal communications are not disclosable. 72. The Inquiry Group's developed analysis is included in the provisional findings (see paragraph 81). However, the Inquiry Group will disclose its developing approach and analysis before publication of provisional findings: (a) Ahead of the main party hearings (see paragraph 77), it will disclose (normally by publishing) an annotated issues statement. This gives an overview of the Inquiry Group's current thinking with reference to the theories of harm and its analysis to date.(In this way, the theories of harm the CC may then be considering (paragraph 168) will be communicated to the parties.) (b) An additional means of conveying the Inquiry Group's developing approach and analysis is to disclose some of the working papers, or parts of working papers (see paragraph 71), often through publication.50 73. On occasions, specific pieces of technical analysis merit discussion between a party and the CC on the methodology used and, possibly, the results found. The CC arranges meetings with one or more parties for this purpose. These are generally attended by CC staff (together, on occasion, with members of the Inquiry Group), the party and its technical advisers. 74. The administrative timetable will include a deadline for the receipt of all parties' responses and submissions for consideration by the Inquiry Group in forming its provisional findings. ## Put-Back 75. The CC may also send ('put back') text to parties for the purpose of enabling them to: (a) verify the factual correctness of certain content (usually information supplied by them); and (b) identify any confidential material, prior to publication; parties are asked to provide reasons for any requests for excisions of the material from published documents. 76. The put-back process is separate from disclosure of the CC's developing thinking (see paragraphs 72 and 73). ## Hearings 77. The Inquiry Group holds a round of formal private hearings with parties (or a selection of them) ahead of the publication of its provisional findings. The primary purpose of these hearings is to enable the CC to test the evidence and explore key issues with the parties. They also provide an opportunity for the parties to explain their views in person directly to the decision-makers as their thinking is developing. The CC aims to ensure that hearings are held with as wide a range of parties as possible. However, decisions on which main and third parties to invite to hearings, and the sequencing of any hearings, rest with the CC. 78. Parties are given an opportunity to make brief opening and/or closing statements, and should expect to respond to the CC's questions. A transcript of the hearing will be taken and will be sent to the relevant party for checking (the transcript will not be published). Additionally, staff-led hearings (sometimes via teleconferencing) are conducted with some parties not attending hearings with the Inquiry Group, including some main parties when there are large numbers of them. Some members of the Inquiry Group may also participate. Transcripts or written notes are taken and sent to the relevant party for checking. 79. A summary of the key points raised at a hearing is normally prepared by the CC, and the party is given the opportunity to comment on both content and confidentiality before the summary is published. The party is also invited to follow up in correspondence any issue raised during the hearing. ## Provisional Findings And The Notice Of Possible Remedies 80. CC staff will start to gather information on possible remedies and identify relevant remedy options after the basis of a possible AEC has been identified. However, the investigation of possible remedies will remain hypothetical until a decision regarding a provisional AEC finding has been made, at which point the Inquiry Group will consider possible remedy options. 81. When the Inquiry Group has provisionally formed a view on whether or not there are features of the market(s) that give rise to an AEC, its provisional findings will be published and a public consultation on them will be held. The Rules (paragraphs 44 to 45) state that the time allowed for the consultation will be no less than 21 days and the CC applies some flexibility in setting reasonable deadlines case by case in light of the relevant circumstances. 82. If an AEC has provisionally been found, the CC will publish, in addition to its provisional findings, a Notice of possible remedies (the Notice). The Notice will contain details of remedies the CC has identified as possibly addressing the AEC effectively, and will provide a starting point for a discussion of remedies with the relevant parties to the investigation, including main parties, customers, competitors, any sectoral regulator and the OFT. The Notice may also outline details of remedies the CC considers unlikely to be effective and the reasons why it has reached this provisional view, as well as inviting parties to put forward any other remedy options that they wish the CC to consider. Normally, the CC will publish the Notice on the same date as its provisional findings and will set a deadline of no less than 21 days for responses, which may coincide with the deadline for responses to the provisional findings. ## Response Hearings And The Provisional Decision On Remedies 83. Where the CC provisionally finds that there is an AEC, response hearings will take place with main parties and potentially with key third parties. At a response hearing, parties will be given the opportunity to comment orally on the provisional findings and the CC may seek clarification of particular points made in written submissions or at the hearing. However, much of the discussion will focus on possible remedies and/or relevant customer benefits (RCBs) (see paragraphs 355 to 357). Transcripts, or alternatively Notes, of response hearings will be taken and, in most cases, summaries prepared and both will be processed in a similar way to those relating to hearings held earlier in the investigation (see paragraphs 77 to 79). 84. Having considered the responses from parties, the CC will notify its provisional decision on remedies, normally through publication on its website, for comment before reaching its final decision. The CC will normally allow a period of at least 21 days for parties to respond to its provisional decision on remedies. 85. Separately, a deadline will have been set in the administrative timetable for the receipt of all parties' responses and submissions for consideration by the Inquiry Group ahead of reaching its final decision. ## Final Report 86. The CC will publish its final decision on the competition question and (if necessary) remedies together with supporting reasons and information in a final report.51 The report will, if it confirms the finding of an AEC, contain sufficient detail on the nature and scope of remedies to provide a firm basis for subsequent implementation of remedies by the CC. 52 87. Parties may, during the two months following the release of the CC's findings, lodge an appeal with the CAT against the decisions. If a judgment of the CAT upholds an aspect of an appeal, this could lead to the investigation or a part of it being remitted to the CC for reconsideration. (Appeals against CAT judgments can, if allowed, go forward to the Court of Appeal or, in Scotland, the Court of Session and, ultimately, to the Supreme Court.) ## Implementation Of Remedies 88. Following publication of the final report, if the CC has determined to take action itself, the CC has the choice of implementing remedies by accepting undertakings from the relevant parties and/or by making an order (see paragraphs 92 and 93 for a discussion of the considerations relevant to this choice). 89. The CC will publish an administrative timetable for the implementation of those remedies where it has decided to take action itself. For straightforward remedies, the CC expects to make an order or accept undertakings within around six months of publication of its final report. The implementation of more complex remedies may take longer, though the CC expects to make an order or accept undertakings within ten months from publication of its final report, other than in exceptional circumstances.53 The CC consults all parties affected by the remedies in determining the required undertakings or order. This includes a period of formal public consultation.54 55 90. The action the CC takes in implementing remedies must be consistent with the decisions in the final report unless there has been a material change of circumstances since the preparation of the report or the CC has a special reason for acting differently. 91. An Inquiry Group will normally be disbanded following its acceptance of Final Undertakings or the imposition of an order to implement remedies. Responsibility for overseeing any further implementation activity that falls to the CC, such as the implementation of any divestiture remedy, falls to either the CC's Remedies Standing Group or to a specifically-appointed Group. A Group specifically appointed to oversee further implementation activity may include some or all members of the original Inquiry Group (see footnote 32). The identity of the Group charged with this activity is determined in light of factors such as the availability and expertise of members, the type of remedy to be implemented and the extent to which implementation is expected to be resource- and/or time-intensive. If all remedies are being implemented by means of recommendations to other bodies, the Inquiry Group originally appointed is normally disbanded following publication of the final report. The OFT is normally responsible for monitoring and enforcement of behavioural remedies56 following acceptance of undertakings or the imposition of an order by the CC. Compliance with undertakings or an order is enforceable in the courts.57 ## Undertakings And Orders 92. The CC's decision whether to implement remedies by means of accepting undertakings or making an order is determined case by case, primarily by practical issues including the number of parties concerned, and their willingness to negotiate and agree undertakings. Another consideration is the scope of the CC's ordermaking powers and whether the remedy it is considering falls within those powers. 93. The content of any orders made by the CC is limited by the Act.58 In contrast, the subject matter of an undertaking is not similarly limited.59 This, and the process involved in agreeing undertakings, can help the CC and the parties, in terms of flexibility and suitability, in implementing remedies. However, because market investigations are likely to be market-wide rather than focused on the conduct of one firm, it may be more practical to implement remedies by order rather than through undertakings, so as to avoid the likely delay and complexity of negotiating undertakings with several parties.60 In regulated sectors, if the CC decides to modify licence conditions to give effect to, or take account of, any provision of a proposed remedy, it will make an order.61 ## Part 3: The Aec Test 94. In assessing whether or not an AEC has arisen the CC looks at three basic issues: (a) the main characteristics of the market and the outcomes of the competitive process; (b) the composition of the relevant market62 within which competition may be harmed (market definition); and (c) the features, if any, which are harming competition in the relevant market (the competitive assessment—which the CC frames using 'theories of harm'), considering also possible countervailing factors, such as efficiencies, which may remove or mitigate the competitive harm of the features. 95. Analyses of these issues are not conducted as distinct chronological stages of the investigation but as overlapping and continuous pieces of work, which often feed into each other. For example, the CC may take an initial view about the scope of the relevant market but the competitive assessment may suggest that this initial view of the market was either too broad or too narrow. Evaluation of outcomes continues throughout the investigation. 96. Part 3, Sections 1 to 3, below, deal with each of these issues in turn, and are followed by a short section on the conclusion of the AEC test. ## Part 3: Section 1—Market Characteristics And Outcomes 97. To develop robust findings on whether or not features in a market are harming competition, the CC needs to understand how a market operates and reach a view about its performance. A part of its investigation is therefore the collection and analysis of information about the main characteristics of the market referred and the outcomes of the competitive process within that market. The CC's evaluation of characteristics and outcomes goes on throughout an investigation and continuously informs its assessment of what might be causing any adverse effects in the market. ## Market Characteristics 98. Reviewing evidence and observations on the main characteristics of the markets that it investigates helps the CC to frame the analysis of market definition and competitive effects, as well as to assess the practicability of remedy options, should an AEC be found. 99. Any assessment of the working of competition usually begins with an overview of market structure and the possible implications of this structure for the conduct of the firms within the market. The CC studies the profiles and performances of the suppliers (or, where relevant, acquirers) of the goods or services referred for investigation. ## Market Share Data 100. The CC calculates the market shares of the suppliers of the reference products (and sometimes other measures of market concentration), if possible over several years, using the methodologies set out in Annex A (The measurement of: market shares and concentration; profitability). 101. The calculation of market concentration measures can provide background data for the assessment of the levels of firms' market power (see paragraphs 9, 14 and 186 to 195)63 195 and may be relevant for the assessment of other sources of potential competitive harm, for example coordinated conduct. In many cases, the weight the CC places in its competitive assessment on market concentration measures will be influenced by its ability to define with confidence the boundaries of that market (see paragraph ) so as to ensure that these are neither too narrow nor too wide (paragraph 137). However, there are some measures of market concentration, such as the Logit Competition Index (LOCI), which can be used, if relevant information is available, without relying on establishing market boundaries (see Annex A, paragraph 8). ## Other Background Market Characteristics 102. The other market characteristics most relevant to the CC's investigation will vary from case to case. However, the CC normally looks at the following: (a) The nature and characteristics of the products or services included in the terms of reference and of any potential substitutes for these products. (b) The nature of the customer base—for example, whether customers are businesses or final consumers, the extent of customer segmentation in a market, the demographic profile of the customer base or, where relevant, the extent to which they are informed about the products in the market subject to investigation. (c) The legal and regulatory framework that applies to the reference market. Laws and regulations can determine the nature of competition within a market and may also be relevant to the CC's consideration of remedies. (d) Industry practices, for example the way in which products are sold and how prices are set and communicated to customers. (e) The history of the market, including recent competitive developments such as any recent examples of entry, expansion or exit and any significant changes that are anticipated in the market in the foreseeable future. ## Market Outcomes 103. Outcomes of the competitive process in their different forms in a market—eg prices and profitability, levels of innovation, product range and quality—can also provide evidence about its functioning. Evaluating these outcomes helps the CC determine whether there is an AEC and, if so, the extent to which customers may be harmed by it, ie the degree and nature of 'customer detriment'. This can be an important factor in any later consideration of possible remedies. 104. Prices and costs are among the more observable and measurable outcomes and an analysis of these may be useful in quantifying the extent and nature of competition and can be helpful in measuring customer detriment. However, the other, lessquantifiable factors, such as quality and innovation, are no less important to customers. 105. Although the outcomes of the competitive process may differ in character, there may be linkages between them, and the CC does not therefore consider each in isolation. The extent to which prices respond to changes in costs and the question of whether those costs are at an efficient level, for example, may have implications for a firm's profitability, and the level of investment may have implications for efficiency and product or service quality. 106. The following paragraphs in this section deal in turn with: A. Prices and profitability. B. Quality, innovation and other non-price indicators. ## A. Prices And Profitability 107. The types of analysis the CC may undertake on prices and profitability depend on the nature of the markets and the theories of harm the CC has postulated (see paragraphs 163 to 169). Four possible types of analysis are considered below: pricing patterns; price cost margins; price comparisons; and profitability. ## Price Patterns 108. In markets subject to effective competition prices are likely to respond to changing supply and demand conditions and firms will seek to win business by improving their prices and other aspects of their offer. The pattern of prices over time can therefore indicate the nature of competition (see, for example, paragraph 246). However, the CC recognizes that there may be several factors affecting prices and will take this into account when considering inferences from this type of analysis. Taken in conjunction with other evidence and in the absence of other explanatory factors, such as cost increases: (a) static or continually rising prices may indicate a lack of competition; and (b) parallel pricing—ie the practice by a seller of varying prices in a similar way and at about the same time as competitors—may be a symptom of coordinated effects (see paragraphs 249 and 189). 109. The pricing strategies adopted by firms in the market can also be indicative of competitive conditions. For example: (a) introductory discounts followed by price increases might indicate high switching costs or customer inertia (see section on weak customer response, paragraphs 295 to 318); and (b) a wide range of prices for similar goods or services might indicate the presence of search costs (see section on weak customer response, paragraphs 295 to 318). 110. Another type of analysis in this category, price concentration studies, looks at the extent to which prices may vary with market concentration. This is relevant to the assessment of unilateral market power (paragraphs 186 to 195). For example, if there were several local geographic markets, higher prices being charged in more concentrated areas may indicate limitations in the competitive process in those areas.64 This type of analysis may also examine the relationship between prices, margins and concentration over time. ## Price-Cost Margins 111. The analysis of prices will in many cases be complemented by an analysis of costs, because these may explain price changes over time or differentials between areas. Therefore when analysing patterns of prices over time or geography, the CC may consider price-cost margins. Typically a price-cost margin is calculated by subtracting some measure of marginal cost from revenue and expressing the difference as a percentage of revenue.65 112. Price-cost margins can also provide useful information about the effectiveness of competition in the short run (ie for a current range of products), including about the willingness and ability of customers to switch between alternatives. Vigorous competition may be expected to lead firms to price towards marginal cost. The CC may therefore consider the pattern of price-cost margins across geographic markets or customer segments or over time. A pattern of sustained high price-cost margins may, for example, indicate an unwillingness or inability to switch because of, for example, switching costs, search costs, limited customer information or significant product differentiation (see section on 'weak customer response', paragraphs 295 to 318). But the CC interprets price-cost margins with caution: margins may be a misleading indicator in some industries66 and in many circumstances a gap between price and marginal cost can be consistent with robust competition.67 A fuller analysis of profitability may be required to establish whether prices are on average above the competitive level, as described below. ## Price Comparisons 113. Comparisons of prices with those of other markets, such as markets for similar products in other countries or in markets for comparable products in the UK, are sometimes made in CC market investigations. Such comparisons can be relevant where market conditions are similar. In the Home Credit investigation (November 2006), for example, the CC found that prices in that market were high in comparison with the prices of other credit products and were higher than prices in the Republic of Ireland, where similar products were offered to customers. ## Profitability 114. One approach to the question of whether prices are above competitive levels is to consider the profitability of the business activity being investigated. In many cases, the CC's focus will be on the largest incumbent firms in the market or market sector. However, the CC may also consider the profitability of less well established firms with smaller market shares, eg for comparative purposes. Where the business activity being investigated is only one part of the firms' activities, it will be necessary to take this into account. 115. In its analysis the CC is concerned with economic profits and these can differ in important respects from accounting profits. The CC will generally derive the profitability of the relevant business activity by identifying the relevant revenues and costs for that business activity, including an appropriate value for capital employed and an allowance for the cost of capital. More information about the CC's approach to the calculation of profitability is in Annex A (The measurement of profitability). 116. Firms in a competitive market would generally earn no more than a 'normal' rate of profit—the minimum level of profits required to keep the factors of production in their current use in the long run, ie the rate of return on capital employed for a particular business activity would be equal to the opportunity cost of capital for that activity. The profitability of firms representing a substantial part of the market can therefore be a useful indicator of competitive conditions in a market (see paragraphs 118 and 119). 117. In practice, a competitive market would be expected to generate significant variations in profit levels between firms and over time as supply and demand conditions change, but with an overall tendency towards levels commensurate with the cost of capital of the firms involved. At particular points in time the profitability of some firms may exceed what might be termed the 'normal' level. There could be several reasons, including cyclical factors, transitory price or other marketing initiatives, and some firms earning higher profits as a result of past innovation, or superior efficiency. 118. However, a situation where profitability of firms representing a substantial part of the market has exceeded the cost of capital over a sustained period could be an indication of limitations in the competitive process. 119. The ability to earn profits persistently above the competitive level could indicate the presence of entry barriers (see paragraph 231). A situation where a firm with a large market share has earned profits that have been persistently above the competitive level may indicate significant market power (see paragraph 180). A situation where levels of profitability have remained persistently high and stable over time across several incumbent firms may indicate coordinated conduct (see paragraph 247). 120. The extent to which the results of profitability analysis indicate limitations in the competitive process may depend on both the size of the gap between the level of profitability and the cost of capital and the length of the period over which the gap persists. 121. The appropriate time period over which to examine the persistence of the gap between profitability and the cost of capital may therefore vary according to the specific market. The pattern of investment and the nature of sources of competitive advantage (advertising, research and development (R&D), more efficient production) may affect the CC's view of the relevant timescales over which it would expect to see competition playing out in the market. Where large and risky investments have been made, the CC would expect to see a normal level of profitability restored over a relatively long timescale. 122. In cases where a persistent gap is not unequivocally substantial, it is particularly important for the CC to consider the analysis in conjunction with other information about the operation and nature of the market concerned. 123. Moreover, as with other forms of analysis, the CC's interpretation of profitability analysis may be affected by the quality of the data available (see section on the gathering and analysis of evidence, paragraphs 35 to 41). 124. The trend in profits will be an important consideration and the CC will seek to understand the reasons for the observed trend. Where the size of the gap between the level of profitability and the cost of capital has grown over a period the competitive situation may have worsened. Where that gap has narrowed competitive conditions may have improved. Where that gap has fluctuated the CC may consider whether, on average for firms representing a substantial part of the market, profits have exceeded the cost of capital. 125. A CC finding of low profitability would not necessarily signify that competition is working well. Low profitability may be concealing ineffective competition. Reasons for this may include: (a) A period of low profitability may occur during the course of a downturn in trading conditions, regardless of the state of competition in the affected market. (b) Weak competition as a result of customers not responding effectively to competing offers may sometimes result in an inefficient market structure in which operators have higher costs and set higher prices than would be the case in a competitive market68 295 (see section on weak customer response, paragraphs to 318). (c) Incumbent firms, despite being protected from new entry, are not earning high profits because they are inefficient and operate with higher costs than would be sustainable with stronger competition in the market (see section on barriers to entry, paragraphs 205 to 236). In some cases, the CC may be able to compare actual costs with efficient costs when looking at the level of profitability achieved by firms but this may not always be practical. ## Indicators—Not Features 126. In summary, the CC will consider prices and profitability in the context of its overall assessment of the market. While useful, findings that price-cost margins are wide or profitability is high in a market do not on their own provide conclusive evidence that the market could be more competitive. Such findings are not in themselves causes of competitive harm—they are not features of the market for the purpose of the AEC test. ## B. Quality, Innovation And Other Non-Price Indicators 127. As indicated above, prices and costs are not the sole indicators of the level of competition in a market. Poor quality, lack of innovation, or limited product ranges are prominent among other indicators of weak competition in a market. Evidence about this kind of indicator tends to be qualitative, coming particularly from surveys, questionnaires or discussions with customers, investors, or other market observers. In several past market investigations, such analysis has spotlighted various negative non-price factors as important indicators of weak competition. 128. In the investigation into Northern Irish personal banking, the CC chose a range of indicators on which information was readily obtainable and readily comparable and, analysing responses to questionnaires, made a comparison between banks within Northern Ireland and some of the large banks based in Great Britain. This evidence indicated several non-price indicators of a lack of competition between Northern Irish banks in relation to branch opening hours, functionality of Internet banking and product innovation.69 In its investigation into PPI, the CC considered evidence it had obtained so as 'to identify: any new PPI policies which had been introduced, whether there had been any innovations within existing policies, the rationale for product change or innovation, and whether, and if so how, distributors advertised and marketed their policies'. The CC concluded that there was less choice (and possibly less innovation), as well as higher prices, 'than would be expected in a wellfunctioning market'.70 129. In its investigation into BAA airports, the CC compared Aberdeen Airport with other regional airports and found slower development of routes; lack of ambition in development; underinvestment and poor facilities. In relation to the South-East of England airports the CC found a lack of responsiveness to the interests of airlines and passengers that would not be expected in a well-functioning market; 71 weaknesses in the approach to planning and consulting on capital expenditure; and deficiencies in the level and quality of service.72 ## Part 3: Section 2—Market Definition 130. A market is a collection of goods and services provided in particular geographic areas (or in some cases to particular groups of customers or at particular times), connected by a process of competition. The process is one in which firms seek to win customers' business over time by improving their portfolios of products and the terms on which these are offered, so as to increase demand for the products (see paragraph 10). The willingness of customers to switch to other products is a driving force of competition. In forming its views on market definition, the CC will therefore consider the degree of demand substitutability. In some markets, supply-side constraints will also be important (see paragraph 134). 131. In considering the substitutability of goods or services or areas of supply set out in the ToR, the CC may (as stated above, paragraph 26) conclude that the market definition goes wider or narrower than those goods and services. ## The Role And Determinants Of Market Definition 132. In defining the relevant market (see paragraph 26), the CC identifies the participating firms and customers and the traded products in the market(s) that are the subject of the reference. This enables the CC to focus on the sources of any market power73 and provides a framework for its assessment of the effects on competition of features of a market (see paragraph ).74 31 133. Market definition is thus a useful tool, but not an end in itself, and identifying the relevant market involves an element of judgement. The boundaries of the market do not determine the outcome of the CC's competitive assessment of a market in any mechanistic way. The competitive assessment will take into account any relevant constraints from outside the market, segmentation within it, or other ways in which some constraints are more important than others. 134. While the composition of a relevant market is usually determined by the degree of demand substitutability (see paragraph 130), the CC will where relevant include supply-side factors in defining the market. There might, for example, be a possibility that firms supplying non-substitute products have the capabilities and assets to redirect production to goods and services that would be substitutes for those in the market.75 198 (For further detail on substitutability, see paragraphs to 204.) Alternatively, the same firms might compete to supply the non-substitute products under similar conditions of competition; in that case aggregating the supply of these products and analysing it as one market does not affect the competitive assessment (for example, in markets characterized by bidding and tendering processes76 ). 135. The nature of competition in a particular market (and the theories of harm 77 under consideration) may require that the CC identify more than one market for the same product so as to understand different aspects of competition. For example, in some industries certain aspects of competition are determined at a national level, while others occur at a local level. Looking at how competition operates at both levels, and at how the levels interact, could produce important insights.78 136. Substitutability in the short run may, moreover, be different in the longer term. In the short run firms compete on the basis of the products in their existing portfolios and the current geographical footprint of their distribution systems. In assessing short-run competition the CC will therefore usually define markets on the basis of substitutability between existing products and areas. However, in the longer term concentration and to consider the constraints of supply-side substitution from different operators. firms may compete by improving their product portfolios, or extending the geographical scope of their operations. The CC's assessment of this sort of competition may be concerned with identifying groups of firms that have the capability to introduce new or improved substitute products, or open new outlets in a more broadly defined product category or areas. ## Assessing Substitutability 137. In defining a market it is important to ensure that the pool of products identified as effective substitutes for the relevant product(s) is not unrealistically small. If the market is drawn too narrowly there is a risk that a party is incorrectly viewed as holding significant market power,79 whereas in reality that position is undermined by constraints from alternative suppliers that should be included in the market. (Conversely, defining a market too widely carries the risk that market participants, in seeming to be in weaker positions, are inferred to have less market power than they actually enjoy.) 80 138. The hypothetical monopolist test (HMT) is a tool which can be used to identify effective substitutes and to check that the market is not defined too narrowly. The principle behind it rests on defining a market as a product, or collection of products, a sole supplier of which could hypothetically impose a small but significant nontransitory increase in price (sometimes referred to as the SSNIP test). The test can help to identify the constraints that would prevent a hypothetical monopolist from exercising market power. In practice it may often be used, not quantitatively, but as a conceptual framework. 139. There are some practical difficulties in using the HMT in market investigations. If significant market power is already being exercised, using prevailing prices can lead to defining markets too broadly and possibly to an incorrect inference that significant market power does not exist. 81 In theory, the HMT could be implemented in the presence of significant market power using notional competitive prices, but in many cases it is difficult to assess what those prices would be. There is also a risk that using a notional benchmark in effect assumes the existence of significant market power as part of the framework within which the competitive assessment is being undertaken.82 140. The CC will consider the pros and cons of using the HMT depending on the particular facts and circumstances of the case, including whether the practical difficulties mentioned above can be avoided and how informative its use would be. 141. In practice, the HMT is more likely to be used to check that the market has not been defined too narrowly in cases where the CC's findings include a finding that high concentration is a feature harming competition (see paragraph 195). ## Dimensions Of The Market 142. The different dimensions of the market are discussed in the following sections. These are (as indicated in paragraph 130): the product dimension, the geographic dimension, and markets defined with reference to customer group or temporal factors. ## Product Market 143. The CC may consider the following types of information, where available, when assessing whether products are substitutes: (a) Product characteristics, such as physical properties and intended use that can indicate similarities (from the purchaser's perspective) between different products. (b) Relative price levels and the extent to which prices of products within the possible relevant market are correlated with each other, as compared with the prices of products outside that market. (c) Prices and sales volumes over time or across areas that permit analysis of the way that customers respond to changes in prices or to firms entering or leaving the market. (d) Responses from customers, competitors and interested and informed third parties to questions—sometimes posed in surveys—about customer behaviour. (e) Firms' view of the products, drawing on internal documents such as marketing studies, consumer surveys prepared in the normal course of business, market analyses prepared for investors, and internal business analyses (eg board papers, business plans and strategy documents). 144. The existence of a market for secondary products has sometimes to be considered in fixing the dimensions of a market. Secondary (or aftermarket) products are those that are purchased only as a result of the customer having purchased a primary product. An example is the market for printer cartridges, a secondary market linked to the primary market for printers. The CC may sometimes consider primary and secondary products to be in separate markets. However, it may consider the products to be in the same market where customers take into account the cost of the secondary product when purchasing the primary product (see also paragraphs 291 to 293). Whichever of the two definitions is chosen will not determine the outcome of the CC's competitive assessment, since the competitive constraint from other suppliers will be taken into account in either case.83 ## Geographic Market 145. Geographic markets may be based on the location of either suppliers or customers. In the case of the former, the geographic market is an area covering a set of firms or outlets which compete closely because enough customers consider them to be substitutes (as in the case of retail markets and some industrial markets). In the latter case, a geographic market is an aggregation of customers paying individually negotiated prices but enjoying sufficiently similar purchasing options (ie in effect many customers in industrial markets). 146. The geographic market: may be local, regional, national or wider. Imports may be taken into account as well as UK products. Depending on the circumstances of the case and the theory of harm posited, the CC may examine geographic markets at more than one level in the same investigation, eg at both national and local levels. 147. The key to defining both supplier-based and customer-based geographic markets, as to defining the product market, is the degree of substitutability, ie the extent to which suppliers can switch their areas of supply and the extent to which customers in one area may be served in another area. 148. In the case of supplier-based markets the geographic scope may be described as a set of competing outlets. In identifying these sets the CC may consider the following information on: (a) the catchment areas from which the bulk of an outlet's customers is drawn; (b) differences in pricing, sales, advertising and marketing strategies by area; (c) which outlets customers consider to be substitutes for each other; and (d) natural experiments which show the effect on one outlet's sales arising from entry, exit or expansion by other outlets nearby. 149. The CC may consider the following when identifying the boundaries of customerbased markets: (a) product characteristics such as perishability; (b) differences in pricing, sales, advertising and marketing strategies by area; (c) information enabling the estimation of switching costs (which can include additional delivery costs) that customers might incur in changing to products currently supplied in other geographic areas, relative to the value of the products and the length of time taken to make the switch; and (d) the flows of goods between regions or into the UK and any barriers to entry, whether legislative, natural or strategically created. ## Other Issues Customer Groups 150. Many markets serve a diverse customer base, for example suppliers may have both business and personal customers. One set of customers may be more affected than others by any particular feature. Where such diversity exists, and where suppliers can charge different prices to different groups (ie price discriminate), the CC will recognize these differences. In terms of market definition, depending on the market and the evidence presented, the CC may choose either to treat these different groups as separate markets, or as segments within one market, noting the scope for price discrimination between different groups within the market (see also the discussion of the hypothetical monopolist test at paragraph 139). ## Temporal Dimensions 151. When customers are not able to substitute products between periods, there may be a temporal dimension to the market, for example seasonality, peak and off-peak services. A typical example concerns commuters and leisure travellers on trains. Commuters constrained by their hours of work have little choice but to travel at 'peak' times, during which the train companies charge more than at other times. On the other hand, leisure travellers may be less concerned about the time of travel and more willing to travel at off-peak times and are charged less. In such instances, depending on the circumstances of the case, the CC may decide to define two or more markets, or it may decide to define only one market and note the scope for price discrimination within the market, for instance identifying a market for rail travel with different prices charged to peak and off-peak travellers. ## Grouping Markets Together 152. In some cases, the CC may treat a group of product, geographic or other types of markets together for the purposes of assessing competitive effects. This can be the case where a feature manifests itself in a similar way across several different markets (for example, the need for an operating licence may be an aspect of many local markets) and the CC is able to reach a view about the effects of the feature on competition across the group of markets as a whole. In the investigation into home credit,84 for example, the CC was satisfied that the conditions of competition were sufficiently similar to justify a conclusion that applied throughout the reference area, without looking at every geographic area in detail. ## Effects Outside The Relevant Market 153. The CC may also consider effects in neighbouring markets, including those which are upstream or downstream of the relevant market (see paragraph 26). For example, one firm's advantage as a buyer in an input market may protect it from competitive pressures when supplying a downstream market for manufactured goods relying on that input. If the input market has been referred to it, the CC may consider effects in the downstream output market. ## Part 3: Section 3—The Competitive Assessment 154. In deciding whether or not there is an AEC, the CC's core task—given the statutory questions (paragraphs 28 and 29)—is to assess the effects of possible features on competition. In conducting this assessment, the CC will seek to establish whether or not any of the possible features, or any combination of them, can be expected to harm competition when measured against a theoretical benchmark (see paragraphs 30, 319 and 320). The emphasis on assessing the competitive effects of features means that any AEC finding will be grounded in a clear understanding of why competition in a market may be harmed. ## Identifying Features That Harm Competition 155. As noted in paragraph 31, a market feature may be intrinsic to the structure of the market or may arise from the conduct of any market participant (whether supplier, acquirer or customer and whether or not in the reference goods or services market). The Act does not require the CC to state whether particular features of a market are to be considered structural features or an aspect of conduct. Provided the relevant feature falls within at least one of these categories, the categorization is of little practical importance. Since the concept of a feature is broad, the CC has the flexibility to investigate a wide range of possible market features, each of which may have effects on the different aspects of competition (see paragraphs 13 to 15). Moreover, how far any feature identified by the CC is along a causal chain resulting in harm to competition may vary (ie some may be directly causing harm and others may be doing so indirectly). 156. It has been emphasized (see paragraph 22) that the CC, on receiving a market investigation, makes no presumption that there are market features that harm competition. A CC investigation may find that there are no such features giving rise to an AEC in the relevant market (as was the case in the investigation into Movies on Pay TV85 ). ## Structural Features 157. Structural features may include high levels of market concentration, high entry barriers, common ownership of competing facilities and buyer power.86 For example, market concentration was identified as a feature harming competition, in the market investigations into classified advertising services87 and the supply of groceries by retailers;88 high barriers to entry in the cases of the supply of groceries and domestic bulk liquefied petroleum gas (LPG)89 and the ROSCOs90 investigation; common ownership in the case of BAA airports;91 and buyer power in the case of the supply of groceries investigation. 158. Specific structural features identified in past investigations to be harming competition include aspects of the planning system, government policy and the regulatory system (in the BAA airports investigation and, with regard to the planning regime, in the grocery retailing market); the criteria applied for the award of franchises (in the ROSCOs market investigation); information asymmetries between incumbents and entrants (in the home credit market investigation); 92 and a point-of-sale advantage for credit providers selling PPI (in the PPI market investigation).93 ## Conduct Features 159. 'Conduct' of a market participant includes any failure to act, whether intentional or not, and any other unintentional conduct.94 160. Conduct features by sellers identified in past investigations as harming competition include: a failure of Northern Irish banks sufficiently to explain their charging structures and practices for personal current accounts; 95 and the failure of distributors and intermediaries in the market for PPI to try to win customers by setting competitive price or quality levels for their policies.96 'Exclusionary behaviour'—for example, by bus companies deliberately obstructing the services of competitors97 — also falls within the category of a conduct feature. The conduct of firms which supply the market when acting in other markets can be a feature of the market. For example, if the market investigation concerned competition to supply a particular manufactured good, the conduct of vertically integrated suppliers in the market for the input might be a conduct feature. 161. The behaviour of customers can also sometimes be a feature limiting competition between firms. (As noted in paragraph 19, market investigations allow the competition authorities to look at customer behaviour and customer vulnerability in relation to their implications for competition, instead of just looking at them as consumer protection issues; see also paragraphs 295 to 318). The insensitivity of customers to measures of price other than the level of weekly repayment was found to be a feature detrimental to competition in the home credit market.98 Similarly, the low sensitivities of customers to store card APRs99 and late payment charges were identified as features harming competition between store card credit services.100 A customer behaviour feature—failure to investigate alternative accounts or banks— was also found in the market for personal current accounts in Northern Ireland.101 ## A Combination Of Features 162. In some circumstances, several features may in combination harm competition. In the PPI investigation,102 for example, competition was found to be adversely affected by several interconnected features, including barriers to searching and switching, which hindered customers' ability to compare PPI policies or to switch to alternatives, as well as the point-of-sale advantage credit providers enjoyed. Barriers to searching included product complexity, the perception that taking PPI would increase a customer's chances of being given credit, the bundling of PPI with credit and the limited scale of stand-alone provision. Barriers to switching included contract terms which made switching expensive or which risked leaving customers uninsured. ## Theories Of Harm 163. To provide focus and structure to its assessment of the way competition is working in a market the CC sets out one or more 'theories of harm'. A theory of harm is a hypothesis of how harmful competitive effects might arise in a market and adversely affect customers. The use of the term does not imply any prejudgement of an AEC in a given market. 164. Focusing the competitive assessment on the testing of theories of harm helps the CC to understand the market and to evaluate evidence so as to be able to decide the statutory question of whether or not there is a prevention, restriction or distortion of competition and, if so, identify what features are causing it. The use of theories of harm also helps the parties by identifying the issues that will be addressed and indicating the information that will be gathered. ## Formulating And Reviewing Theories Of Harm 165. The starting point for formulating theories of harm in market investigations is the work already done by the referring body, particularly the terms of reference (paragraph 26) and decision documents.103 These will not only include observations on the structure of the market but will also have described the products the referring body considers are affected and the features it has grounds for suspecting may be the cause of harm to competition. At this stage, the CC supplements the analysis carried out by the referring body with its own initial consideration and may formulate theories of harm involving other possible aspects of the market on the basis of its own analysis (see paragraphs to 105 on market characteristics and outcomes). 98 166. The initial theories are set out in the issues statement published at an early stage in an investigation (see paragraph 68). In the market investigation into local bus services, for example, the CC noted in the issues statement (4 February 2010): 'It appears from the OFT investigation that in many (local bus) markets there is limited head-to-head competition. The OFT's report also suggests that concentration is high.' It went on to list hypotheses as to why this might be so, including theories derived from barriers to entry, supplier behaviour and aspects of the tendering and bidding systems. 167. Although the CC aims to focus on those aspects of the market that appear most likely to influence competition directly, these are not always clear at the outset of an investigation. At this early stage, one or more theories may often therefore be set out in broad, generic terms. 168. As the CC investigates the interlinked issues of market characteristics and outcomes, market definition and the operation of competition within that market, it reviews its theories. The theories often become increasingly specific to the investigation. Some may be dropped and others put forward (see paragraph 72 for information on how substantial changes in theories of harm are communicated to the parties). 169. Several different hypotheses may be put forward for investigation. They need not be mutually exclusive. One or more theories may be linked to different outcomes, may in combination produce a single outcome, or may relate to different markets. On the other hand, several competing theories may sometimes be advanced linking features with observed market outcomes, and in that case the CC has to consider which theory, if any, best explains the outcome. ## Potential Sources Of Competitive Harm 170. Individual theories of harm are numerous and specific to different market investigations. However, most draw on a limited number of common potential sources of competitive harm. These reflect the nature of competition as set out in Part 1 (paragraphs 10 to 15), which explained that the constraints helping to ensure that competition is effective mainly come: first, from other firms already in the market; secondly, from firms that could readily enter it; and, thirdly, from their customers; conversely, competitive harm can flow from five main sources: (a) unilateral market power (including market concentration); (b) barriers to entry and expansion; (c) coordinated conduct; (d) vertical relationships; and (e) weak customer response. 171. The list is not exhaustive. While the majority of theories of harm flow from these five sources, other theories may be identified that do not do so. 172. Moreover, the five sources are not mutually exclusive. Individual features identified in a market investigation have been associated with more than one of them. Some may have mutually reinforcing effects. Barriers to entry and expansion, in particular, have been found to be features, sometimes in combination with other features, in many investigations. ## Countervailing Factors 173. In assessing the potential sources of harm, the CC considers aspects of the competitive situation that may, on the other hand, benefit competition and operate to the benefit of customers. 174. In some circumstances, for example, the positive effects of *efficiencies* on competition associated with a particular market feature may outweigh the harmful effects of that feature, which would otherwise cause an AEC. Efficiencies can enhance rivalry when they induce one or more firms to follow a course of action of benefit to customers (eg lowering prices or increasing innovation) in response to actual or expected actions by rivals. Examples of such rivalry-enhancing efficiencies are given within each of the following sections on the potential sources of competitive harm. Should the CC decide that, despite the existence of some efficiencies that benefit customers, there is still an AEC in the market, these efficiencies may be taken into account as RCBs when the CC considers possible remedies (see paragraphs 355 to 366). 175. The prospect of *entry or expansion* (see paragraphs 205 to 236)—and therefore of stronger competition in the longer term—may also sometimes offset competitive harm that may otherwise arise, if there are no significant barriers to entry or expansion and the CC judges that: (a) actual entry or expansion is likely, of sufficient scale and swift enough to constrain incumbent firms in the near future; or (b) the threat of potential entry or expansion is sufficient to exercise a constraint even though no actual entry of sufficient scale has been observed in the recent past (small-scale past entry does not demonstrate the absence of entry barriers see paragraph 234); such a constraint could arise when entry would be swift and low-cost so as to exploit any commercial opportunity in the market. 176. Countervailing buyer power may also be taken into account in the CC's competitive assessment. In some markets prices are in effect determined by the relative bargaining power of sellers and buyers. The exercise of buyer power can sometimes be a feature harming competition (see paragraph 157 and footnote 86). However, in other circumstances 'countervailing buyer power' can have the positive effect of preventing the exercise of a supplier's market power in the bargaining process. The presence of large buyers relative to the size of the suppliers does not necessarily guarantee that the buyers can exert countervailing buyer power. The relative importance to each buyer and supplier of its business with the other party104 is a key factor, and the strength of the buyers' 'outside options', ie their alternative strategies in relation to the relevant product, is often the crucial determinant of countervailing buyer power. Whether or not suppliers have the ability to offer different prices that discriminate between customers and customer groups, and thereby reduce any potential impact of buyer power, can sometimes be an important issue in the CC's assessment. The CC will also assess the extent to which the benefits of any countervailing buyer power are passed on to customers in lower prices. ## The Five Potential Sources Of Competitive Harm 177. The following subsections deal with each of the five sources of potential competitive harm identified above (see paragraph 170) by considering first the nature of the mechanism involved, and secondly its potential impact on the market, including any positive effects, and the CC's approach to testing this impact. 1. Unilateral market power 178. As explained in Part 1 of these Guidelines (see paragraph 14), competition within a market may be weak when one or more market participants105 enjoys significant market power,106 and is therefore able to influence market outcomes and other important aspects of competition. The features that give rise to significant market power may cause an AEC to arise. When exerted by a single firm, or by several firms acting independently in a market, such power is termed 'unilateral market power', distinguishing it from the market power that arises as a result of coordinated conduct. 179. A single firm's level of market power will be related to the elasticity of demand for its product and its rivals' elasticity of supply for that product. The market power of a firm will be strong if the level of demand for its product is insensitive to an increase in price of that product and if its rivals are unlikely to step up their supplies in response to a price rise. Significant market power may also be conferred on one or more firms operating in markets with particular characteristics. Such cases include: (a) monopolies, where a single firm or group supplies all or nearly all of a market for a product or service; (b) oligopolies, where a concentrated market or industry is dominated by a small number of sellers (see paragraph 189); (c) network or two-sided markets providing services over a network or through a platform;107 and (d) secondary or after-markets (where the products are purchased only as a result of the customer having purchased another (primary) product; see paragraph 144 and paragraphs 291 to 293). ## Indicators Of Unilateral Market Power 180. The CC may sometimes observe indicators of unilateral market power, such as high profits (see paragraphs 114 to 126), high price-cost margins (see paragraph 112), low single-firm demand elasticities (see paragraph 179) or other evidence of adverse effects in the form of high prices, low quality and limited choice (see paragraphs 127 to 129). 181. The way a firm behaves—for example, in relation to its customers or competitors— may also give an indication of the market power it may enjoy. However, actions apparently indicating the exercise of unilateral market power may be benign or even beneficial practices. For example, a supplier pitching prices below cost may be predatory action, but may alternatively be part of an introductory offer which will expand future demand for the product and therefore increase competition in the longer term. ## Innovation And New Product Development 182. One important outcome of unilateral market power can be to stifle incentives on firms to innovate or invest in product development and thereby prevent the gains in productive efficiency and customer benefits that innovation or new products bring over time. When firms face competition—whether from other incumbents or from the threat of entry—the possibility of generating high profits encourages them to discover new products and processes. In contrast, firms that do not face competitive pressures may choose not to invest significantly in R&D (see paragraph 121). 183. However, the relationship between market power and innovation is not always clear cut. Large incumbent firms may benefit from significant economies of scale in the innovative process.108 On the other hand, an incumbent firm with unilateral market power may have a lower incentive to innovate than a smaller competitor or new entrant because it has less to gain.109 In some markets innovators may expect to benefit only to a small extent but, even in such markets innovation incentives may be strong if rivalry is intense. 184. In assessing market power in high-technology industries, the CC will pay particular attention to the number of products and/or technologies that are being developed. Another useful indicator in high-technology industries is R&D spending relative to sales. High R&D spending to sales ratios provide a clear indication that competition takes place through innovation. Where R&D investment is high, market power may be vulnerable to future innovations by rivals or new entrants. Substantial shifts in market share over time are also positive signs of a high level of rivalry in innovative or high-technology industries. ## Assessing Sources Of Unilateral Market Power 185. Generally, the most common reasons for one or more firms to possess unilateral market power are: ## (a) high concentration (see paragraphs 186 to195); (b) capacity constraints (see paragraphs 196 and 197); (c) lack of substitutability (see paragraphs 198 and199); and (d) absence of supply-side constraints (see paragraphs 200 to 204). ## (A) High Concentration 186. An examination of market structure, including the initial calculation of market shares and sometimes other concentration measures (as discussed above, paragraph 101 and in Annex A), often provides a starting point for the assessment of firms' market power. 187. In general, a highly concentrated market—as indicated by, for example, persistently high market shares held by one or more firms—might be an indicator that one or more firms hold unilateral market power. If a firm has a high market share it might have less incentive to compete vigorously with its rivals (particularly if there are barriers to entry). For example, if a price reduction aimed at new customers would also apply to existing customers, a firm with a large market share may be more reluctant to implement a price reduction than might one with a small share. The firm with a large market share may feel little pressure to reduce price even if a smaller rival does so. 188. A large market share could also confer advantages in bargaining with suppliers upstream, or buyers downstream (see paragraph 50), and a firm may be able to control prices in its favour or impose conditions in the negotiation process that restrict competition in one or more markets. 189. As explained in paragraph 179, market concentration and the exercise of market power are not necessarily linked to the position of a single firm. A market with a small number of suppliers which are protected by barriers to entry (an oligopoly), for example, may be characterized by significant market power. One mechanism by which this market power can manifest itself is through coordinated conduct (see paragraphs 237 to 294). However, unilateral market power can be enjoyed by a number of firms even where they act independently, albeit aware of each other's presence—so-called 'non-coordinated oligopolies'.110 In such situations, each firm knows that it can affect market prices and hence its rivals' profits. This awareness conditions the way in which competition occurs, although the precise way it does so will depend on the specific characteristics of the market in question. 190. A large market share does not always indicate that competition within the market is weak. It may simply indicate that the firm(s) possessing it is capable and relatively efficient, having low costs, an attractive product, or both. Moreover, a firm with a large market share could be vulnerable to entry and expansion which might constrain its market power (see paragraphs 175), or face countervailing buyer power (see paragraph 176). 191. Conversely, since a firm's level of market power will be related to the elasticity of demand for its product, and to its rivals' elasticity of supply for that product (see paragraph 179), even a firm with a low share of sales of a product may have significant market power if both measures of elasticity are low. 192. Observed changes in market share over time (see paragraph 101) may help interpret the implication of high concentration in a market. For example, when market shares have been stable over time, especially in the face of historical changes in prices or costs, high concentration may indicate that competition within the market is weak. However, a highly concentrated market may be competitive if market shares fluctuate over short periods in response to changes in competitive offers; such volatility may indicate the existence of effective competitive constraints, such as successful entry and innovative developments. 193. In markets characterized by bidding and tendering processes (see paragraph 134 and footnote 76), market shares may fluctuate only when tenders occur and a firm may have a high market share at any given point, as a result of winning several recent tenders, without necessarily possessing significant market power. 194. In some cases, recent or ongoing changes in market conditions may indicate that the current market share of a particular firm either understates or overstates the firm's expected competitive significance in the near future. Predictable effects of such changes—for example, the spreading of new technologies, the longevity of patents and the prospective development of new products—may be taken into account when calculating and interpreting market share data. 195. In some circumstances, the CC will find that high concentration is a feature causing harm to competition. It has been so identified in several market investigations (see paragraph 157). As explained in paragraphs 101 and 137, the CC will consider how confident it is that it has defined the market neither too widely nor too narrowly before identifying market concentration as a feature harming competition. The CC would generally expect to find this in conjunction with other features, such as barriers to entry. ## (B) Capacity Constraints 196. In markets involving relatively undifferentiated products, one or more market participants may find it profitable unilaterally to reduce output and increase the market price (eg by leaving capacity idle or diverting production to another market). Such a strategy is more likely to be profitable when any rival is limited by capacity constraints or a relatively low elasticity of demand in the market (see paragraph 179). In some markets, therefore, share of capacity may be more important than share of supply. 197. In assessing the power of a firm to suppress output unilaterally in this way the CC focuses on the degree of spare capacity other firms in the market may possess, the ease with which these firms could expand existing capacity, and their commercial incentive to counteract any overall output shortfall. ## (C) Lack Of Substitutability Of Products 198. A firm may also enjoy unilateral market power because it controls a group of close substitute products, for which its customers have limited alternatives. In differentiated product markets, while some products can be close substitutes and compete strongly with each other, others are more distant substitutes and compete less strongly. Branding, quality, product characteristics or geographical location will have effects on the extent to which a product competes with another; one high-end product, for example, may compete more directly with another high-end product than with a lowend product. 199. Assessing the extent of direct competition between close and distant substitute products may involve calculations of diversion ratios and of cross-price elasticities of demand.111 The higher the cross-price elasticity of demand between two products the closer substitutes they are in the eyes of customers. ## (D) Weak Supply-Side Constraints ie 'supply-side substitutes' do not come into the market. 200. Unilateral market power can only be sustained if potential market participants will not respond to a price rise by expanding their production facilities to produce the goods and services concerned,112 113 201. Two products are considered to be supply-side substitutes if the supplier of one of the products already owns the key assets needed to produce and market the other, without incurring additional sunk (ie non-recoverable) costs. An incumbent firm may be able to do so, and sometimes new entrant firms may exert a competitive constraint if they can easily and rapidly begin selling in the market without incurring significant sunk costs. This may be the case when, for example, a firm has idle capacity or when it produces the relevant product but sells it in a neighbouring geographic market—or to customers in another market. Similarly some firms, even producing relatively distant substitutes, may have access to the know-how, and may have assets (physical and human) that can be easily and rapidly adjusted to produce and distribute close substitute goods. 202. So as to assess the extent to which suppliers of potential supply-side substitutes enhance competition in the market (or whether the absence of supply-side constraints restricts competition), the CC considers whether: - there are economic incentives to engage in production of the relevant goods/services; - the suppliers are able to divert production to the relevant goods or services, or conversely are contractually tied to continue production of existing products; and - the suppliers possess unused plant capacity that can be brought into production at a reasonable cost.114 115 203. The CC will also consider whether the existence of supply-side substitutes influences the market behaviour of incumbent firms which otherwise would enjoy significant market power (seeking evidence, for example from internal documents, past episodes of successful rapid entry and exit, and from customers about the credibility of rapid entrants ). 204. In assessing the prospects of expansion, repositioning, and mobility, the CC will consider in particular, the timing of the likely supply response, possible legal restrictions, access to distribution channels, and commercial risks and incentives on account of such factors as customer loyalty, brand reputation or managerial expertise. ## 2. Barriers To Entry And Expansion 205. Entry or expansion by firms will often stimulate competition and, as noted in paragraph 175, the prospect of entry and expansion within a short time can sometimes countervail against a prospective AEC decision. The possibilities of entry by outside firms or the expansion of incumbent firms have featured in most findings on whether or not there is an AEC in a market. 206. Firms can enter a market or expand within it in several ways. Firms coming into a market may build new capacity or take over existing capacity to use it in new or more productive ways. Incumbent firms may expand by building new plants or capacity, developing new products or expanding into neighbouring markets. Incumbent firms may invest in upstream or downstream companies to suppy materials and process their output, respectively (see paragraph 50). Entry or expansion, or just the threat of it, can: - upset established patterns of market conduct, particularly by making it difficult for an incumbent firm to continue wielding significant market power; - promote efficent firms at the expense of inefficient ones; - introduce new technology and fresh approaches to product design, marketing and delivery; the impact of entry and expansion on innovation within an industry has been observed above (see paragraph 182); and - lead to more competitive prices as well as greater choice and quality to the benefit of customers. 207. A major source of competitive discipline is therefore generally eliminated or reduced if there is any barrier to market entry and expansion, whether an absolute barrier116 or some other form of restriction such as aspects of the market that deter entry.117 Barriers to entry and expansion give at least some incumbent firms an advantage over efficient potential firms or rival incumbent firms, either by reducing the expected profits, or increasing the expected costs, of entry or expansion. They may therefore constitute a feature, often in combination with other features, that harm competition. 208. The main focus of the CC's assessment of the conditions for entry and expansion in a market is generally on the ability and incentive of new or relatively small incumbent firms to enter into or expand in a market. However, the prospects for larger incumbent firms, which can also in some cases be an important driver of competition, will also be evaluated. 209. A barrier to entry, as well as denoting different levels of restrictions (paragraph 207), takes various forms. The following sections of these Guidelines, first, outline the different types of barriers to entry and, secondly, describe the CC's approach to assessing the impact of these barriers. The barriers surveyed are mostly entry barriers but some are barriers to expansion; the same analytical principles apply in assessing both sorts of barrier. ## Types Of Entry Barriers 210. There are three broad categories of barriers to entry: natural or intrinsic barriers; strategic and other 'first mover' advantages (including the endogenous costs of investing in market entry118); and regulatory barriers. Other factors will also help determine an entrant's decision to move into a market, for example, the possession of the necessary production facilities, and the economic prospects for the market. Barriers to exit—the cost of exit from the market if the business venture fails—have also to be considered. Barriers to entry or exit can interact with and magnify each other's effects.119 ## Natural Or Intrinsic Barriers To Entry 211. Firms entering a market unavoidably incur costs, These costs can sometimes in effect be 'natural' or 'intrinsic' barriers to entry, and may include the cost of putting the production process in place, gaining access to essential facilities or inputs and the acquisition of any necessary intellectual property rights (IPRs). Important considerations in evaluating the effects of such costs on the ability of firms to enter the market are the nature of the costs and the extent to which the costs are 'sunk', ie investments that cannot be recovered upon exit and hence would serve to commit a firm or firms to staying in the market. Sunk costs may include, for example, some specific asset investments, advertising, R&D and, in some markets, the costs of acquiring a reputation (eg for producing quality products).120 (Non-sunk costs, in contrast, are recoverable if production ceases, and do not therefore pose the same risk.) 212. Economies of scale, in combination with sunk investment costs, can constitute a barrier in cases where these relate to the cost of getting into or expanding in the market. 213. In industries where economies of scale are significant, entry on a small scale may not be profitable unless the firm is aiming at a 'niche' in the market or can develop a new production strategy which offsets the disadvantages of small-scale production. Entry on a large scale will often entail a high risk (that sunk investment costs may not be recovered) because it will generally be successful only if the firm can expand the total market significantly, or substantially replace one or more existing firms.121 214. Entrant firms may also face disadvantages relative to incumbents where production costs decrease as the cumulative quantity produced increases (ie through 'learning by doing'). Similar considerations apply to economies of scope, which arise where producing two (or more) products is less costly for a single firm than for two (or more) firms each to produce the products separately. Where economies of scope are significant, an entrant, if it is to be successful, might have to produce a range of products from the outset, adding to the costs of entry. 215. Other disadvantages to entrants, imposed by natural or intrinsic barriers to entry, may arise simply because incumbents are already in the market. Switching costs for customers may be such an intrinsic barrier, as well as other demand-side factors (see also strategic and 'first-mover' advantages, paragraphs 217 to 222). 216. Network effects—where other customers committing to a particular product or service makes it more attractive to new customers (see paragraph 179)—may constitute a barrier to entry.122 This is because incumbents with an existing customer base have an automatic advantage over entrants. However, when demand is growing fast, or innovation is rapid, the barrier might not be as high as when demand or technological change is more static. ## Strategic Advantages Of Incumbents 217. Some forms of investments by incumbents, although they may often be procompetitive and/or benefit customers, may sometimes have the effect of deterring market entry by increasing the sunk costs of entry. Such barriers are termed strategic and can have the effects of: (a) lowering the incumbents' costs relative to those of potential entrants (for example, by increasing capacity); (b) altering the cost structure of rivals (for example, by vertical arrangements); and (c) altering demand conditions in their favour (for example, by brand and product proliferation). 218. Such strategic entry barriers may increase the risks faced by new entrants. For example, vertical arrangements may in some cases make it difficult for an entrant to gain sufficient distribution outlets, because existing sellers are largely tied up with existing suppliers, or to gain access to vital components (see also paragraph 269). 219. The risks will be proportionately higher if the sunk costs of entry are high and the difference between the incumbent's profitability and the rival's post-entry profitability is substantial. In general, the greater the financial investment needed by a potential entrant the greater becomes the risk associated with entry. 220. The existence of significant switching costs for customers may act as a barrier to entry. These may be intrinsic to the market (see paragraph 215), but firms may also act strategically to increase them, for example by offering fidelity discounts or agreeing long-term contracts with customers, accompanied by penalties for early termination. Moreover, incumbent firms producing complementary goods may tie or bundle them together, potentially raising the costs for an entrant producing only one of the complementary goods (see paragraphs 286 to 290). 221. The incumbent firms may also be able to deter entry by signalling that they would respond aggressively to entry, including by over-investing in spare capacity, or seek to target entrants specifically to discourage them from entering the market. ## 'First Mover' Advantages 222. Other entry barriers may result simply from the established position of the incumbent firms in the market. Such so-called 'first-mover' advantages may make it difficult for other firms to enter a particular industry because experience or an established reputation is necessary to compete effectively. Relevant factors in this context include customer loyalty to a particular brand, the closeness of the relationships between suppliers and customers, and the role of promotion or advertising in the particular industry. ## Regulatory Barriers To Entry 223. The ability of firms to enter a market can be affected by the market's regulatory framework, broadly defined as including any applicable legislation (for example, intellectual property law and planning law),voluntary or compulsory standards and codes of practice, and other applicable sectoral regulations. 224. Regulations may be beneficial for a variety of reasons ranging from ensuring the stability of the financial system to protecting the environment, but they may inhibit the extent to which competition can flourish in certain circumstances. Some types of regulations may concern the production process and the characteristics of the finished product, for instance health and safety standards. Others may limit the number of competitors in the market directly, for example by requiring that only firms with a licence or permit may operate within it.123 225. With regard to their effect on competition, a distinction can be drawn between regulations that impose costs proportionately on all firms and those that hit new entrants harder than incumbent firms. Subsidies, tax reliefs and preferential purchasing may raise barriers to entry in a market if potential entrants are not equally eligible for them. Barriers that raise fixed costs can more easily be absorbed by an incumbent firm than by an entrant (because of the former's larger sales in the market); however, barriers that raise variable costs would fall more evenly on both firms. Planning policies and regulations can also constitute a barrier to potential entrants into a market to the advantage of incumbent firms. IPRs such as patents, trademarks and copyrights give the owners of such rights exclusive use of them and the ability to control their use by others, though the period of such exclusivity or control varies according to the nature of the property right. IPRs can act as barriers to entry when access to the rights owned by an incumbent may be vital for entry. 226. Quality, environmental, and health and safety standards that apply to all the firms in a market may on occasions adversely affect entry despite making no formal distinction between incumbents and new entrants. For example, they might favour the technology the incumbent owns and therefore raise the costs of a new entrant. Some regulations may give advantage to incumbents by not requiring them to comply with the same standards as new entrants.125 ## Assessing The Impact Of Entry Barriers 227. To test a theory of harm based on the effects on competition of any barriers to entry, the CC has to assess the impact that the entry barriers identified have had, are having or may have in the future. ## Current Competitive Climate 228. The CC considers how the competitive climate within a market affects the decisions of individual firms to enter or invest in that market, taking into account the advantages of established sellers. This entails examining the factors influencing entry decisions, while recognizing that these will be accorded different weights by different firms. 229. The post-entry profitability that a firm can expect—and therefore the degree of attractiveness to that firm of entering a market—is affected, not only by the extent to which entry costs are sunk (see paragraph 211) but also by its assessment of the likely intensity of competition post-entry. The expectation of a tough competitive regime post-entry leads entrants to anticipate lower prices, reducing the profitability of entry and making it less attractive. If, on the other hand, growth in demand is likely to be large and rapid, barriers to entry are less likely to have a lasting effect. Similarly, in markets characterized by innovation, product cycles are likely to be shorter and barriers less likely to have a lasting effect. Entry decisions are often influenced by a range of other factors, including payback periods, the effect on other business segments (eg possible cannibalization, ie creation of competition to a firm's existing business), and the risk of the project. The risk will in turn be affected by various factors influencing the certainty or otherwise of forecast future cash flows: for example, the management team's level of experience, the predictability of demand, and likely competitor reactions. 230. In assessing the factors influencing entry decisions, the CC therefore may consider: - the costs involved in entry and in operating at the minimum efficient scale necessary to achieve a reasonably competitive level of costs; - the likelihood of entry within a timescale that would bear on the incentives and decisions of the existing firms in the market; - the cost of exiting the market; and - the likely response to entry by incumbent firms. ## Past And Prospective Entry 231. Evidence of persistent profits above the competitive level within the industry or among large incumbents could suggest there may be entry barriers in the market. But such evidence is neither necessary nor sufficient. Conversely, data showing that incumbents consistently fail to earn high profits may be consistent with low entry barriers, but it does not prove that barriers are low and that competition is working dynamically (see paragraph 125). 232. The CC will examine the history of entry and evidence of planned entry. This assessment will include the extent to which past entrants and smaller firms have successfully gained market share (see paragraphs 100 and 101) and, more generally, the cost of gaining a significant share of the market. 233. In considering historical evidence, the CC may consider: survival rates, ie how long any entrants traded in the market; the effects that entry or expansion had on competition in the market, in particular whether past entry or expansion modified the pattern of behaviour and competition; and if so, whether this would be relevant for the present analysis. The CC may also consider the price effects, if any, from past episodes of entry, the viability of the entrant and its experience in trying to gain market share. 234. Although evidence of past entry (or the lack of it) can be helpful in assessing the significance of entry barriers in a market, previous episodes of entry do not necessarily prove that it was easy, that it was competitively significant, that it is likely to take place again, or that the possibility of entry is imposing a competitive constraint (see also paragraph 175). Moreover, current potential entrants may not face the same market conditions that previous entrants faced. Similarly, although an absence of actual or meaningful entry in the past may indicate the presence of entry barriers, it does not necessarily prove that significant entry is unlikely in the future. ## The Positive Effects Of A Barrier 235. In some circumstances barriers to entry may have a positive impact: - Entry barriers may sometimes increase incentives to innovate. While new entrants can often lead to innovative competition, the effect of entry barriers, or the prospect of creating them, may also increase the incentives for incumbents to create new products and services. IPRs, for example, provide an incentive to innovate because they prevent rivals 'free-riding'126 on other firms' innovations. Given these conflicting factors, the CC will assess the incentives of incumbents relative to those of potential entrants to engage in innovative activities in the presence of entry barriers. The CC will also sometimes assess whether or not potential technological change and innovation could affect the nature and effectiveness of current barriers to entry. - Some regulations which restrict entry may achieve important social goals outside the scope of competition policy (see paragraphs 224 and 226). Safety regulations, for example, may make it more difficult to switch suppliers of domestic liquified gas in the UK, but the CC recognized in its investigation of the LPG market that regulation in that industry was necessary.127 236. Such positive impacts could be taken into account at different stages of an investigation. First, they may be considered as part of the competitive assessment, for example, a restriction on short-run competition might be tolerated so as to preserve incentives to compete in longer-term ways. Secondly, they may be considered during the remedies process as RCBs (see paragraphs 355 to 366). 3. Coordinated conduct by firms 237. The successful adoption by rival firms of a coordinated course of action is a third way in which competition in a market may be harmed to the detriment of customers. ## Forms Of Coordination 238. Coordination typically involves repeated interaction, aimed at increasing or protecting profits, between firms in the market. But coordination can take different forms across a wide spectrum of behaviour. 239. At one end of the spectrum, direct and unambiguous communication among competitors can lead to explicit agreements to fix prices, share markets or allocate customers. At the other end of the spectrum, when a market is sufficiently stable and rival firms interact repeatedly they may be able to anticipate each other's future actions, enabling them tacitly to establish a coordinated course of action without communicating directly or sharing information. Coordination does not have to be 'perfect' at all times to affect a market. For example, it may be intermittent; ie periods of coordination may be interspersed with periods of greater competition when not all competitors see it in their interest to cooperate. 240. The sole focus of any market investigation is upon the effects on competition of possible features of the market (whether through coordinated conduct or otherwise) and it is not the CC's role to ascertain whether one or more parties have been acting unlawfully. While enforcement action on some cases of coordinated behaviour may fall within Article 101 of the TFEU or Chapter 1 of CA98,128 the CC may investigate all forms of coordination. Any form of coordination has the potential to reduce strategic uncertainty among competitors to the detriment of their customers and, depending on the degree, may thereby result in an AEC. ## Impact Of Coordinated Conduct 241. Coordination may have an impact on any dimension of competition, including price and output levels, the scope of firms' geographic operations, investment or innovation. 242. Not all cooperation will be harmful. It may sometimes also bring about procompetitive effects, which benefit customers. For example: - In some financial markets, credit providers and insurers routinely share certain data (eg about customers' repayment or claim history) that facilitates the efficient operation of those markets. The CC found that the absence of such data sharing was a feature harming competition in the market for home credit and required lenders above a certain size to provide credit reference agencies with full data on the payment records of customers.129 130 - In its investigation into local bus markets, the CC found that effective multioperator ticketing schemes could reduce barriers to entry and expansion associated with network effects and made various recommendations to facilitate the development of such schemes. 243. However, in many cases coordination between rivals has harmful effects on both competition and customers. Prices may be higher than they would have been if firms had taken unilateral decisions. In other cases, coordination may involve limiting production or innovation. Firms may divide up the market between them, for example by geographic area or customer characteristics, or by allocating contracts between themselves. Joint action may be taken to foreclose access to markets, inputs or customers. In these ways, coordination between rivals can worsen the terms on which products are offered to customers, reduce customer choice and hold back efficiency and innovation. ## Assessing Potential Concerns About Coordination 244. In assessing whether coordination gives rise to an AEC, the CC will examine the evidence of the behaviour of firms in the market, structural characteristics of the market and market outcomes. In doing so, the CC considers whether market conditions are conducive to coordination, seeks to understand the way in which the firms in the market operate and comes to a view on whether the observed outcomes are best explained by coordinated or non-coordinated behaviour.131 ## Observed Market Outcomes 245. The CC will consider whether observed market outcomes may suggest coordinated behaviour. A range of market outcomes may be relevant to this assessment. Some examples are given below (paragraphs 246 to 248). 246. Certain forms of pricing behaviour can be possible outcomes of coordination. For example, information on demand elasticities (see paragraph 179) and variable profit margins (sales revenue minus costs of sales) may suggest that prices are higher than would be expected if firms were acting unilaterally since each firm would stand to profit by undercutting the current market price. 247. It has also been noted (see paragraph 119) that a situation where levels of profitability have remained high and stable over time across several incumbent firms could indicate coordinated behaviour. 248. The absence of a provider serving an area where there are potential customers that it would be economic to supply may also be an indication of coordination by firms over the scope of geographic operations. 249. The CC will generally look at a range of market outcomes in combination. A single outcome looked at in isolation may often be consistent with both coordinated and non-coordinated behaviour. For example, whilst coordination may result in price parallelism (see paragraph 108(b)), intense price competition often also does so. Non-coordinated behaviour may be the more likely explanation if parallel pricing is explained by common movements in costs, and the CC will therefore consider information about changes in variable costs alongside price movements. ## Market Conditions And Characteristics 250. Three conditions are necessary for coordination to be sustainable in a market: (a) Firms need to be able to reach an understanding and monitor the terms of coordination. Where there is no explicit agreement, firms need to have sufficient awareness of each other and be able to anticipate each other's reactions so as to identify a mutually beneficial outcome. (b) Coordination needs to be internally sustainable among the coordinating group— ie firms have to find it in their individual interests to adhere to the coordinated outcome; the firms must lack an incentive, or have a positive disincentive, to compete because they appreciate how each other will react. However, coordination does not need to be perfect or continuous to fulfil this criterion (see paragraph 239). (c) Coordination also needs to be externally sustainable, in that coordination is unlikely to be undermined by competition from outside the coordinating group or from the reactions of customers. 251. An important part of the CC's investigation is therefore to establish whether or not the specific characteristics of the market—structural characteristics and the way firms behave—create the conditions in which coordination can arise and be sustained.132 These characteristics are described below. Which of them the CC will consider as potentially facilitating coordination will depend on the facts of the individual case. (A) Structural characteristics of the market 252. Structural characteristics that may help firms reach an understanding and monitor terms of coordination, include: (a) A non-complex and stable economic environment can help firms to reach an understanding on the terms of coordination. For example: where markets are concentrated, firms are more likely to be aware of the behaviour of individual competitors; it is often easier to coordinate on a price when demand and supply conditions are relatively stable than when they are continually changing. (b) Simple and relatively undifferentiated products are more easily subject to the coordinated setting of prices than situations in which each firm's offering is different from the offerings of its rivals.133 (c) Customers with easily identifiable characteristics help firms coordinate by way of market segmentation (based on geography or customer type or simply on customers who typically buy from one supplier). (d) Firms that are relatively *symmetric*, for example in terms of cost structures, market shares or spare capacity levels, may more easily respond to incentives to reach an understanding with each other.134 (e) Firms with cross-shareholdings, participating in joint ventures with each other or in reciprocal supplier/buyer relationships may also find it easier to reach an understanding. 253. Other structural characteristics that may help firms reach an understanding and monitor terms include the need for firms to make a long-term market commitment, and the existence of institutions (eg trade associations) or regulations that may facilitate the sharing of information. 254. The following market characteristics can help increase the *internal sustainability* of coordination: (a) A *concentrated market* is the foremost factor in helping to sustain coordination internally. It allows deviations to be spotted quickly. (In a less concentrated market with many companies coordinating, deviation may be more likely because a larger market share can be gained through undercutting.) (b) Market transparency also allows coordinating firms to monitor whether one or more of them are deviating from a coordinated outcome. The way transactions are conducted will often determine the degree of transparency in a market; price transparency will, for example, be higher on a public exchange, than when transactions are negotiated confidentially and bilaterally. Nonetheless, even where price transparency is limited, other aspects of transparency (eg of sales or production volumes or customer relationships) may help increase internal sustainability. (c) Transparency in the market also affects the speed, and hence effectiveness, of any deterrent mechanism used against a deviating firm or strengthens firms' ability to anticipate each other's conduct. (d) Factors that make it easier to respond quickly to deviation from a coordinated outcome may make coordination easier to sustain. For example, firms could use excess capacity as a credible threat against deviation. Likewise a response to a perceived deviation from a coordinated outcome need not necessarily take place in the same market as the deviation; if coordinating firms have commercial interactions in several markets, these may offer various ways of responding to deviations, such as cancellation of joint ventures or selling shares in jointlyowned companies. 255. The *external sustainability* of coordination may be affected by the following characteristics: (a) Barriers to entry or expansion facilitate coordination. If barriers to entry or expansion are low, the threat of entry or expansion by non-coordinating competitors will tend to undermine coordination. (b) The *number and size* of the non-coordinating (or fringe135 ) rivals, their *cost* and profit margins and, critically, their scope to *expand output* in relation to their current levels and to the output of the coordinating firms will determine the extent to which non-coordinating firms act as a competitive constraint. (c) If a firm has the capacity to take significant share from any group of firms that tried to coordinate without its participation but also has substantially different incentives from those of the coordinating group, it can undermine a coordination strategy. (Such a firm is sometimes referred to as 'a maverick'.)136 (d) Countervailing buyer power of customers (see paragraph 176) can similarly undermine the stability of coordination. For example, a large buyer may do so by concentrating its purchases on one supplier or by offering long-term contracts and tempting one of the coordinating firms to break ranks to gain substantial new business. ## (B) Practices Of Firms Operating In The Market 256. In addition to investigating structural characteristics of the market that may be conducive to coordination and considering evidence of outcomes that might be indicative of coordinated conduct, the CC will look at whether would-be competitors have taken any actions137 to reach, sustain or enhance coordination. Such actions may involve exchanges of information or specific types of arrangements. ## - Availability Of Information 257. The ease with which firms can obtain information about their competitors tends to facilitate coordination. Readily available information or exchanges of information increase transparency between firms and help firms interpret the choices their competitors have made. Information availability can facilitate coordination by: (a) generating mutually consistent expectations among rival firms regarding their conduct and beliefs, making it easier for firms to reach an understanding on the terms of coordination (paragraph 250(a)); (b) giving an indication of rivals' past and present conduct and enabling rival firms to monitor deviations and, potentially, to retaliate, thereby increasing internal sustainability of coordination (paragraph 250(b)); and (c) increasing transparency making it easier for coordinating companies to monitor where and when other companies are trying to enter the market, allowing the coordinating companies to target the new entrant. This can increase the external sustainability of coordination (paragraph 250(c)). 258. The means by which companies may obtain or exchange information, other than by the many forms of direct communication, include most-favoured customer clauses (MFCs, see paragraphs 261 and 272), voluntary publication of information, price announcements, or information shared—even anonymously—through trade associations. Cross-directorships, joint ventures, supplier/buyer relationships and similar arrangements may also make monitoring and retaliation easier. 259. Less obvious means and practices may also increase the transparency or predictability of the environment in which firms operate. These may include the adoption of rules of conduct, ethics codes, product standardization, regulatory disclosures, joint marketing or buying agreements, price computation manuals and R&D joint ventures. Such practices may sometimes be justifiable on efficiency or customer-benefit grounds, but they could also create market conditions favourable for coordination. 260. These Guidelines cannot be prescriptive about the type of information that may be associated with coordinated conduct. The likely effects of the availability of particular items of information on competition are analysed by the CC on a case-by-case basis. The assessment compares the likely effect of the information flow with the competitive situation that would prevail in its absence. - Specific arrangements made by firms 261. The specific types of arrangements firms make, which, although sometimes benign from a competition viewpoint, can sometimes facilitate coordination, include: - *Best price policies* (or low-price guarantee);138 they can increase transparency, facilitating consensus and the detection and punishment of cheating. 139 - *Most favoured customer (MFC) clauses*; although generally benign, these provisions can in some circumstances deter competitive price cutting, reduce the incentive to deviate from established terms of coordination, and deter a firm from offering discounts to its smaller customers. 140 - Minimum advertised price agreements can be conducive to coordination at both retail and manufacturing levels since they can control the pricing strategies of several competing retailers and are visible to competing manufacturers. 141 - *Resale price maintenance (RPM*) 17 can be used to facilitate coordination between suppliers and retailers, making it easier to detect whether a supplier deviates from a coordinated price; strong or well-organized distributors may be able to use RPM to influence one or more suppliers to fix their resale price above the competitive price. Instances of RPM may sometimes fall to CA98 and TFEU investigation (see paragraph ). However, depending on the circumstances, manufacturers can use RPM to promote effective competition by preventing 'free-riding'142 at the distribution level. ## 4. Vertical Relationships 262. Market outcomes may sometimes be the result of vertical integration or other vertical arrangements within the market (collectively known as 'vertical relationships'). - 'Vertical integration' means that activities at upstream and downstream levels of the supply chain have been brought under common ownership and control (see paragraph 50). - 'Vertical arrangements' fall short of vertical integration and may involve agreed pricing schemes or other contractual provisions between companies at different levels of the supply chain. 263. Vertical relationships will often have been established when upstream and downstream firms in a trading relationship (see paragraph 50) consider that it is more efficient and economical for transactions to be organized within firms.143 Arm's length supply contracts between such firms may be imprecise, incomplete and/or difficult to enforce and in practice may give one of the contracting firms leverage over the other. To avoid this risk one or other of the firms may decide to bring the transaction 'in house', either through internal growth or external acquisition. 271 to 294. 264. Alternatively, firms may make vertical arrangements with each other, either via legally enforceable contracts or commitments by each firm not to behave opportunistically against the interests of the other. By restricting each other's actions, vertical arrangements may give both parties a mutual incentive to invest in their relationship. A wide variety of vertical arrangements are employed by firms. Among the most prominent are exclusive purchasing, tying and bundling, franchising, selective distribution systems and pricing arrangements. Some examples of vertical arrangements, and the CC's approach to assessing their effects, are discussed in paragraphs ## Impacts Of Vertical Relationships 265. Vertical relationships often have beneficial effects. They can improve the coordination of activities at different stages of the supply chain and deliver savings in transaction and inventory costs.144 With vertical integration, the benefits are achieved by bringing 'in-house' activities which would otherwise be carried out in separatelyowned businesses.145 The benefits of other vertical arrangements flow from a closer alignment of the incentives of firms within a supply chain (eg the supplier and its distributor), towards the achievement of complementary objectives. Vertical relationships may also help to resolve the 'free-rider' problem146 in markets where suppliers require their distributors to incur certain costs if advice and other pre-sale services are to be provided in a sustained way. 266. Since vertical relationships involve complementary products, services or activities, each firm would like the other to lower the price of its product. Such a relationship can therefore have the effect of lowering prices that would be charged to customers if the firms acted independently and in this way can sometimes benefit customers. 267. However, despite their potential to enhance efficiency and consumer welfare, vertical relationships can also sometimes lead to an AEC in a market, particularly by allowing the firms to: (a) foreclose rivals' access to inputs and customers; and/or (b) otherwise have a dampening effect on competition. ## (A) Foreclosure 268. For a vertically related firm, foreclosure may be achieved by practices that restrict access to essential inputs or raise rivals' costs, or limit rivals' ability to acquire sufficient customers to benefit from economies of scale, learning effects147 and/or network effects. 269. Foreclosure can be total (where rivals are forced to exit from the market or are prevented from entering) or partial (where rivals or potential entrants—are materially disadvantaged and consequently compete less effectively). 270. Foreclosure of access to key inputs ('input foreclosure') may lead to a reduced competitive constraint on a vertically related firm. When deciding whether to supply its competitors downstream with key inputs, a vertically integrated firm may take into account how these sales would affect the profits of its own downstream division. If it has significant market power in the upstream market, the firm may have an incentive to refuse access to the input or to raise its price, and consequently increase the costs of competing downstream firms. By being subjected to higher input prices—of which an extreme form is a 'margin squeeze'148 —downstream competitors may be unable to compete effectively. As a result of such foreclosure effects a vertically integrated firm may be able to maintain high prices and/or increase the prices charged to customers relative to the prices obtained in the absence of vertical integration. ## (B) Dampened Competition 271. Since the rationale for vertical relationships is often unconnected to competition issues (see paragraph 263), a widespread network of overlapping vertical relationships may develop within an industry. While such arrangements may address market failures, they can have far-reaching effects on the operational structure of the upstream and downstream markets, reducing the incentives on firms to compete vigorously against each other and possibly leading to an increased likelihood of coordinated conduct by firms at the same level of the supply chain and to a greater incidence of entry barriers. 272. Pricing relationships especially, notably MFC and RPM arrangements (see section on coordinated conduct, paragraph 261) may sometimes harm competition in some industries because a commitment to apparently less vigorous conduct may lead rivals to see that their best interest lies in allowing prices to rise. Such practices have greatest impact when the arrangements have been adopted by most or all of the firms in an industry. ## Assessment Of Vertical Relationships 273. In reaching a judgement on whether a particular vertical relationship has an adverse effect on competition, the CC will evaluate its overall impact on competition, taking into account rivalry-enhancing, as well as adverse, effects. This will normally require an assessment of the impact of the vertical relationship on rivalry at different stages of the supply chain.149 150 ). 274. For vertical relationships to result in foreclosure of rivals, the firms involved must have significant market power in one or more markets along the supply chain. They will also need to have both the ability and an incentive to seek to foreclose rivals (this will not necessarily be the case, even if the firms enjoy significant market power 275. In conducting its assessment of the overall impact of vertical relationships on competition, the CC will look at a variety of evidence. Economic modelling may be used to test whether or not different vertical relationships have a harmful effect on the evolution of competition in a market. The CC will also assess the conduct and strategic interactions of relevant market participants. This may involve comparing relevant industry characteristics and firm behaviour over time or across geographical locations, making comparisons with other similar sectors or examining and drawing inferences from any observed natural experiment, where available. 276. Analysis of profitability and financial data can help provide an insight into whether foreclosure would be a profitable strategy. 277. The profitability of input foreclosure will depend on: (a) the integrated firm's ability to refuse to supply or to increase the price of an essential input, or limit access to an asset, facility or platform; (b) the competitiveness of upstream and downstream markets (lower competition leads to higher profitability); (c) the size of any cost asymmetry151 it can create on the downstream market (higher cost asymmetries lead to higher profitability); and (d) counter-measures by rivals such as vertical integration, or other factors (such as switching costs) which could reduce the profitability of foreclosure. 278. The following paragraphs survey some of the more prominent among the wide range of vertical arrangements and discuss how the CC approaches an assessment of their effects on competition. Some arrangements, such as exclusive purchasing arrangements, tying and bundling and RPM can sometimes come within the jurisdiction of the TFEU and CA98 (see paragraph 17). ## Exclusive Purchasing Obligations 279. Exclusive purchasing obligations may effectively require the customer to purchase all or a significant part of its requirements from a particular upstream supplier.152 If the customers make up a large part of the market, this has the effect of foreclosing the upstream supplier's competitors from the market. Similar foreclosure effects may derive from conditional rebates and other inducements that levy switching costs on any buyer seeking to switch from an incumbent. Exclusive purchasing may thus be used in some situations as a substitute for vertical integration and have similar effects as a refusal to deal. 280. Foreclosure may lead to an AEC where, without the exclusive purchasing obligations, an important competitive constraint could be exercised by competitors that either were not present in the market at the time the obligations were concluded, or that were not in a position to compete for the full supply of the customers. 281. In general, the longer the duration of the obligation, the stronger the likely foreclosure effect, in particular if new entrants are affected. Foreclosure of this type will be more likely if the exclusive purchasing obligation has been tied selectively to buyers of particular relevance to new entrants. In such cases an anticompetitive foreclosure effect may result even though the market share involved is modest. 282. The existence of exclusive purchasing arrangements in a market does not necessarily suggest that competition is harmed. For example, when an upstream supplier faces significant inter-brand competition,153 it may need to compensate buyers, in whole or in part, for the loss in choice resulting from the possible foreclosure. Such compensation could, for instance, take the form of lower prices or other benefits. 283. Moreover, competitors may have counter-strategies at their disposal allowing them to protect themselves against exclusive purchasing strategies and to prevent any harm to competition. Such counter-strategies could, for instance, include: (a) concentrating their sales on certain customers; (b) building up stronger 'ex-ante' competition for the customers, as foreclosure is less likely if customers, before entering into exclusive purchasing obligations, have had access to several alternative competitive offers; and (c) ensuring new entry in the downstream market, either by sponsoring entry or by integrating vertically. ## Exclusive Supply Obligations 284. Exclusive supply obligations—by which a supplier is obliged to sell exclusively or to a large extent to an incumbent downstream firm—may also be used to try to foreclose the downstream market to new entry if an incumbent downstream firm has sufficient market power to induce all input suppliers to make such arrangements. Exclusive supply obligations may be found to lead to an AEC if they have tied most of the efficient input suppliers and rival buyers have been unable to find alternative sources of input supply. The foreclosure effects would be likely to be stronger if there were significant scale economies or network effects in the downstream market (see paragraph 179) or if there were significant entry barriers for input suppliers. 285. Exclusive supply incentives may have similar effects to exclusive supply obligations. Under such arrangements, for example, an incumbent firm with significant buyer power offers to pay a higher price if the supplier sells it a higher percentage of its output, or the supplier may be required to pay a lump sum so as to get its goods on to the shelves of the incumbent buyer. Tying and bundling 286. Tying and bundling are common commercial practices, frequently having no anticompetitive consequences but with the potential sometimes to foreclose markets and harm customers. 287. Tying occurs when the supplier makes the sale of one product (the tying product) conditional upon the purchase of another distinct product (the tied product) from the supplier or a firm designated by that supplier. Bundling relates to situations where a package of two or more goods is offered in fixed proportions.154 Tying and bundling may also be achieved in indirect ways, eg by offering discounts or rebates to customers using both products or limiting guarantees to customers using only one of the products. 288. Tying and bundling can benefit customers by enabling firms to provide better products or offerings in cost-effective ways. They can lead to significant savings in production, distribution and transaction costs. 289. However, a firm with significant market power in the tying market can harm customers through tying by foreclosing the tied market and, indirectly, the tying market. In the case of the tied market, competition may be harmed if the tying has led to less competition for customers buying the tied good but not the tying good; if there are not enough of these customers to sustain competitors of the tying firm in the tied market, these customers may face higher prices. In the tying market such foreclosure may constrain market entry by rivals, which would have been likely in the absence of the tie. Similar effects may arise from pure and mixed bundling. (Paragraph 220 discusses tying and bundling as a potential barrier to entry and expansion.) 290. The factors the CC considers in assessing the extent of the foreclosure effect of tying and bundling in a market, include: the nature of the restriction applied, eg whether tying or bundling, and its effects on the choices of customers and the commercial strategies of firms; the tied percentage of total sales on the tied market; the overall strength of the tying firm on both the tying and the tied markets; the identity of the tied customers; the level of sales of the tied product to customers not buying the tying product and, in the case of bundling, the extent to which a firm is bundling goods, and whether the items within the bundle may also be purchased separately. In considering whether foreclosure of the tying market had deterred market entry, the CC may examine previous attempts to enter it. ## Aftermarket Arrangements 291. In those aftermarkets where secondary products can be used with one brand of primary product but not easily with another brand (although the primary products may be substitutable), the supplier of the primary product may reserve the secondary product for itself by excluding competitors, for example through tying or a refusal to deal (eg to supply necessary information, licences, IPRs or spare parts). In other cases, the supplier of the primary product may have a point-of-sale advantage in relation to the secondary product that restricts the ability of other potential suppliers of the secondary product to serve its customers.155 292. In assessing the effects of aftermarket arrangements, the CC will typically first consider the nature of the relationship between the primary and secondary markets. This may constrain the extent of, or in some cases remove, any market power enjoyed in the secondary market by the supplier of the primary product. In particular, if the primary market is competitive and if customers anticipate the likely cost of secondary products when making decisions about which primary product to buy, competition in the primary market may constrain suppliers' ability to raise prices of the secondary product. Competition in the primary market may in this way ensure that the overall price of the 'bundle' of goods and services comprising the primary product and the secondary product(s) is set at a competitive level. 293. The extent to which competition in the primary market may constrain market power in the secondary market is determined by: (a) The amount of information available to customers, together with the use customers make of this information when buying a primary product. These are important factors in assessing the extent to which customers calculate the overall cost of the bundle over the expected life cycle of the primary product. For this competitive constraint from the primary market to function effectively, a sufficient number of customers must engage in life-cycle cost calculations, and the supplier(s) concerned must not be able to discriminate between customers that make such calculations and those that do not. (b) Whether the suppliers, even if customers have not based their choice on accurate life-cycle calculations, make their own assessment of the profitability of a customer relationship over the life cycle of a product and compete vigorously in the primary market so as to enjoy profits on subsequent aftermarket sales.156 The CC may consider the extent to which customers benefit from lower prices of the primary product as part of its assessment of RCBs (see paragraphs to 355 366).157 ## Wider Competition-Dampening Effects 294. As explained (see paragraphs 271 and 272) in some circumstances vertical relationships can have far-reaching effects on the operational structure of a market. These potential effects, for example the possibilities of coordination or entry barriers arising from competition-dampening relationships are assessed in the ways described in the relevant sections on coordinated conduct and entry barriers. 5. Weak customer response 295. Competition (as emphasized in Part 1, paragraph 15) may be threatened if customers respond weakly to competitive offers. A weakness of customer response may be variously caused by customers' behaviour, actions by suppliers or a structural feature of the market (for example, affecting the availability of information). A market investigation is well placed among competition policy instruments to analyse and remedy undesirable patterns of customer responses which result in a lack of competition.158 ## Impacts And Assessment Of Weak Customer Response 296. To drive effective competition customers need to be both willing and able to: access information about the various offers available in the market; assess these offers to identify the good or service that provides the best value for them; and act on this assessment by switching to purchasing the good or service from their preferred supplier. 297. Theories of harm that competition is adversely affected by weak customer response are therefore generally examined in relation to these three issues so as to establish what may be restricting customers from exercising effective choice. The following sections of the Guidelines examine barriers to: (a) accessing information; (b) identifying best value offers; and (c) switching suppliers. ## (A) Barriers To Accessing Information 298. When customers face significant impediments or costs in their search for—and comparison of—alternatives, sellers may be able to set prices with only limited regard to competition. 299. Firms can enjoy some market power (see paragraph 9) if customers cannot easily or effectively compare their products with others on offer, because of the difficulty or cost (including the opportunity cost of customers' time) of finding better deals.159 300. Where it is difficult to obtain information, or where the cost of obtaining information is high, customers may not search the market but simply choose a firm randomly; firms may respond by charging a high price to these customers. Search costs are likely to be substantial in cases where the information that could possibly affect purchasing decisions is relatively complex, or difficult to obtain or process. 301. Firms may be able to charge high prices even where some customers search for information but a significant number of less well-informed customers remain; a seller's profit foregone by losing informed customers who buy elsewhere may be more than offset by the higher profits accruing from less well-informed customers who do not shop around.160 An increase in the proportion of informed customers will generally increase the level of effective competition in a market. 302. Prices in the market tend to increase with the cost of acquiring information (although there is no general formulation for the relationship between prices and customers' search costs). This is because the higher the search costs, the lower the net gain for customers from searching for a lower price and the higher the degree of market power that firms can exploit. 303. Firms may sometimes engage in practices that increase search costs so as to obtain market power (or fail to engage in practices that would reduce search costs). They may do so, for example, by: (a) charging different prices for the same good at various locations or under different brand names, making it difficult to find the low-priced brand; (b) not clearly displaying prices or referring to some prices (eg special offers) which are not necessarily available to all customers; and (c) failing to make available all the product information needed by customers to make an informed choice, in particular of one-off purchases.161 304. Other reasons buyers—in particular end-consumers—may have difficulty acquiring knowledge of substitutes or of the quality and prices of goods on offer might include: (a) information may vary in availability or may become dated; (b) customers' knowledge about their requirements may be imprecise; (c) customers may have limited capabilities to search for products and compare alternatives, for example they can remember and readily recall only a limited amount of information; and (d) customers may be sensitive or embarrassed about the product for which they are searching. 305. Advertising and other freely available information on products (eg online price comparison sites or organizations conducting product reviews) might be expected to reduce search costs. However, their influence may be limited in this respect, for example because: (a) Advertising, while a 'free' resource reducing buyers' search costs to some degree, may not tell customers everything that they want or need to know about a product. (b) Third party providers of information may have a legitimate commercial interest in protecting the IPRs (see paragraph 211) to the information they collect and distribute—for example, to prevent its use to publicize only the 'bottom' line (eg which brand is most or least reliable overall), or to benefit those who have not produced or paid for information.162 (c) The large fixed costs typically associated with the creation of information, and the small marginal costs of distributing it, may prevent fully efficient pricing and may give sellers an incentive to limit the information they provide. ## (B) Barriers To Identifying Best Value Offers 306. Even if customers are able to access several offers, their assessment of those offers may be handicapped by two main factors: (a) the susceptibility of some customers to behavioural biases and the potential for exploitation of these biases by providers (see paragraphs 307 to 310); and (b) the potential for asymmetries of information to exist between suppliers and their customers (see paragraphs 311 to 315). ## Behavioural Bias 307. There are many explanations of the biases customers apply when making purchasing decisions. The main biases identified in the literature on the subject163 are: (a) Processing power biases including: choice overload (faced with too many choices, customers have difficulties making a purchasing decision); representational biases (customers use visible value as a reliable indicator of hidden value); and rules of thumb (for example, customers imitate what other customers do rather than make their own decisions). (b) Framing biases including: relative utility (a customer's choice is affected by reference points such as past actions); default biases (customers adopt the default option); and placement biases (customers' choices depend on where goods are placed on a list—for example, they may tend to choose the first). (c) Time inconsistency biases including: projection bias (customers expect that they will feel the same tomorrow as they do today); overoptimism (customers overestimate how much they will use a good, or underestimate how much it will cost them); and hyperbolic discount biases (customers value a reward today disproportionately more than one tomorrow). (d) Loss aversion biases including endowment biases (customers value something more once they have owned it than before they own it). 308. In practice it can be difficult to predict how a customer will react in a particular situation. Empirical evidence is normally required to identify behavioural biases and any possible impact on competition in particular markets. The persistence of a bias is also hard to predict. Customers can learn from their biases and become more sophisticated, for example in markets where they make frequent purchases (or can benefit from the learning of others via word of mouth).164 Advisers, intermediaries, consumer organizations and the media can also act as catalysts in improving customer decision-making, where there are customer biases.165 309. As well as influencing their purchasing decisions, the behavioural biases of customers can have a bearing on suppliers' behaviour. Where such biases exist, firms can act to exploit them at every stage in the decision-making process. They can potentially increase their profits by playing to these biases in certain ways, for example, unilaterally or jointly restricting the information provided to customers or by failing to highlight the add-on costs of a service. 310. In some markets there will be a proportion of 'active' customers who recognize their biases and correct for them and a proportion of more 'passive' customers who do not do so. Competition in these markets will work most effectively where there is a high proportion of 'active' customers and it is difficult for suppliers to discriminate between 'active' and 'passive' customers. ## Information Asymmetries 311. Information asymmetries between suppliers and customers might have adverse effects on competition, particularly in markets for goods or services where customers are not able to gauge the quality of a service when acquiring it. 312. Buyers may not know, for example, how quality varies across brands. Markets where customers may be unsure about quality include those for professional services, used goods and complex mechanical or electronic products. When, as a result of information asymmetries, customers are unable to form an accurate assessment of product quality (eg if they consistently underestimate the probability of product failure), a market may operate inefficiently. Imperfect information about quality can be a particularly severe problem for infrequently purchased goods or goods the quality of which cannot be verified even after purchase—so-called 'credence' goods. ## - Potential Adverse Effects On Competition 313. In extreme cases, asymmetric information about quality may lead to only the lowest quality product being offered, effectively meaning that a true market may not exist. This could arise where sellers of low-quality products are able to make their products appear indistinguishable from higher-quality products, and consequently sellers of the higher-quality products are unable to convince customers of their products' worth. In this situation, customers are only willing to pay the price of the average quality product, which is not enough to cover the cost of the higher quality products, leading to these products not being supplied. Even if information asymmetries do not lead to all higher-quality products being forced out of the market, quality levels are lower than they would be in the absence of any asymmetry. 314. A related issue (the so called *'principal-agent'* problem) arises where a provider (the agent) acts on behalf of another party (the principal), thereby providing a service to it. If the agent has better information than the principal about how well it is providing the service, the principal may be prevented from exercising effective choice. Moreover, where the two parties' interests are not aligned, the agent may act against the interests of the principal if information asymmetries allow it to do so undetected by the principal.166 315. These effects of asymmetric information are generally commensurate with the degree of asymmetry: the greater the asymmetry of information, the greater the effect. However, the potential effects of asymmetric information may be mitigated in various ways: (a) The Government, consumer groups, industry groups or others may provide information in the form of standards (defining a metric, or scale, for evaluating a particular product) and certification (that a particular product has been found to meet a standard)—for example, relating to the licensing of new drugs, car safety regulations and rules for financial fund managers. (b) Liability laws may serve the same function as explicit warranties, forcing the manufacturer to make good any defective products. (c) Professional and other bodies can regulate entry into, and ongoing participation in, the profession and require that practitioners obtain certain qualifications, thus guaranteeing quality of service to some degree (see also discussion of entry barriers, paragraphs 223 and 224). (d) A disinterested expert may be able to provide customers with reliable information, for example, a mechanic in the case of a used car. (e) Warranties or guarantees may eliminate problems due to limited information or act as a signal of the item's quality at the time of purchase, for example 'satisfaction guarantees' might be offered by holiday providers. ## (C) Barriers To Switching Suppliers 316. Switching from one supplier or provider to another, so as to respond to attractive offers, may be made difficult for customers by the costs of doing so. 317. In investigating switching costs, the CC recognizes that they can sometimes have both detrimental and beneficial effects on different groups of customers. (a) On the one hand, switching costs allow firms potentially to charge high prices to 'captive' customers. Even if the firm is unable to discriminate between 'captive' and new customers, switching costs may enable it to charge higher prices in what would in other respects be a competitive market. (b) On the other hand, the presence of switching costs may benefit some customers by intensifying the competition for new customers, particularly if there is scope to charge different prices to new as opposed to existing customers. In other situations, some limited constraint on switching (eg for a fixed period after signing a contract) may enable providers to recoup upfront costs of supplying a customer and may in that way facilitate customer-specific investments (eg in the equipment needed to receive a particular product). 318. Among the causes of high switching costs the CC may consider are: (a) Lack of information on the part of the customer about alternative products; in some markets the customer may be unaware of the existence of competing products, possibly because of a lack of access to information or high search costs (see paragraph 300 above). The latter in particular magnify switching costs.167 168 (b) Inconvenience and administrative obstacles: the CC's report on banking services to small and medium-sized enterprises identified the 'hassle in moving direct debits, standing orders etc and a fear that crucial payments could be missed whilst a switch was in progress' as a factor discouraging switching between banks. (c) The presence of network effects (see paragraph 179 and footnote 107), which gives rise to collective switching costs, locking customers into existing standards and the firms that control them. (d) If customers have made a large investment in a piece of equipment or in productspecific skills they may be deterred from switching if it involves a further substantial investment;169 the CC found that such high switching costs were features harming competition in the markets for domestic LPG.170 171 (e) Contractual terms (eg low early settlement rebates ) or marketing devices, such as loyalty cards, and negative advertising can have the effect of increasing switching costs or influencing switching decisions. ## Part 3: Section 4—Concluding The Aec Test 319. Having considered evidence of all kinds, the CC comes to a rounded judgement on what may be causing any adverse effects on competition. This judgement entails the CC reaching a finding on whether there is a feature, or combination of features, of a relevant market that prevents, restricts or distorts competition in connection with the supply or acquisition of any goods or services in the UK or part of the UK. If so, it will find that there is an AEC. In forming its judgement the CC will apply a 'balance of probabilities' threshold to its analysis, ie it addresses the question: is it more likely than not that features or a combination of features lead to an AEC? 320. In identifying some features or combination of features of the market that may give rise to an AEC, the CC has to find a benchmark against which to determine how the market may be judged to be performing. In the absence of a statutory benchmark, the CC defines such a benchmark as 'a well-functioning market' (see paragraph 30)—ie one that displays the beneficial aspects of competition as set out in paragraphs 10 to 12 but not an idealized perfectly competitive market.172 The benchmark will generally be the market envisioned without the features. But there may sometimes be reasons to depart from that general concept, for example, if features are intrinsic to the market but nevertheless have anticompetitive effects (as in the case of a natural monopoly) or if the nature of competition in the market is defined by arrangements put in place by Government, eg as in rolling stock leasing.173 321. If the CC decides that there are features in the market leading to an AEC, it moves on to consider appropriate remedies. ## Part 4: Remedial Action 322. When identifying and implementing a remedy to an AEC the CC may have to intervene directly in the structure of established markets and/or address the conduct of firms and their customers. Consideration of whether remedies are necessary and identification of the right remedy are highly dependent on the facts and context of the investigation and require the exercise of judgement by the Inquiry Group conducting the reference.174 The starting point for the CC's remedies assessment is its finding of features that give rise to an AEC and the related findings of fact. More broadly, the CC will have developed, through the course of its investigation, a detailed understanding of the market and an appreciation of the way in which it is capable of working. 323. In choosing a remedy the CC will normally have to consider the interaction of a range of legal, factual and economic considerations. 324. This part of the Guidelines first sets out the framework for consideration of remedies (paragraphs 325 to 369). It then provides an overview of the different types of remedy and their characteristics (paragraphs 371 to 380) before setting out some of the main considerations that go into the selection of remedies from the options available (paragraphs 381 to 393. A more detailed discussion of particular types of remedy is included in Annex B. ## Framework For Consideration Of Remedies The Remedy Questions 325. Where the CC decides that there is an AEC, it is required to decide the following additional questions:175 (a) whether action should be taken by [the CC] … for the purpose of remedying, mitigating or preventing the adverse effect on competition concerned or any detrimental effect on customers so far as it has resulted from, or may be expected to result from, the adverse effect on competition; (b) whether it should recommend the taking of action by others for the purpose of remedying, mitigating or preventing the adverse effect on competition concerned or any detrimental effect on customers so far as it has resulted from, or may be expected to result from, the adverse effect on competition; and (c) in either case, if action should be taken, what action should be taken and what is to be remedied, mitigated or prevented. 326. A detrimental effect on customers is defined as one taking the form of:176 (a) higher prices, lower quality or less choice of goods or services in any market in the UK (whether or not the market to which the feature or features concerned relate); or (b) less innovation in relation to such goods or services. 327. Whether action should be taken therefore involves consideration of both the action the CC can take and the action the CC can recommend others to take. The CC may act itself through exercising its order-making powers or through accepting undertakings from parties (see paragraphs 92 and 93). Alternatively or in addition, the CC may recommend that remedial action should be taken by others, such as government, regulators and public authorities. Such recommendations do not bind the person to whom they are addressed, although the UK Government has committed to respond to any recommendation made to it within 90 days of publication of the CC's final report.177 When deciding on certain remedial actions in regulated sectors the CC has to have regard to the relevant statutory functions of the sectoral regulator concerned.178 In all cases, the CC will state the action that should be taken and what it is designed to address. 328. In practice, the CC may decide to take several actions itself and/or make several recommendations. This combination of actions and/or recommendations is sometimes referred to as a 'package' of measures. Unless otherwise specified, reference to a remedy or a remedy option in this section encompasses the package of measures the CC is taking and/or recommending. 329. The Act requires the CC, in considering these questions, 'in particular to have regard to the need to achieve as comprehensive a solution as is reasonable and practicable to the adverse effect on competition and any detrimental effects on customers so far as resulting from the adverse effect on competition'.179 To fulfil this requirement, the CC will consider how comprehensively possible remedy options address the AEC and/or its detrimental effects and whether they are effective and proportionate. The CC may also have regard, in accordance with the Act, to any RCBs of the market feature(s) giving rise to the AEC180 83 (see paragraph ). Paragraphs 330 to 333 provide greater detail about these factors and their interaction, the ways in which the CC seeks to assess the impact of remedies and the possible outcomes that may arise from balancing these factors. ## A Comprehensive Solution To The Aec And/Or Detrimental Effects 330. Remedies can remedy, mitigate or prevent the AEC or its detrimental effects on customers. The clear preference of the CC is to deal comprehensively with the cause or causes of AECs wherever possible, and by this means significantly increase competitive pressures in a market within a reasonable period of time. 331. AECs are likely to result in costs to the UK economy in general and to customers in particular. Remedies that are effective in generating competition are likely to deliver substantial benefits, by driving down prices and costs and increasing innovation and productivity, thereby facilitating economic growth and increasing the choice available to customers. 332. In deciding what action to take, the CC will typically consider whether tackling some or all of the features it has identified (see paragraphs 154 to 162) will remedy, mitigate or prevent the AEC. In some situations, for example where an AEC arises from a combination of features, it may be necessary to devise a package of remedies to address the AEC, generally by addressing its causes. However, the remedy that is ultimately selected need not directly address every feature identified, if for example, tackling a subset of features directly would be sufficient to generate effective competition and thereby remedy the AEC. 333. While generally preferring to address the causes of the AEC, the CC will consider introducing measures which mitigate the harm to customers created by competition problems, for example if other measures are not available, or as an interim solution while other measures take effect.181 Such measures to control outcomes may be able to reduce the harm to customers associated with high prices, for example, but are unlikely to generate the dynamic benefits, such as innovation, that are normally associated with competitive markets. These measures are therefore likely to represent a less comprehensive remedy to the AEC and any detrimental effects. ## Effectiveness 334. The CC will assess the extent to which different remedy options are likely to be effective in achieving their aims, including their practicability. 335. The effect of any remedy is always uncertain to some degree. In evaluating the effectiveness of potential remedies, the CC will consider the risks associated with different remedy options and will tend to favour remedies that have a higher likelihood of achieving their intended effect. Assessing the effectiveness and practicability of a remedy may involve consideration of several dimensions discussed further below. 336. First, a remedy should be capable of effective implementation, monitoring and enforcement. To facilitate this, the operation and implications of the remedy need to be clear to the persons to whom it is directed and also to other interested persons. Other interested persons may include customers, other businesses that may be affected by the remedy, sectoral regulators, and the OFT (and/or any other body) which has responsibility for monitoring compliance. The effectiveness of any remedy may be reduced if elaborate monitoring and compliance programmes are required.182 Remedies regulating behaviour generally have the disadvantage of requiring ongoing monitoring of compliance and may also constrain beneficial aspects of competitive rivalry. 337. Secondly, the timescale over which a remedy is likely to have effect will be considered. The CC will generally look for remedies that prevent an AEC by extinguishing its causes, or that can otherwise be sustained for as long as the AEC is expected to endure. The CC will also tend to favour remedies that can be expected to show results within a relatively short time. Some remedy options may have an almost immediate impact, while the effects of others will be delayed. In such instances the CC may select a remedy package combining both types of measure taking into account both when each measure would take effect and how long it would endure. 338. Where an AEC is expected to be short-lived (for example, because a specific future event is expected to bring it to an end) and the timescale for implementation of a remedy option would extend significantly into this period, the CC will consider whether an alternative measure would more be appropriate. 339. The CC may also consider whether to specify a limited duration—for example, by means of a long-stop date in a 'sunset clause'—for individual measures, where these are designed to have a transitional effect.183 This might occur if the CC expects an AEC to be time-limited, or if a particular element of a remedy package is intended to be a temporary arrangement to deliver improvements in the short term, while other longer-term measures take effect. However, the period used for any long-stop or review date will depend on the circumstances of the case. The duration of an AEC, in the absence of an intervention by the CC, cannot normally be predicted during the course of an investigation and there will normally be some uncertainty about the precise timescale over which remedies will take effect. For these reasons, the CC will generally rely on parties applying for variation or cancellation of remedies on the basis of a change of circumstances.184 In some cases, the CC may also recommend that the OFT reviews (or considers reviewing) the continued need for particular measures at some future date and/or specify the types of future circumstances which might be expected to trigger such a review (eg significant new entry).185 Alternatively, the OFT might identify a change of circumstances following a review conducted on its own initiative. 340. Thirdly, remedies may need to take account of existing laws or regulations either currently applicable or expected to come into force in the near future. Such other legislation may include both UK and EU legislation and directives and could cover any aspect, for example competition law, health and safety, or data protection). Where there is a tension between existing laws or regulations and the actions that the CC considers necessary to achieve an effective remedy, the CC may make recommendations to the body responsible for the laws or regulations in question. Remedies will also need to take into account the extent to which the prohibitions on anticompetitive agreements and abuses of market power are applicable to the market concerned and impact, if any, these have on the need and ability to impose remedies (see paragraph 17). 341. Fourthly, where more than one measure is being introduced as part of a remedy package, the CC will consider the way in which the measures are expected to interact with each other. As a general rule, measures which have a shared aim of introducing, or strengthening competition within a market will tend to be mutually reinforcing. For example, where market-opening measures are being introduced that increase customer choice by facilitating entry or removing barriers to switching, these may be accompanied by information remedies that help customers choose the best product available to them.186 ## Reasonableness And Proportionality 342. In considering the reasonableness of different remedy options the CC will have regard to their proportionality. 343. The CC's assessment of proportionality will depend on the particular facts and circumstances of the case. It often depends on what other remedy options are also being considered and on judgements about the respective merits of each option, including whether or not a remedy option is likely to be effective in practice. 344. In making an assessment of proportionality, the CC is guided by the following principles. A proportionate remedy is one that: (a) is effective in achieving its legitimate aim; (b) is no more onerous than needed to achieve its aim; (c) is the least onerous if there is a choice between several effective measures; and (d) does not produce disadvantages which are disproportionate to the aim.187 345. Applying these principles to the circumstances of particular cases usually involves consideration of remedy options both relative to other effective measures as well as relative to taking no action 346. The CC will apply these principles to the evaluation of individual measures within a package of remedies as well as to the package taken as a whole (see paragraph 332). 347. Where the CC is considering whether to modify licence conditions in a regulated sector would be proportionate it will have regard to the relevant statutory functions of the regulator concerned.188 A useful summary of the proportionality principles is contained in the following passage from the judgment of the ECJ in Case C-331/88 R v Ministry of Agriculture, Fisheries and Food and Secretary of State for Health, ex parte Fedesa [1990] ECR I-4023, paragraph [13], to which we were referred by the Commission: 'By virtue of that principle, the lawfulness of the prohibition of an economic activity is subject to the condition that the prohibitory measures are appropriate and necessary in order to achieve the objectives legitimately pursued by the legislation in question; when there is a choice between several appropriate measures recourse must be had to the least onerous, and the disadvantages caused must not be disproportionate to the aims pursued'. ## Assessing The Impact Of Remedies 348. In reaching a judgement about whether to proceed with a particular remedy, the CC will consider its potential effects—both positive and negative—on those persons most likely to be affected by it. The CC will pay particular regard to the impact of remedies on customers. The CC will also have regard to the impact of remedies on those businesses subject to them and on other affected parties, such as other businesses (eg potential entrants, or firms active in upstream or downstream markets189 ), government and regulatory bodies, the OFT and other monitoring agencies. 349. The CC will explain what effects it expects to result from a remedy option and will form a view of their significance. As in its assessment of competition in a market (see paragraphs 35 to 41), the CC may take into account a variety of evidence and use a variety of techniques—both qualitative and, where appropriate, quantitative—to analyse effects of remedy options. Similarly to its prioritization of resources in conducting the AEC test (see paragraph 36), the level of detail in which the CC investigates particular effects of a remedy will be influenced by their importance to the CC's overall assessment. For example, if it is clear that the costs of a particular remedy are likely to be very small—both in absolute terms and relative to its likely benefits—the CC may not seek to establish these costs with greater precision.190 350. The extent to which the CC will seek to quantify particular effects of remedies, and the degree of precision with which such quantification is attempted, are likely to vary from case to case. The CC will not carry out quantitative analysis that it considers unnecessary or otherwise not justified by the need to identify a remedy that meets the statutory tests. The general principles the CC follows in its use of evidence are set out in paragraphs 35 to 41. 351. The CC will assess the potential beneficial effects of its interventions. In considering how markets may develop with remedies in place, the CC will consider both benefits that are relatively easy to quantify (such as lower prices) and benefits that are more difficult to quantify (for example, the dynamic benefits of increased rivalry on productivity and innovation). Both are important. The more an AEC reflects longer-term and structural problems within a market, the greater the significance the CC is likely to accord to the long-term development of competition in the market and to the less quantifiable consequences of an improvement in the competitive pressures in the market.191 Conversely, if addressing the AEC requires a remedy focused on achieving relatively predictable changes to outcomes in the shorter term, quantification of these changes is more likely to be a material aspect of the CC's assessment of the beneficial effects of the remedy. 352. Similarly, the CC will consider the potential negative effects of a remedy including the costs to business. Such negative effects may arise in various forms, for example: (a) A remedy may result in unintended distortions to market outcomes. This is more likely to be the case where behavioural remedies are used which intervene directly in market outcomes, especially over a long period. Such distortions may reduce economic efficiency (including dynamic incentives to invest and innovate) and adversely affect the economic interests of customers over the longer term. (b) A remedy may result in implementation costs (for example, modifying a distribution system), ongoing compliance costs (for example, providing the OFT with periodic information on prices or reporting to the OFT on other aspects of compliance), and monitoring costs (for example, the costs of the OFT or other agencies in monitoring compliance). The CC will normally collect information from parties about the potential cost of implementing and complying with its remedies. In evaluating such information, the CC will bear in mind that it has less information than the parties have about how such potential costs have been estimated and that there might be incentives for parties to overstate the cost of those remedies that they do not support. The CC is likely to place most weight on estimates of implementation and compliance costs where parties have provided a clear explanation of how the estimate was reached, together with supporting evidence as to the assumptions used to derive those estimates. (c) If remedies extinguish RCBs, the amount of RCBs foregone may be considered to be a relevant cost of the remedy (see discussion of RCBs, paragraphs 355 to 366). 353. To avoid imposing unnecessary burdens on business, the CC will seek (as stated in paragraph 344) to ensure that its remedies are no more onerous than is necessary to remedy the AEC it has identified. In selecting and designing remedies, the CC will also have regard to the potential for more competitive markets to create profitable opportunities for new and innovative competitors as well as the cost of remedial measures on established businesses. However, where businesses have been found to be earning profits persistently in excess of their cost of capital as a direct result of a feature of the market (see paragraphs 114 to 126), and are likely to continue to do so in the absence of intervention, the CC will not usually give any significant weight to the anticipated reduction of such profits as a negative effect of a remedy. ## Possible Remedy Outcomes 354. In reaching a decision on what remedial action to take, the CC will seek a comprehensive solution to the AEC and resulting customer detriment. In so doing, it will have regard to the need for the solution to be both reasonable and practicable. A consequence of balancing these considerations is that there may be circumstances where the CC judges, for example on the basis of considerations of proportionality, that it should not pursue an effective remedy option that is potentially available to it. There may also be rare cases where, having found an AEC, the CC chooses not to take any remedial action, for example: (a) Where there are no practicable remedy options available to the CC, including any possible recommendations to others. (b) Where the cost of each practicable remedy option is disproportionate compared with the extent that the remedy option resolves the AEC. This might be the case, for example, if the market in which the AEC was found was small in relation to the costs of each practicable remedy option and/or if it was only practicable to mitigate some of the negative consequences of an AEC and the costs of doing so were prohibitively high. (c) Where RCBs accruing from the market features are both large in relation to the AEC and would be lost as a consequence of any practicable remedy (see paragraphs 355 to 359). ## Relevant Customer Benefits 355. The CC, in deciding the question of remedies, may in particular 'have regard to the effect of any action on any relevant customer benefits of the feature or features of the market concerned'.192,193 194 356. RCBs are limited to benefits to relevant customers in the form of: (a) lower prices, higher quality or greater choice of goods or services in any market in the UK (whether or not the market to which the feature or features concerned relate); or (b) greater innovation in relation to such goods or services. 357. The Act provides that a benefit is only an RCB if the CC believes that: (a) the benefit has accrued as a result (whether wholly or partly) of the feature or features concerned or may be expected to accrue within a reasonable period of time as a result (whether wholly or partly) of that feature or those features; and (b) the benefit was, or is, unlikely to accrue without the feature or features concerned.195 196 358. In considering potential RCBs, the CC will therefore need to ascertain that the market feature(s) with which it has been concerned results, or is likely to result, in lower prices, higher quality, wider choice or greater innovation, and that such benefits are unlikely to arise in the absence of the market feature(s) concerned. RCBs may include benefits to customers in the market in which the CC has found an AEC and to customers in other markets within the UK, provided these benefits meet the criteria set out in paragraphs and 357. 356 359. In general, the CC would expect parties to put forward for the CC's consideration any RCBs they think relevant. Parties doing so will be expected to provide convincing evidence regarding the nature and scale of any RCB that they claim to result from the market feature(s) concerned and to demonstrate that these fall within the Act's definition of such benefits. ## Possible Relevant Customer Benefits 360. Whether a particular claimed benefit to customers is found to be an RCB will depend on the facts of the case and the characteristics of a particular market. 361. It would normally be expected that market features that have been found to adversely affect competition—after consideration of any potential rivalry-enhancing efficiencies (see paragraph 174)—would also have detrimental effects on customers. For example, one usual consequence of a failure of competition is that prices will be higher than they would otherwise be. Nevertheless, it is possible that features that adversely affect competition could result in beneficial effects on customers, either in the market in which competition is adversely affected, or in other related markets. The potential loss of such beneficial effects on customers may therefore be taken into account by the CC in its consideration of remedies. In the following paragraphs, examples of possible RCBs are given. In all instances the CC will need to consider whether the criteria set out in paragraphs 356 and 357 are met. 362. Aspects of market structure that could adversely affect competition, such as a high level of concentration, might enable economies of scale and/or scope to be obtained that would not be available if there were a larger number of firms in the market. Whether scale or scope economies would constitute an RCB in a particular case would depend partly on the extent to which, in practice, any cost economies were being passed on to customers as lower prices, improved quality, greater innovation or more choice. 363. Similarly, on the demand side, network effects and the operation of multi-sided markets or platforms (see paragraph 179) may lead to barriers to entry and sustained market concentration, but may also bring benefits to customers of being able to participate in a larger and/or better integrated network or platform.197 In determining whether a particular form of network effects constitutes an RCB, the CC will consider whether customers benefit in practice from such effects and whether such benefits are unlikely to arise in the absence of the AEC resulting from the network effects.198 364. Generally, customers are unlikely to enjoy any benefits as a direct result of entry barriers. However, some entry barriers may indirectly secure other kinds of benefit (see paragraph 235). For example, regulations that limit entry to persons of proven competence or with adequate capital resources may lead to an improvement in product or service quality. Likewise regulations that protect IPRs (see paragraph 211), while potentially restricting access to markets, may lead to improvements in innovation by enabling innovative companies to benefit from the new ideas that they generate. The CC will generally have regard to the wider purpose of such regulations in considering their effects on customers. In the absence of clear, countervailing customer benefits from barriers to entry, the CC would normally expect customers to benefit from any reduction of entry barriers as this would be expected to facilitate dynamic competition and better market outcomes (see paragraphs 205 and 206). 365. As set out in paragraphs 265 and 266, vertical relationships can often have beneficial effects, for example through better coordination of activities at different stages in the supply chain, resolving 'free-rider' problems between producers and distributors and creating incentives to reduce the price of complementary products, Where an AEC has nonetheless arisen from vertical relationships within a market (see paragraph 267), the CC will consider whether these relationships have resulted in RCBs. 366. The CC will similarly consider, when AECs have arisen from the many forms of business conduct that can also have either positive or negative effects, depending on the context, whether these conducts have resulted in RCBs. Tie-in sales or product bundling (see paragraphs 286 to 290), for example, may sometimes be convenient to customers, reduce transaction costs or provide quality assurance. ## Relevant Customer Benefits And Remedies 367. If the CC is satisfied that there are RCBs deriving from a market feature that has resulted in an AEC, the CC will consider whether to modify the remedy that it might otherwise have imposed or recommended. The CC will consider several factors including the size and nature of the expected RCB, what proportion of the benefit will be preserved through the modification, and how long the RCB may be sustained. The CC will also consider the different impacts of the features on different customers or groups of customers. 368. It is possible that the RCBs are of such significance compared with the effects of the market feature(s) on competition that the CC will decide that no remedy is called for (see paragraph 354). This might occur if no remedies can be identified that are able to preserve the RCBs whilst also remedying or mitigating the AEC and/or the resulting customer detriment. This situation has not arisen on a market investigation to date. 369. Alternatively, the CC, as a result of identifying RCBs, may choose a different remedy, for example a behavioural remedy rather than a structural remedy (see paragraph 371 for an explanation of this distinction). In this case, the CC will have to weigh the disadvantage of a less comprehensive solution to the competition problem against the preservation of the RCBs that result from the feature concerned.199 ## Choice Of Remedy 370. Paragraphs 371 to 380 provide an overview of the various types of remedy and their characteristics. Paragraphs 381 to 393 consider the selection from these types of remedy by applying the decision framework outlined in paragraph 384. ## Remedies Universe 371. A diagrammatic representation of the universe of possible remedies is shown in Figure 1. Remedies are conventionally classified as either structural or behavioural. Structural remedies are generally one-off measures that seek, in market investigations, to increase competition by altering the competitive structure of the market. Behavioural remedies are generally ongoing measures that are designed to regulate or constrain the behaviour of parties in a market and/or empower customers to make effective choices. Some remedies, such as those relating to access to IPRs, may have characteristics of structural or behavioural remedies depending on their particular formulation. Likewise, recommendations to others may be either structural or behavioural in nature, depending on their content. Further discussion of the different categories of remedy may be found in Annex B. 'Remedies Universe' Recommendations Structural remedies Behavioural remedies Intellectual Divestiture property Enabling measures Controlling outcomes remedies Source: CC. ## Divestiture 372. The aim of divestiture in market investigations will generally be to address competition problems resulting from structural features of a market.200 This may be done by either creating a new source of competition through disposal of a business or assets to a new market participant, or by strengthening an existing source of competition through disposal of a business or assets to an existing market participant that is independent of the divesting party (or parties). 373. A successful divestiture will address at source the lack of rivalry resulting from structural features of a market. Divestiture remedies will generally not require detailed ongoing monitoring beyond the completion of the disposal of the business or assets in question, although, in some cases, an effective divestiture may require supplementary behavioural measures for an interim period (eg to secure supplies of an essential input or service from the divesting party to the divested business). The requirements for design and implementation of divestiture remedies are considered in detail in Annex B, paragraphs 3 to 30. ## Intellectual Property Remedies 374. A remedy that provides access to intellectual property (IP) by licensing or assignment of those rights may be viewed as a specialized form of divestiture remedy.201 The aim of such a remedy is that the party or parties acquiring the IPRs should thereby be able to compete effectively with other companies in the market. Where the terms of an IP remedy result in a material ongoing link between the original owner of the IP and the parties gaining the IP (eg providing access to new releases or upgrades of technology) an IP remedy may take on some of the characteristics of a behavioural commitment, which may require ongoing monitoring and enforcement. As with other types of remedies, the CC will assess the extent to which specific interventions in relation to IPRs may risk creating distortions, for example by reducing incentives to innovate (see paragraphs 225 and 235). Considerations regarding the design and implementation of IP remedies are outlined in Annex B, paragraphs 31 to 36. ## Enabling Measures 375. Certain forms of behavioural remedy operate principally to enable competition by removing obstacles to competition or stimulating actual or potential competition. 376. Within the category of enabling measures, there are further distinctions between: (a) market-opening measures, which are intended to open up a market to new sources of competition by removing or reducing barriers to entry, expansion or switching. Such measures may, for instance, limit parties' ability to require their customers to enter into long-term or exclusive contracts or to otherwise create switching costs for customers (see Annex B, paragraphs 46 to 60);202 203 (b) informational remedies, which are aimed at giving customers information to help them make choices and thereby increase competitive pressure on firms in the market (see Annex B, paragraphs 61 to 71). 241 Where an AEC results from coordinated effects (see paragraphs to 243) the CC may consider remedies that prevent the sharing of information between firms, if sharing such information has been found to facilitate coordination; and (c) remedies that restrict the adverse effects of vertical relationships (see paragraphs 267 to 272). Such measures may include restriction of access to confidential information ('firewall provisions'), or obligations to provide access to facilities on fair, reasonable and non-discriminatory (FRND) terms (see Annex B, paragraphs 72 to 85).204 377. Enabling measures are generally likely to require ongoing intervention and monitoring. In some instances this may involve complex issues, for instance the pricing of access to facilities that are subject to rapid technological change. Further considerations regarding the design and implementation of enabling measures are outlined in Annex B, paragraphs 46 to 85. ## Controlling Outcomes 378. Certain forms of behavioural remedy seek to prevent the exercise of significant market power and thereby control the detrimental effects arising from an AEC. For example, price caps, supply commitments and service level undertakings all control the way a business can operate to limit any possible detrimental effects on a customer.205 Such measures are often used in regulated sectors, where it may not be feasible to introduce effective competition. However, this type of behavioural remedy can be complex to implement and monitor, given informational asymmetries between the parties and the authorities and the associated risk of circumvention. There is also a risk that such controls create market distortions, particularly if they are kept in place over a long period. Ensuring that measures to control outcomes remain fit for purpose in the light of market developments may involve costs for monitoring and enforcement agencies as well as for the parties subject to them. Further considerations regarding this type of remedy are outlined in Annex B, paragraphs 86 to 93. ## Recommendations 379. The CC can decide to make recommendations to other bodies, rather than taking action itself. Such recommendations can be thought of as falling into one of two categories: (a) In some cases, the legal framework, regulations or conduct applicable to a market may be a structural feature giving rise to an AEC; for example, planning or certification requirements may inhibit entry or restrict market outcomes (see paragraphs 223 to 226). In such cases the CC may recommend modifications of these requirements to the Government or other controlling body to help address the AEC or control its detrimental effects. For example, the CC may recommend the removal or reform of regulatory requirements that have been found to constitute a barrier to entry. (b) The CC may also make recommendations in situations where it is more practicable, or otherwise preferable, to implement a remedy by means of a recommendation.206 380. It will, of course, be for the Government or other person to whom a recommendation is addressed to decide whether to act on the recommendation and the CC will consult with the relevant body prior to making the recommendation. Further considerations regarding this type of remedy are outlined in Annex B, paragraphs 94 to 102. ## Selection Of Remedies 381. As set out in paragraphs 88 to 93, the identification of the Group's preferred remedy is an iterative process in which a potentially wide range of remedy options are progressively narrowed down until a solution has been found that enables the CC to meet its statutory duties. This process involves public consultation on those remedy options that appear to the Inquiry Group to have the best chance of being both effective and proportionate. Some of the key considerations that affect the selection of remedies are set out in the remainder of these Guidelines. 382. As set out in paragraph 330, in deciding what remedial action should be taken, the CC will first look for a remedy that would effectively address the causes of the AEC directly and thereby deal with any detrimental effects on customers of the AEC. 383. The type of action that will be effective in increasing competition will depend on the nature of the AEC concerned. The range of potential competition problems that may be identified as giving rise to an AEC is wide, as is the range of potential remedies. The relative merits of different remedy options will be determined by the facts of the case and, in particular, the nature of the underlying competition problem that gives rise to the need for remedial action. 384. Table 1 illustrates some possible approaches to remedying some of the different types of competition problem that may give rise to an AEC. Example of problem arising Possible remedy approaches - Market-opening measures to reduce barriers to entry and promote dynamic competition. - Recommendations to Government or regulatory bodies to address any barriers to entry which are caused or created by government laws or regulatory actions (eg planning rules). Restrictions on competitive entry or expansion reduce dynamic competition and slow technological progress and introduction of new products. - Structural measures (eg divestiture, IP licensing) to create directly a less concentrated market structure. - Market-opening measures (eg reduction of entry barriers) to increase the competitive constraint from entry, addressing market structure indirectly and thereby increase competitive threat to incumbents. - Recommendations to Government or regulatory bodies to address regulatory barriers to entry or expansion. | Concentrated market structure | | |-------------------------------------|-----| | means that the market is | | | dominated by one player, or a | | | small number of players, whose | | | position is protected by high | | | barriers to entry and/or expansion. | | - Measures to control outcomes (eg price caps) possibly on an interim basis to mitigate the harm to customers until market-opening measures become effective. Measures to control outcomes might also be used if market concentration is very difficult or very costly to alter in practice (eg in a natural monopoly) and/or if concentration gives rise to very substantial RCBs (eg network effects) that would be lost in a more fragmented market structure and market-opening measures are unlikely to be successful. - Structural measures (eg divestiture, IP licensing) to make it harder to achieve, monitor and sustain a coordinated outcome, by increasing the number of significant market participants. Coordination between rivals means that competition is restricted and customers are made worse off. - Market-opening measures (eg reduction of entry barriers) to increase the competitive constraint from entry and thereby increasing competitive threat to incumbents. - Restrictions on supplier conduct or other market features that have the effect of facilitating coordination—for example, remedies might be aimed at limiting the availability of information held by suppliers about their rivals. - Recommendations to Government or regulatory bodies to ensure that government laws or regulatory actions do not facilitate coordination or cause unnecessary barriers to entry or expansion. - Structural measures—for example, to separate 'natural monopoly' activities from potentially competitive activities, or to reduce market power at one or other stage of the supply chain. - Remedies to restrict the effects of vertical relationships to ensure access to key services, products or facilities; prevent discrimination; or prohibit vertical arrangements that restrict competition. - Measures to control outcomes—for example, to mitigate the detrimental effects in 'natural monopoly' activities and/or if vertical relationships give rise to substantial RCBs (eg network effects) that would be lost with other measures. Vertical effects. Competition problems can arise where a single firm operates at a number of levels of the supply chain or where there are other vertical arrangements between firms active at different levels of a supply chain. - Market-opening measures to address the source of switching costs and/or encourage entry and expansion by firms with incentives to reduce search costs (eg by advertising). - Informational remedies to make it easier for customers to find out about products in the market and to facilitate comparisons; to address 'customer' barriers to switching (eg inertia, or lack of familiarity with the switching process) and/or to encourage whole-life costing (eg upfront disclosure of 'hidden' charges). Such measures might involve an element of product regulation to simplify the choices facing customers and/or to protect customer interests, where customer search for information on a particular aspect is unlikely to occur. Information shortfalls and behavioural biases. Competition can be weak, when customers find it hard to identify good value products in a market or switch between providers, or are subject to behavioural biases. Source: CC. 385. As Table 1 shows, structural remedies such as divestiture are a potential solution where horizontal market concentration, coordinated effects or vertical integration are among the principal market features that give rise to an AEC (see Annex B, paragraphs 3 to 30). Likewise, IP licensing may be used to remedy AECs that result from highly concentrated markets, if, by virtue of an IP remedy, new or expanding suppliers would be able to provide an effective competitive constraint on powerful incumbents (see Annex B, paragraphs 31 to 36). 386. Enabling measures may also remedy structural problems. Market-opening measures, for example, may remove or reduce barriers to entry (see Annex B, paragraphs 47 to 60) or measures may be introduced to restrict the adverse effects of vertical relationships (see Annex B, paragraphs 72 to 85). 387. In choosing between structural remedies and enabling measures that impact on market structure indirectly, the CC will consider whether the market response to either type of remedy will be timely and of sufficient scale to represent a comprehensive solution to the AEC. In remedying competition problems arising from high concentration structural remedies have some important advantages over other measures. Once implemented, structural remedies may be expected to increase competitive constraints on the behaviour of firms in the market within a short timescale and without requiring ongoing detailed monitoring by the OFT and/or any other body such as the relevant sector regulator. The underlying cause of high concentration may also be relevant. For example, if certain features of a market (eg network advantages or other barriers to entry and expansion) result in a tendency towards high levels of concentration, enabling measures that address the underlying causes of high concentration (eg by lowering barriers to entry or expansion) might be preferred. The costs of different remedy approaches, including the extent to which any RCBs are retained (see paragraphs 355 to 366) may also be relevant to this choice. 388. In other circumstances, structural remedies may not address the features giving rise to the AEC and behavioural remedies are likely to be preferred. An important difference between remedies in merger and market investigations is that structural remedies, even if they are feasible in a market investigation, may not be an appropriate solution to a particular AEC because of the wide range of features, including nonstructural features, that can give rise to an AEC. For example, enabling measures are more likely to be chosen where: (a) the conduct of firms has given rise to an AEC—for example, by raising barriers to entry or facilitating coordination. In such situations the CC may consider restrictions on firms' behaviour that constrain firms' future ability to engage in such conduct (see Annex B, paragraphs 49 to 53); (b) switching costs or barriers to entry or expansion are among the features that give rise to an AEC. Here, the CC may consider market-opening measures that address the main barriers to switching, entry or expansion that it has identified (see Annex B, paragraphs 54 to 60); or (c) search costs and other information shortfalls are among the features giving rise to an AEC. In such situations, informational remedies that make it easier for customers to search and switch may be an appropriate response (see Annex B, paragraphs 61 to 71). 389. Remedial action may also be required to address customer detriment directly, for example where effective remedies aimed at introducing competition by addressing the AEC are unavailable or will not bear fruit in the short term (see Annex B, para- graphs 86 to 93). Price controls are the most obvious example. However, such measures to control outcomes are not likely, by their nature, to provide a solution to the underlying problem and may also give rise to distortion risks, if retained over a long period. For these reasons (as stated in paragraph 330), remedial action to control outcomes will not generally be preferred as a long-term solution. 390. As stated in paragraph 379, recommendations may be considered where an aspect of regulation or government behaviour is itself giving rise to an AEC or where it would be more practicable (or otherwise preferable) for the CC to implement a remedy by means of a recommendation rather than taking action itself. This may include situations in which other bodies have powers that are unavailable to the CC207 or where a recommendation enables a remedy to be better integrated with existing interventions in a sector.208 It may also include cases where a remedy to increase competition in a market has the potential to come into conflict with other important public policy objectives and it is more appropriate for Government, rather than the CC, to balance these conflicting objectives.209 391. In deciding whether to make a recommendation rather than take action itself, the CC will form a view as to the likelihood that the recommendation will be acted upon and, if so, over what time period. In reaching this view, the CC will have regard both to the stated policy of the body to which the recommendation is to be directed and to the possibility that that stated policy may change, either in light of the CC's recommendation or subsequent events (see Annex B, paragraphs 94 to 102). The likelihood of a recommendation being implemented is therefore relevant to the timeliness and effectiveness of such a recommendation. However, the CC may sometimes make recommendations that may not be implemented immediately, where it judges that these are nonetheless likely to be more effective than other possible remedies. 392. In looking for remedies that would be likely to increase competition in the relevant market(s), the CC will give attention to the time period within which the remedy can be expected to show results. If a remedy is not likely to have rapid results, the CC may choose an alternative remedy or implement additional remedies such as measures to address the detrimental effects on customers during the interim period. Otherwise, not only might there be uncertainty as to whether the beneficial effects of the remedy would materialize, but, in the meantime, customers would continue to suffer from the consequences of the AEC. 393. The CC's experience to date suggests that remedies in market investigations may take the form of a 'package' of measures, rather than the implementation of a single measure (see paragraph 332). This may be because there are several features giving rise to an AEC, and consequently an individual measure may be incapable of addressing the AEC in its entirety. For example, to deal with problems associated with a lack of customer switching it may be necessary both to remove contractual barriers to switching and also to put in place informational remedies that raise customer awareness of the potential benefits of switching. Where more than one measure is being introduced, the CC will consider the way in which the measures are expected to interact with each other. As a general rule (as stated in paragraph 341), measures which share the aim of introducing competition into a market will tend to be mutually reinforcing. ## Annex A: Market Characteristics And Outcomes 1. Measuring market shares and concentration ## Market Shares 1. Subject to the availability of data, the CC normally calculates market shares for all firms currently producing products in the relevant market or in any market the CC considers relevant to its investigation. It does so on the basis of the available indicators of firms' future competitive significance in the market. These may depend upon the nature of competition in the market as well as on the availability of data. In many cases, the CC will calculate market shares on the basis of several indicative measures (see paragraph 2) so as to understand fully how a market is operating. The CC may use information from a variety of sources including established sellers, potential entrants, customers, buyers, suppliers, trade associations and market research reports. 2. Market shares can be measured in terms of revenues, volumes, production capacities or inputs: - *Revenues.* In most contexts, the CC uses actual or projected revenues in the market as the bases for measurement. They are the best 'real world' measure and are particularly pertinent when products differ in quality. But in some cases, unit sales (eg when a new, less expensive product has entered the market) or revenues earned just from recently acquired customers (when long-term contracts or high switching costs are involved) may be better measures of competitive significance than total revenues. - *Capacities.* In markets for homogeneous products, the level of readily available capacity or reserves to serve the market can be an appropriate measure if that capacity is efficient enough to make expansion profitable in response to a price rise or to reduced output by competitors. If this measure is used, market participants that are not current producers may sometimes be assigned positive market shares to reflect their impact on competition. 3. Typically, annual data is used, but where individual transactions are large and infrequent, annual data may be unrepresentative, and in these cases the CC may measure market shares over a longer period of time. ## Concentration Measures 4. The degree of concentration in a market may be measured in different ways, depending on the nature of competition and availability of data. A numerical count of the firms in a market is the basic measure. It does not take into account differences in market shares and the size distribution of firms, but can be useful when there is a gap in market share between significant competitors and smaller rivals or when it is difficult to measure revenues in the market. The CC attaches particular weight to a numerical count of firms when considering coordinated conduct. 5. Two other commonly used measures are the concentration ratio and the Herfindahl- Hirschman Index (HHI). 6. The concentration ratio measures the combined market share of the largest firms in a market. For example, the 'five firm' concentration ratio is simply the sum of the mar- ket shares of the five largest firms in the market. It does not provide any information on the relative size of the firms nor on the number, or size, of the smaller firms. 7. The HHI potentially reflects both the number of firms in the industry and their relative size. It is defined as the sum of the squares of all the market shares in the market, and thus gives proportionately greater weight to the larger market shares. The CC is likely to regard any market with an HHI in excess of 2,000 as highly concentrated, and any market with an HHI in excess of 1,000 as concentrated. However, the CC will have regard to these threshold levels—if considered relevant—only as one factor in its wider assessment of competition. 8. The calculations of market shares, numbers of firms, concentration ratios and the HHI generally depend on being able to identify the boundaries of the market concerned. However, one technique, which is closely related to other traditional concentration measures, but does not rely on pre-defined boundaries, is the Logit Competition Index, sometimes referred to as LOCI. LOCI can be computed as (one minus) a firm's weighted average market share across the submarkets within which it operates. The weights are calculated according to the importance to the firm of each submarket, and the definition of a submarket depends on the particular application. In practical terms, LOCI requires that a much greater amount of information be available than is required for computing the traditional concentration measures described in paragraphs 4 to 7 above. 2. Measuring profitability 9. In measuring profitability the CC's approach will often be to start with accounting profit produced in line with UK Generally Accepted Accounting Principles (GAAP) and then to make adjustments to arrive at an economically meaningful measure of profitability, usually in terms of rates of return on capital.1 The CC will often inform its judgement on what is an 'economically meaningful measure of profitability' by examining the management accounting records of the firms in question. The manner by which industry participants, including firms, analysts, and investors, assess profitability for the purposes of monitoring and reporting performance may well inform our view as to what is an appropriate measure for the industry in question.2 For example, in the financial sector the CC has previously considered return on equity over a five-year period as its primary measure of profitability. In other industries the CC has considered return on capital employed over a similar period.3 4 10. The appropriateness of a given measure will also depend on the nature of the industry and the pattern of investment. Where investment is characterized by large one-off expenditure, or the industry has experienced a period of growth, it may be desirable to consider profitability over a relatively long period of time or on a project appraisal basis. For example, it may be appropriate to use a cash-flow-based model to compute a measure of the internal rate of return (IRR) where reliable data is available on this basis. 11. An important factor to consider when selecting an appropriate model will be data availability. Where possible, the CC will base its calculations on financial data that can be reconciled to audited financial statements, albeit with appropriate adjust- ments. For example, where the market of interest is a division or segment of a company it may not be possible to obtain reliable cash flow data at this level and the CC may therefore adopt a return on capital approach for this reason. 12. Whatever measure of profitability is used, the calculation of profitability for the purposes of competition analysis is often not straightforward because of the need to obtain an appropriate value for capital employed, as described below. In industries with a relatively low level of tangible assets, such as service and knowledge-based industries, the book value of capital employed may bear little relationship to the economic value because of the presence of significant intangibles. In some cases, the replacement cost of assets may be different from historical costs due to the length of time elapsed and changes in asset prices and efficient technologies over time. 13. Obtaining a value for capital employed can present difficulties irrespective of the choice of model. For example, the use of a truncated IRR requires the assets to be valued appropriately at the beginning and end of the period selected. Similarly, a return on capital approach, whether return on equity or return on capital employed (ROCE), requires an economically meaningful value for the capital base which may not accord with the value ascribed in the financial records. 14. Hence, it may be necessary to make adjustments to accounting data produced in line with UK GAAP. In particular, the following adjustments may be considered: - Under current accounting standards, most assets are held at historical cost and this may differ substantially from the 'replacement cost' or 'Modern Equivalent Asset value',5 which the CC considers to be the economically meaningful measure for its purposes in most cases. In these circumstances, and where this would be likely to have a material effect on its calculations, the CC will consider whether replacement cost values can be derived reliably. 6 - Secondly, the CC may consider the inclusion of certain intangible assets where the following criteria are met: - it must comprise a cost that has been incurred primarily to obtain earnings in the future; - this cost must be additional to costs necessarily incurred at the time in running the business; and - it must be identifiable as creating such an asset separate from any arising from the general running of the business. In establishing a value for intangible assets meeting the above criteria, the CC will have regard to similar principles as for other types of assets. - Other adjustments may be considered on a case-specific basis. 15. In situations where capital employed cannot be reliably valued the CC may consider alternative measures, such as the return on sales or other relevant financial ratios. For instance, comparisons with businesses operating in different but similar markets may on occasions be helpful. 16. In assessing levels of profitability the CC will have regard to its view of firms' cost of capital. The CC will generally look to the capital asset pricing model (CAPM) when considering the cost of capital, since this is a widely understood technique with strong theoretical foundations. However, the CC will have regard to alternative models where appropriate. ## Annex B: Remedial Action Types of remedy 1. This annex summarizes some of the key considerations relevant to the evaluation, design and implementation of different classes of remedies. It is structured as follows: (a) Section 1 discusses divestiture and IP remedies. (b) Section 2 discusses behavioural remedies. (c) Section 3 discusses recommendations. ## Section 1: Divestiture And Intellectual Property Remedies 2. This section deals with issues relating to divestiture and IP remedies. These types of remedy are sometimes referred to as 'structural remedies', though as set out in paragraph 31, IP remedies can have both structural and behavioural aspects. Divestiture remedies are discussed in paragraphs 3 to 30 and IP remedies in paragraphs 31 to 36. ## Divestiture Remedies Introduction 3. In essence, a divestiture seeks to remedy an AEC by either creating a new source of competition through disposal of a business or set of assets to a new market participant or strengthening an existing source of competition through disposal to an existing market participant independent of the divesting party (or parties). 4. The CC has required divestiture in one market investigation to report to date (BAA Airports). This guidance reflects the CC's experience in that case and also, where relevant, the experience of designing and implementing divestiture remedies in merger inquiries, where divestiture is the most frequently used remedy option.1 5. The design of a divestiture remedy will seek to address the underlying cause of an AEC and will take account of any risks of not addressing the AEC and any RCBs that may be affected by the form of divestiture. ## Divestiture Risks 6. Divestitures may be subject to a variety of risks that may limit their effectiveness in addressing an AEC. It is helpful to distinguish between three broad categories of risks that may impair the effectiveness of divestiture remedies as follows: (a) Composition risks—these are risks that the scope of the divestiture package may be too constrained or not appropriately configured to attract suitable purchasers or may not allow a purchaser to operate as an effective competitor in the market. (b) Purchaser risks—these are risks that a suitable purchaser is not available or that the divesting party (or parties) will dispose to a weak or otherwise inappropriate purchaser. (c) Asset risks—these are risks that the competitive capability of a divestiture package will deteriorate before completion of divestiture, for example through loss of customers or key members of staff. 7. The incentives of divesting parties may serve to increase the risks of divestiture. Although divesting parties will normally have an incentive to maximize the disposal proceeds of a divestiture they will also have incentives to limit the future competitive impact of a divestiture on themselves. Parties may therefore have, on balance, an incentive to make divestitures to weaker competitors of less competitive assets or businesses and may also allow the competitiveness of divestiture packages to decline during the divestiture process.2 8. Divestiture risks can be overcome, at least in part, through the design of the divestiture and by adopting protective measures such as appointment of monitoring and divestiture trustees and alternative divestiture packages as shown later in this section. To be effective in increasing rivalry—and managing divestiture risks—a divestiture remedy should involve the sale of an appropriate divestiture package to a suitable purchaser through an effective divestiture process. These critical elements of the design of a divestiture remedy are discussed in detail in the following sections. ## Scope Of Divestiture Packages Package definition 9. In defining the scope of a divestiture package that will satisfactorily address an AEC, the CC will normally seek to identify a divestiture package that comprises a viable, stand-alone business that can compete successfully on an ongoing basis and is of sufficient scale and scope to enable its acquirer to become an effective competitor. This may comprise a division or the whole of an operating company functioning in the market affected by the AEC. Depending on the nature of the AEC, it may be necessary to identify more than one divestiture package to achieve a comprehensive solution—for example, if several distinct businesses under common ownership need to be divested to remedy the AEC.3 10. In order to achieve a proportionate solution, the CC will seek to identify the smallest such package (or packages) that is likely to be a viable competitor and satisfactorily addresses the AEC. Following discussion with parties, the CC may modify the scope of the proposed divestiture package (or packages) provided that the parties can demonstrate, to the CC's satisfaction, that the modified package (or packages) addresses the AEC and the modification does not create significant additional new costs or composition, purchaser or asset risks after taking account of protective measures. 11. The scope of a divestiture package will be outlined, with reasons, in the CC's report. The package will generally be specified in greater detail in the undertakings accepted or orders made by the CC when implementing the remedy. The divesting parties may also add further assets to the specified package at their request with the approval of the CC, or may be required to do so by the CC, to secure divestment to a suitable purchaser. The divesting parties will generally be prohibited from subsequently purchasing assets or shareholdings sold as part of a divestiture package or acquiring material influence over them. The CC will normally limit this prohibition to a sunset clause period of ten years. Divestiture of an existing business or package of assets 12. The CC will generally prefer divestiture of an existing business that can compete effectively on a stand-alone basis independently of the divesting party (or parties), to divestiture of part of a business or a collection of assets. This is because divestiture of a complete business is less likely to be subject to purchaser and composition risk and can generally be achieved more quickly. 13. Where a proposed divestiture comprises part of a business or specified assets, such as IPRs, the capabilities and resources of prospective buyers are likely to be more critical to a successful outcome than for a stand-alone business. A package of assets proposed for divestiture may, for example, lack an established infrastructure and its viability may therefore be more dependent on an appropriate match with the capabilities of the purchaser. A package of assets may also be far more difficult to define or 'carve out' from an underlying business4 15 and the CC may have less assurance that the purchaser will be supplied with all it requires to operate competitively. In such circumstances, the CC is likely to require additional protective measures such as identification of an alternative divestiture package (see paragraphs and 16) to mitigate increased purchaser and composition risk. Where a package of assets is proposed for divestiture, the CC will require the divesting parties to specify the composition and operation of the package in detail. 14. In particular circumstances, parties may propose a 'virtual divestiture' consisting of divestiture of production capacity5 for a specified period rather than conventional disposal of a business or package of assets. Such a proposal may have higher risks and costs than a conventional divestiture, and require continuing monitoring and compliance activity. The CC would need to satisfy itself that there was good reason to justify such a proposal in preference to a conventional divestiture and that the risks of the proposal could be appropriately contained. ## Alternative Divestiture Packages 15. In some circumstances, it may be appropriate to define a more extensive and/or more marketable divestiture package ('alternative divestiture package'6) which the CC would require the parties to sell if the initially proposed divestiture package were not sold within a specified period. Alternative divestiture packages may be appropriate if there is doubt as to the marketability of the initially proposed divestiture package or where a business is subject to major asset risks and speed of divestiture is likely to be a critical requirement.7 In such circumstances, prior identification of a more extensive, more marketable package may be the most effective means of facilitating rapid disposal if the initial package cannot be sold to a suitable purchaser within a specified period.8 In specifying an alternative divestiture package the CC would wish to satisfy itself that divestiture of such a package would be effective and (in the event that the proposed divestiture package had not been disposed to a suitable purchaser) proportionate. 16. The alternative divestiture package will include all the core assets necessary to remedy the AEC. The CC will wish to satisfy itself that the purchaser of such a package is committed to operate the core assets so as to compete effectively in the market(s) affected by the AEC and not primarily attracted by the additional assets. The CC will identify the alternative package in its report but the precise nature, and in some cases the existence, of an alternative package may be excised from the published version of the report to prevent the existence of the alternative package undermining divestiture of the initial package. ## Suitable Purchasers Criteria 17. The identity and capability of a purchaser will be of major importance in ensuring the success of a divestiture remedy. The divesting party (or parties) will therefore need to obtain the CC's approval of the prospective purchaser(s). The CC will wish to satisfy itself that a prospective purchaser is independent of the divesting parties, has the necessary capability to compete, is committed to competing in the relevant market(s) and that divestiture to the purchaser will not create further competition concerns. The relative importance that the CC attributes to each of these criteria will depend on the circumstances of the inquiry. These criteria are considered in more detail below: (a) Independence. The purchaser should have no significant connection to the divesting parties that may compromise the purchaser's incentives to compete with them or, where relevant, with other major suppliers in the relevant market(s). Significant connections may include, for example, an equity interest, shared directors, reciprocal trading relationships or continuing financial assistance. The CC will seek to understand the significance of such connections in the context of the overall relationship between the parties concerned, in order to form a view of their cumulative effect on incentives to compete. (b) Capability. The purchaser must have access to appropriate financial resources, expertise and assets to enable the divested business to be an effective competitor in the market. This access should be sufficient to enable the divestiture package to continue to develop as an effective competitor. For example, a highly leveraged acquisition of the divestiture package that left little scope for competitive levels of capital expenditure or product development is unlikely to satisfy this criterion. Where the purchaser takes the form of a consortium, the CC will wish to satisfy itself that the structure and governance arrangements of the consortium will permit appropriate access to expertise and finance.9 (c) Commitment to relevant market. The CC will wish to satisfy itself that the purchaser has an appropriate business plan and objectives for competing in the relevant market(s).10 (d) Absence of competitive or regulatory concerns. Divestiture to the purchaser should not create a realistic prospect of further competition or regulatory concerns. Moreover, the CC's approval of a purchaser may be subject to clearance by the OFT or other regulatory authority. 18. Except in circumstances, as specified below, where a divestiture trustee is in place, the divesting parties are responsible for securing a prospective buyer which is able to demonstrate that it satisfies the CC's criteria for a suitable purchaser. However, the CC will keep the progress of the divestiture under close scrutiny. 19. Where divesting parties receive interest from more than one prospective buyer, the CC will generally wish to evaluate whether purchasers fulfil the criteria before any purchaser is granted exclusivity to undertake detailed due diligence. This is to avoid situations where a prospective purchaser undertakes lengthy due diligence on an exclusive basis but is then found not to satisfy the CC's criteria. 20. In certain cases, for example where the effectiveness of a divestiture remedy is particularly dependent on the long-term development of the divested entity, the CC may require a purchaser to provide it with undertakings that it will not sell on the divested entity within a limited period other than with the CC's approval that the new purchaser satisfies the same purchaser criteria as applied in the initial divestiture. Whether such a restriction is necessary and the time period over which any such restriction will apply will be determined by the facts of the case.11 ## Continuing Links And Purchaser Protection 21. A purchaser should not have continuing links with the divesting party (or parties) after divestiture that may compromise the purchaser's incentives to compete with these parties, for example financial, ownership or management links. However, purchasers may require access to key inputs or services at appropriate terms from the divesting party (or parties), on an interim basis, in order to enable the divestiture to operate effectively. Such transitional service arrangements may be permitted by the CC for a limited period. The timescale over which transitional service arrangements will be permitted is likely to vary from case to case, depending on the time that it may reasonably be expected to take potential purchasers to develop their own independent access to the inputs or services in question. 22. The CC may also permit or require non-solicitation clauses or other measures to protect the purchaser from the divesting party (or parties) for a limited period to enable the purchaser to become established as an effective competitor in the relevant market(s). In order to ensure a timely remedy, the CC will seek to ensure that any period of purchaser protection is no longer than necessary and can be justified by reference to the steps necessary for the purchaser to become established as an effective competitor. In any event, given the desirability of achieving a timely remedy, the CC would not normally expect to permit or require such measures for more than two years. ## Effective Divestiture Process Objective Of Process 23. An effective divestiture process will protect the competitive potential of the divestiture package before disposal and will enable a suitable purchaser to be secured in an acceptable timescale. The process should also allow prospective purchasers to make an appropriately informed acquisition decision. ## Protecting The Divestiture Package 24. Divesting parties may have significant incentives to run down or neglect the business or assets of a divestment package, and/or continue to extract know-how and other commercially sensitive information from the divestment package. Such incentives, if acted upon, are likely to reduce the future competitive impact of the divestment package. The resulting asset risk may also be influenced by such factors as the length and complexity of the divestiture process and the pace at which customer goodwill and employee relations may erode. 25. To protect against these forms of asset risk, the CC will generally seek undertakings from the relevant parties which impose a general duty to maintain the divestiture package in good order and not to undermine the competitive position of the package. The CC may also require 'hold-separate' undertakings to mitigate asset risk. These will require the divestiture package to be held and managed separately from the retained business. Protection measures specified in final undertakings may sometimes continue existing measures specified in any interim undertakings that have been accepted by the CC (although interim undertakings can only be accepted in market investigations following publication of the final report). The appointment of a hold-separate manager or management team may also be required to manage the assets/business to be divested so as to maintain their competitiveness and establish separation from the retained assets.12 Establishing separation may be a more complex issue than in merger inquiries. ## Use Of Monitoring Trustees 26. Where divestiture undertakings are in place, the CC will normally require the appointment of an independent monitoring trustee to oversee the parties' compliance with the undertakings and, if applicable, the performance of the hold-separate manager. The trustee will have an overall duty to perform in accordance with his or her agreed mandate and the directions of the CC. The trustee will monitor the ongoing management of the divestiture package and the conduct of the divestiture process. The CC will have the right to propose and direct measures necessary to ensure compliance with the undertakings. The trustee will report to the CC at regular intervals. The divestiture period 27. The CC will state in its report the period in which the parties should achieve effective disposal of a divestiture package to a suitable purchaser (ie the 'initial divestiture period'). However, this period will normally be excised from the report if it is considered that disclosure to third parties may undermine the divestiture process. The length of this period will depend on the circumstances of the case but will normally have a maximum duration of six months in relatively straightforward divestiture cases. The CC, when determining the initial divestiture period, will seek to balance factors which favour a shorter duration, such as minimizing asset risk and giving rapid effect to the remedy, with factors that favour a longer duration such as canvassing a sufficient selection of potential suitable purchasers to facilitate effective disposal and adequate due diligence. In general, the CC would expect that the period permitted for divestiture in market investigations would be sufficient for the divesting company to realize an approximation-to-fair market value for the divestiture package. The initial divestiture period may be extended by the CC where this is necessary to achieve an effective disposal. 28. While the divesting parties are responsible for securing a suitable purchaser in the initial divestiture period, the CC will keep the progress of the divestiture process under close review through regular reporting and, where applicable, the scrutiny of a monitoring trustee. ## Use Of Divestiture Trustees 29. If the divesting parties cannot procure divestiture to a suitable purchaser within the initial divestiture period, then, unless this period is extended by the CC, an independent divestiture trustee may be mandated to dispose of the package within a specified period (the trustee's divestiture period) at the best available price in the circumstances, subject to prior approval by the CC of the purchaser and the divestiture arrangements. If the CC has reason to expect that parties will not procure divestiture to a suitable purchaser within the initial divestiture period, the CC may require that a divestiture trustee is appointed before the end of the initial divestiture period, or in unusual cases, at the outset of the divestiture process.13 The role of a divestiture trustee is distinct from that of a monitoring trustee, but the two roles may be performed by the same person subject to consideration of any potential conflict of interest. The CC may require a divestiture trustee to be selected and made ready prior to the end of a divestiture period in order to prevent any delay in appointment following the end of the divestiture period. ## Review Of Divestiture Documentation 30. The CC will wish to ensure, before providing its final approval of the divestiture at the end of the divestiture process, that the divestiture agreement and relevant supporting documentation convey all assets required to be divested, and contain no provisions that are inconsistent with the remedial objectives of the divestiture. For example, continuing links between the purchaser and the parties, as outlined in paragraph 21, may undermine competitive incentives. ## Intellectual Property Remedies Introduction 31. The licensing or assignment of IP, including patents, licences and brands, may be viewed generally as a specialized form of asset divestiture. However, in certain cases, the terms of a licence may contain ongoing behavioural elements such that the remedy is a structural/behavioural hybrid. The key element is the extent to which any material link between licensor and licensee will exist following award of the licence. A remedy that requires an assignment or licence of an IP right that is exclusive, irrevocable and non-terminable with no performance-related royalties will effectively be treated by the CC as structural in form and subject to similar consideration and evaluation as an asset divestiture. A licence that requires a licensee to rely on the licensor for updates of the technology or continuing access to specialist inputs or know-how will be regarded as a behavioural commitment and is generally subject to greater risks of not being an effective remedy. 32. For licensing of IP alone to be effective as a remedy, it must be sufficient to enhance significantly the acquirer's ability to compete with other parties in the market and thus address the AEC.14 Such a remedy may not be effective if the IP needs to be accompanied by other resources (for example, technical expertise and sales networks) to enable effective competition if these are unlikely to be available in potential acquirers of the IP. 33. In view of the possible risks to effectiveness, as outlined in paragraph 32, that may result from using IP remedies, the CC will generally prefer to divest a business including IPRs, where this is feasible, rather than rely on licensing narrowly defined IP alone. This is because divestiture of a business including IPRs is more likely to include all that the acquirer needs to compete effectively with other parties in the market. ## Design Factors 34. The appropriate design of an IP remedy may be influenced by several case-specific factors such as: (a) The form and jurisdiction of the relevant IP (eg patent, exclusive licence, trade mark etc). The CC will wish to ensure that the IP to be divested is sufficient to enable a purchaser to compete effectively. This may sometimes include less easily transferable forms of IP (eg 'know-how').15 Where there is uncertainty regarding the scope of a licence or its terms and conditions, the parties may be required to divest the underlying right and accept a licence back. 16 (b) The relative specialization of the IP. Highly specialized IP may impose particular constraints on selecting a suitable acquirer as there may be few parties competent to use the IP. (c) The rate of innovation expected in the relevant market. A high rate of innovation may imply a shorter required duration for a licensing remedy than in a more stable market. (d) Forms of payment for IP. The form of payment (eg one-off payment, royalties or profit shares) may have an effect on competitive incentives. recognize the need for preserving incentives for innovation while addressing competitive concerns. 36. Remedies relating to the transfer of IPRs may have international repercussions due, for instance, to international filing and licensing of patent rights. International cooperation with other competition authorities is therefore often particularly necessary in these cases. ## Section 2: Behavioural Remedies Introduction 37. Behavioural remedies are designed to regulate the ongoing conduct of parties so as to address an AEC and/or its adverse effects. In market investigations the CC may use behavioural measures as a main remedy or as an adjunct to other measures (eg structural measures or recommendations). 38. The variety of market features and possible behavioural measures that may be encountered on individual investigations is extensive. This guidance therefore seeks to outline the CC's general approach to behavioural remedies, making reference to the types of measure that have been implemented in investigations to date, rather than dealing with all possibilities. 39. In the rest of this section some general issues are first considered relating to the design, monitoring and enforcement of behavioural remedies and their duration (paragraphs 40 to 45). The two main categories of behavioural remedies are then considered, namely enabling measures (paragraphs 46 to 85) and measures to control outcomes (paragraphs 86 to 93). The former address an AEC by seeking to remove obstacles to competition or otherwise stimulating competition within a market, whereas the latter seek to prevent the exercise of significant market power and thereby control the detrimental effects arising from an AEC rather than remedy the AEC itself. A comprehensive and timely solution to an AEC may require both categories of remedy. ## General Issues Design, Monitoring And Enforcement 40. Behavioural remedies seek to change aspects of business conduct from what may be expected based on businesses' incentives and resources. The design of behavioural remedies should seek to avoid four particular forms of risk to enable these measures to be as effective as possible: (a) Specification risks—These risks arise if the form of conduct required to address the AEC or its detrimental effects cannot be specified with sufficient clarity to provide an effective basis for monitoring and compliance. The intended operation of the measure needs to be clear to the persons to whom it is directed and other relevant parties, so that it is apparent what conduct constitutes compliance and what does not. For example, a commitment to permit access on FRND terms, without further clarification of what this means in practice, may create significant specification risk as the provision may be insufficiently specific to allow effective enforcement. Markets that are subject to frequent change in products or supply arrangements may be particularly prone to specification risk if the definition of required conduct is vulnerable to such changes. (b) Circumvention risks—It is possible that other adverse forms of behaviour may arise if particular forms of behaviour are restricted.17 For example, if prices are controlled a firm may reduce product quality. To avoid or reduce these risks, behavioural measures will generally need to deal with all the likely substantial forms in which enhanced market power may be applied. In some cases this may not be feasible or may make the behavioural measures too complex to monitor and/or enforce. (c) Distortion risks—These are risks that behavioural remedies may create market distortions that reduce the effectiveness of these measures and/or increase their effective costs. Distortion risks may result from remedies overriding market signals or encouraging circumvention behaviour. For example, prohibiting the use of long-term contracts may result in a lack of incentives to compete for new business. (d) Monitoring and enforcement risks—Even clearly specified remedies may be subject to significant risks of ineffective monitoring and enforcement. This may be due to a variety of causes such as the volume and complexity of information required to monitor compliance, limitations in monitoring resources, asymmetry of information between the monitoring agency and the business concerned and the long timescale of enforcement relative to a rapidly moving market. 41. For behavioural remedies to have the desired impact it is important that there are effective and adequately resourced arrangements in place for monitoring and enforcement so that there is a powerful threat that non-compliance will be detected and that action will be taken to enforce compliance where this is necessary. 42. The OFT, or the relevant sectoral regulator where appropriate, is responsible for monitoring and enforcing compliance of remedies under the Act.18 Customers and competitors of the firms subject to behavioural remedies may be in a strong position to report to the OFT, or the relevant sectoral regulator, on instances of noncompliance where they have appropriate resources and incentives to do so. However, such persons may be inhibited from fulfilling this reporting role by lack of resources and verifiable information, lack of understanding of the measures, fear of reprisals and other disincentives. 43. In view of constraints on the OFT's resources and the possible limitations in the reliance that can be placed on the reporting role of customers and competitors, it may be necessary for the CC to seek undertakings from the relevant parties to appoint and remunerate a third party monitor to enable the OFT, or the relevant sectoral regulator, to fulfil its monitoring responsibilities effectively. 19 Alternatively monitoring may be facilitated by the CC making an order requiring the relevant parties to publish certain information20 or to produce compliance reports that have been verified by an independent third party.21 The likelihood of effective monitoring will be significantly increased if it is possible to involve a sectoral regulator in the monitoring regime. 44. A behavioural remedy may seek to prevent certain conduct that may be prohibited under the CA98's Chapter II Prohibition or under Article 102 TFEU. Similarly, a behavioural remedy may seek to prevent the making of agreements that may be prohibited under the CA98's Chapter I Prohibition or Article 101 TFEU. The CC recognizes the importance of ex post competition enforcement. However, the CC has an obligation to achieve as comprehensive a solution to the AEC and its detrimental effects as is reasonable and practicable. The CC will therefore normally prefer to specify its own remedial measures rather than rely on the general provisions of competition law, as this has the advantages that the CC measures can be designed to take account of the circumstances of the case and the provisions for monitoring and enforcement can be fully defined. ## Duration 45. As behavioural remedies are designed to have ongoing effects on business conduct throughout the period they are in force, the duration of these measures is a material consideration. The CC may specify a limited duration if measures are designed to have a transitional effect. Where measures need to apply as long as an AEC persists and as this period can rarely be predicted during the course of an inquiry, the CC will generally rely on the relevant parties applying for variation or cancellation of the measures on the basis of a change of circumstances22 or possibly recommend that the OFT reviews the need for the measures after a given period. However, the CC may, in addition, specify a long-stop date in a 'sunset clause' beyond which the measures will definitely not apply. The period used for the long-stop date will depend on the circumstances of the case. ## Enabling Measures 46. Enabling measures aim to remedy an AEC by removing obstacles to competition or otherwise stimulating competition. Most enabling measures that have been introduced by the CC to date may be classified as:23 (a) market-opening measures; (b) informational remedies; or (c) measures to restrain the impact of vertical relationships. ## Market-Opening Measures 47. Market-opening measures are aimed at removing impediments to effective competition, such as barriers to entry, expansion and/or switching. Such impediments may result from structural features of the market (eg barriers to entry) or from the behaviour of individual firms in that market (eg exclusionary conduct). 48. This is a diverse category of remedies. The specific aim of any market-opening measure and the particular mechanism that is used in any case, will depend on the market features that have been identified as preventing, restricting or distorting competition and the practical opportunities available for addressing those features. Market-opening measures can be further subdivided into the following two categories: (a) Firm-specific measures to restrain horizontal market power. (b) Market-wide measures to reduce barriers to entry, expansion and switching. Firm-specific measures to restrain horizontal market power 49. Where a firm enjoys significant market power it may be able to use the strength of this position in a number of ways to limit or restrain competition. These may include: (a) requiring customers to enter into long-term and/or exclusive contracts; (b) creating switching costs for customers through, for example, volume discounts or contractual penalties; (c) bundling or tying the sale of particular products; and (d) selective discounting or exclusionary conduct. 50. Remedies may be introduced that prohibit, restrict or discourage types of behaviour, such as those listed above, where these have been found to prevent, restrict or distort competition. The selection and design of these measures will depend critically on the circumstances revealed by the inquiry and the need to manage specification, circumvention, monitoring and enforcement risks. Where circumstances point to the use of these measures, the CC will follow the general approach of considering the anticompetitive conduct that has been identified as having an AEC. It will then consider the measures that may be taken to prevent or limit this conduct and the effectiveness and costs of these measures. 51. As an example of the types of consideration relevant to this approach, the use of long-term and/or exclusive contracts by a firm with significant market power may create a barrier to entry or expansion. However, if, in the relevant market, firms need to invest heavily to acquire new customers (for example, by investing in new facilities or systems) requiring a firm with significant market power to have contracts that are short term in nature may generate distortion risks as this could reduce incentives to compete for new contracts if firms do not have sufficient opportunity to recoup their initial investment. In implementing a constraint on the use of long-term contracts, the CC will therefore seek an appropriate balance between facilitating switching and permitting sufficient incentives to compete for new contracts. 52. Likewise, selective discounting or price discrimination by a firm with market power can also have the effect of creating barriers to entry or expansion when used systematically to reduce prices to particular customers that are more likely to switch to other suppliers.24 Measures to restrict selective discounting or price discrimination may therefore sometimes be necessary to address an AEC. However, measures restricting selective discounting or price discrimination may themselves generate significant distortion risk by adversely affecting the competitive dynamics of a market if maintained in the long term. They may therefore be most appropriate as a transitional measure until other sources of competition develop. 53. The CC will have particular regard to avoiding circumvention risk in implementing measures limiting the behaviour of firms with significant market power that has been found to prevent, distort or restrict competition. This is because firms with significant market power may readily evolve new forms of behaviour to replace prohibited or restricted conduct. Market-wide measures to reduce barriers to entry, expansion and switching 54. Market-opening measures may also be applied where incumbency advantages and other barriers to entry or switching have been found to prevent, restrict or distort competition. In this type of situation, market-opening measures to address these features may be applied to a market as a whole or, if this is not necessary and/or practicable, to the largest suppliers within the market. 55. The selection and design of these measures will depend critically on the specific features that have been identified as preventing, restricting or distorting competition. The types of measures that might be considered by the CC include: (a) measures to address barriers to switching; and (b) measures to reduce incumbency advantages and other barriers to entry and expansion. 56. In some markets, customers may be put off switching suppliers by a perception that switching is costly, complex, time consuming and/or risky. This perception may be grounded in customers' own experience. Where barriers to switching have been identified as causing competition problems, measures may be introduced to make it easier for customers to switch.25 For example, the CC may introduce obligations on a customer's existing supplier to cooperate with the proposed new supplier to ensure that costs and disruption to customers are minimized. Generally a new supplier will have significant incentives to make the switching process as easy as possible for the customer and will not normally require corresponding obligations. 57. Another factor that can deter customers from switching is if an important attribute of their current service is not transferable (or 'portable') from one provider to another and this leads them to remain loyal to their current supplier. For example, customers may wish to retain their existing telephone number if they change suppliers and may be deterred from doing so if this were not possible. Interventions to increase the portability of product attributes are most likely to be beneficial when the attribute that customers value is easily identifiable and the ownership rights of the attribute are easily transferable to rival firms or customers. In assessing remedies of this type, the CC is likely to evaluate the extent of any material benefits to customers associated with non-portability such as, for example, being able to identify the network to which a call is being made. 58. Remedies may also be introduced to address competition problems in markets where some existing providers have significant incumbency advantages over other providers (eg potential entrants), which are found to act as a barrier to entry and/or expansion. In some cases, 'incumbency advantages' may result from good com- mercial decisions made in the past (eg to invest in and patent a successful new technology) and interventions to overcome these sources of competitive advantage may risk undermining dynamic incentives to invest and innovate. In other situations the source of incumbency advantages may result from firms having preferential access to key resources, information or customers and it may be possible to intervene to promote competition without adversely affecting dynamic incentives.26 59. A further potential source of incumbency advantage, which may sometimes require intervention, is the 'point-of-sale advantage'. This occurs when a particular supplier has systematically better access to customers than potential rivals. A range of possible approaches might be taken to remedying competition problems resulting from a point-of-sale advantage. For example: - customers may be encouraged to search for alternatives (eg through informational remedies) before they reach a particular point of sale; - providers who enjoy a point-of-sale advantage may be prohibited from completing a sale until a customer has an opportunity to shop around;27 or 28 - providers who enjoy a point-of-sale advantage may be required to offer customers a choice of products at the point of sale. 29 60. In considering such alternatives, the CC will consider the effectiveness and proportionality of different approaches, for example their impact on the behaviour of customers and suppliers as well as whether there are benefits to customers associated with purchasing a product at a particular point of sale. ## Information Remedies 61. Informational remedies can be used to address competition problems that are caused by shortfalls in the information that customers have to enable them to make informed purchasing or switching decisions. Informational remedies can lead to changes in customer behaviour, for example by reducing search costs, increasing customers' awareness of alternatives and making it easier for customers to make comparisons between products when making an initial purchase or when switching suppliers. Informational remedies can also lead to changes in suppliers' behaviour— for example, suppliers may improve their offering, in order that their products appear attractive in terms of the information that customers receive. Information remedies may also facilitate new entry, if a lack of awareness by customers of alternatives was a factor that was restricting entry.30 31 62. The CC has introduced informational remedies in six market investigations completed to date (April 2013) under the Act, as well as in complex monopoly investigations under the Fair Trading Act 1973, such as *Extended Warranties*.32 Informational remedies put in place by the CC include: (a) obliging firms to submit information about their products for publication on price comparisons sites (eg Home Credit, PPI); (*eg PPI* single-premium prohibition); (b) standardization of pricing structures33 (c) mandatory disclosure of price and other key messages at the point of sale and in marketing materials (eg *Extended Warranties, Northern Irish personal banking*); (d) requirement to offer written quotations that remain valid for a fixed period (eg Extended Warranties, PPI); (e) requirement to provide information to existing customers in regular statements (eg Store Cards, *Northern Irish personal banking, PPI*); (f) requirements to provide information to customers about their rights to switch and the switching process (LPG, Northern Irish personal banking, PPI); (g) requirements to provide or extend 'cooling-off' periods (eg *Extended Warranties*); and (h) requirements to provide financial information underpinning the pricing of products and services to potential franchise operators (eg *ROSCOs*). 63. The CC's starting point for the selection of appropriate informational remedies will generally be the identification of the particular barrier to search or other information shortfall which is causing the AEC. This will help identify the information or message that needs to be communicated to customers: for example, if switching is suppressed because many customers have a mistaken belief that they are unable to switch suppliers, then an informational remedy could focus on correcting this misperception. 64. The CC will also consider how information may best be communicated to customers (eg via a website, through companies' marketing material, or by periodic statements to customers). The choice between these options may depend on a number of factors, including: (a) The ways in which customers currently obtain information about the product. It may be more practicable to introduce informational remedies that build on existing sources of information used by customers.34 (b) Customers' ability to access particular information channels. For example, the level of Internet access among a customer base is likely to be relevant to consideration of whether to require firms to disclose prices on a price-comparison website. (c) The nature of the information to be provided to customers. For example, the CC will generally consider whether information needs to be tailored to individual customers (eg via a customer statement) or whether a common message needs to be communicated to all customers (eg in marketing materials).35 36 65. Any obligation to provide information to customers will usually fall on the providers of the product under investigation. If information is to be provided using a medium over which providers have control, the CC may find it necessary to specify in some detail what information is to be provided and how. This is particularly likely to be the case if: 37 or (a) the disclosure is intended to help customers make comparisons between providers and a standard format for disclosure will help achieve this objective; (b) providers have incentives to conceal or marginalize information that presents them in an unfavourable light or which encourages their customers to switch or shop around. 66. The CC will also have regard to the potential benefits of taking a less prescriptive approach. The cost to firms of complying with informational remedies will generally be lower if they have some flexibility as to how they meet their requirements. It may also be necessary to allow some flexibility, in order to 'future proof' the remedy, so that it is still effective in relation to new or unusual situations or products. 67. In considering the design of informational remedies, the CC will generally be mindful of how the remedy is likely to interact with existing obligations on firms relating to information provision. For example, the content of advertisements may already be regulated (as was the case in *Home Credit*) or firms may already be required to give various disclosures to customers at the point of sale (as was the case in PPI). The CC will look, where possible, to exploit positive synergies between existing regulations and CC proposed remedies.38 It may sometimes be possible to implement informational remedies by building on existing mechanisms for communication with customers. Where this is the case, this may be a lower cost option than requiring the establishment of a new form of communication.39 68. In specifying information remedies, the CC will look to ensure that information is provided at a time that the recipient can make use of it. For example, informational remedies that are intended to help customers search the market and compare products will tend to be most effective when customers see this information *before* they have made their main purchase decision. So, for example, providing price and product information in writing after a sale has been concluded—while sometimes required for consumer protection—may only have a limited impact on search behaviour.40 41 69. Informational remedies that are intended to facilitate switching will tend to be most effective if they are targeted at those customers who are able to switch, at a time when they are likely to be interested in switching (eg on invoices or statements setting out how much they have paid over a period). 42 70. The CC may consider whether introducing an information remedy might have the unintended consequence of facilitating coordination between suppliers. As not all markets are conducive to coordination and as suppliers will generally have better information than customers about the prices charged by their competitors, this is most likely to be a material risk if the conditions for coordination are met and if prices are opaque to competitors in the absence of the remedy (eg because prices are subject to individually negotiated discounts). 71. The CC will consider carrying out specific customer research into informational remedies (or 'road-testing') before they are put in place. 43 Road-testing may be carried out during a market investigation to inform choices between alternative remedy options and the design of individual options. The CC has also carried out road-testing after publication of the CC's final report, to fine-tune the detail of particular remedies prior to final implementation.44 ## Restraining The Impact Of Vertical Relationships 72. Competition problems can sometimes arise where individual firms are active at different levels of the supply chain of particular goods or services (vertical integration). Similar problems can arise from contractual arrangements between firms active at different levels of the supply chain (vertical arrangements). Where a party has significant market power at one or more levels of the supply chain, vertical integration and/or vertical arrangements (collectively, vertical relationships) may contribute to an AEC, typically through the firm's incentive and ability to disadvantage competitors by foreclosing access to key inputs, facilities or customers and/or exploiting access to confidential information. 73. For example, if, as illustrated below, the manufacturer (Compco) of most of a key industry component also owned a major user of this component (Prodco1) then the ability of other users (Prodco2 and Prodco3) to compete could be disadvantaged by the combined entity through restricting supply of this component to Prodco2 and Prodco3 or making use of information concerning component orders by Prodco2 and Prodco3. Source: CC. 74. An AEC resulting from vertical relationships might be remedied by structural measures. Such measures might involve vertical separation (eg requiring divestiture of ProdCo1),45 but could also involve reducing the significant market power that the combined entity has at the critical stage of the supply chain (eg partial divestiture of Compco). 75. If vertical relationships produce substantial RCBs that would be largely reduced by structural measures, or if divestiture is otherwise not appropriate or feasible, then behavioural measures may be selected by the CC that enable continued access to necessary products or facilities on appropriate terms and/or measures that prevent the combined entity exploiting privileged access to information. ## Access Remedies 76. Access remedies seek to address competition problems resulting from vertical relationships by enabling competitors to have access on appropriate terms to the products and facilities of a combined entity that they require to be an effective competitor. 77. An access remedy will normally need to specify an access commitment by the firm concerned to third parties in sufficient detail so that third parties and monitoring agencies can enforce the commitment effectively. This will include details of the product or facility to be provided, including quality and technical parameters, and the terms of supply of the product or facility, including service levels and the basis of pricing. The latter may be particularly complex and may be subject to some of the same issues that are encountered with price caps, as discussed in paragraphs 90 to 93. If the access commitment is not specified or monitored in sufficient detail then the measure may be vulnerable to specification risk and the combined entity may be able to avoid its obligations readily. In such circumstances the CC may need to consider alternative forms of remedy (eg divestiture) that are likely to be more effective. 78. To overcome specification risk, the CC will also generally require that an access remedy should make explicit provision for accommodating future changes, for example, in product specifications or supply arrangements. Where a market is likely to be subject to frequent technological change or other wide-ranging market developments, there is likely to be a significant risk that an access remedy will become ineffective if the terms of the access commitment do not accommodate these changes. However, significant technological change might also reduce the market power that results in the AEC (eg if—see Figure 1—effective substitutes are developed for the component supplied by Compco). 79. In some supply arrangements, certain factors that are not easily specified may be particularly important for competitive access, for example quality of product support, priority for system upgrades, and quality of management assigned to a customer's account. Such factors may result in 'soft biases' in access to supply that may generate significant circumvention risk and may significantly undermine the purpose and suitability of an access remedy.46 80. In certain circumstances it may be possible to simplify the specification of an access remedy by obliging the combined entity to supply a particular product on FRND terms where supplies to external customers are provided on the same or similar terms as apply to its own businesses (see paragraph 40). For this to be effective, the nature of FRND terms must deal adequately with the circumstances of external customers and must be transparent to customers and monitoring agencies in sufficient detail to enable effective enforcement. 81. The use of FRND terms may still leave competitors vulnerable to a margin squeeze by the combined entity as it may have an incentive to charge all downstream businesses, including its own, a uniformly high price since reduced profitability in its downstream business can be offset by higher profitability in its upstream business. The CC may therefore require that use of FRND terms is accompanied by provisions to protect against a margin squeeze (eg submission of regular reports demonstrating full cost recovery in the downstream business). 82. Where it is necessary to preserve access to a key facility owned or controlled by a vertically integrated company and the usage and capacity of the facility is readily assessed, the CC may determine that the most practical and effective means of providing access to competitors is to cap usage of the facility by the combined entity and require it to auction remaining capacity to third parties.47 This would be effectively a form of 'virtual divestiture' as considered in paragraph . 14 ## 'Firewall' Measures 83. 'Firewall' measures48 seek to prevent a vertically integrated company from accessing and using privileged information generated by competitors' use of the company's facilities or products. For example, in Figure 1, in the absence of firewall provisions, Prodco1 may be able to exploit privileged information regarding the orders and deliveries of key components from Compco to Prodco2 and Prodco3. 84. Firewall measures prevent access to privileged information by effectively insulating the firm or division generating the information from other group companies. This is generally achieved by restricting information flows and use of shared services, physically separating premises and staff, and regulating transfers of management and any permitted interactions between relevant staff.49 85. To ensure effective compliance with firewall provisions, the relevant firm will normally need to commit significant resources to educating staff about the requirements of the measures and supporting the measures with disciplinary procedures and independent monitoring. ## Controlling Outcomes 86. Remedies that control or restrict the outcomes of business processes, such as price caps, supply commitments and service level agreements, seek to prevent firms from exercising market power. As such, these remedies seek to restrict the customer detriment arising from an AEC, rather than addressing its cause. 87. In order to overcome specification risk, remedies that control outcomes normally need to specify in significant detail the products or services that are subject to control and the basis of the control, for example, the application of price indices to a price cap. The remedy will generally also need to specify how the control will deal with changes, such as the introduction of new products. 88. Measures to control outcomes are often used in regulated sectors, where it may not be feasible to introduce effective competition. The introduction of such measures is also a potential outcome of market investigations, particularly where it is not possible to identify effective ways of addressing the causes of the AEC or where competitionenhancing measures are likely to take a long time to remove the customer detriment that results from the AEC. However, such measures are vulnerable to the main risks associated with behavioural remedies (see paragraph 40) and this can have a negative impact on their effectiveness and cost. Specifically: (a) Defining appropriate parameters for the control measure—for example, the level of a price cap—may be complex and, in some cases impractical, and the measure may therefore be vulnerable to specification risks. This is especially likely where any of the following conditions apply: (i) Pricing in the relevant market is naturally volatile, for example because of variability in input costs. (ii) Products or services are differentiated rather than homogeneous; this may increase the complexity of any control in order to capture adequately the diversity of products offer. (iii) Prices are individually negotiated, which may also increase the complexity of any control measure. (iv) Supply arrangements and products are subject to significant ongoing change, which require the control measure to change to reflect new developments. (b) This class of remedy directly overrides market signals with the result that it may generate distortion risks over time that increase the effective cost of the remedy or reduce its effectiveness. For example, a supply commitment for a particular product may discourage product innovation. While it may sometimes be possible to design measures to minimize distortion risk (sometimes referred to as 'incentive regulation') this may be at the expense of increasing the complexity of the control. (c) The control may be vulnerable to circumvention risks. For example, a price cap may be circumvented by a firm reducing the quality of controlled products or restricting the supply of controlled products. It may be sometimes possible to add preventative provisions to reduce the risk of circumvention, though this may be at the expense of increasing the complexity of the control. (d) Monitoring and enforcement may be costly and intrusive and, in the absence of an industry-specific adjudicator or regulator,50 may lack effectiveness, especially where the form of remedy is complex. 51 89. In view of these risks the CC will not generally use remedies that control outcomes unless other, more effective, remedies are not feasible or appropriate. In addition, where this class of remedy is employed, it is most likely to be used on a temporary basis unless there is no alternative to a continuing regulatory solution. ## Price Caps 90. Price caps are likely to be the most common form of measure for controlling outcomes and illustrate many of the issues outlined above. 91. Different approaches may be adopted to defining the products and prices to be controlled depending on the circumstances of the case: (a) Prices of all affected products may be individually capped. This may be impractical where a large number of products are involved and may be inflexible in dealing with product changes.52 53 (b) The average price of a basket of products may be capped. This allows greater flexibility in taking account of shifts in demand between products but the weighting of the constituents of the basket may be problematic and subject to distortion, for example, if revenue-weighting is used and the firm introduces a number of low-cost product variants. (c) The price cap may apply to key benchmark products. This approach could greatly simplify monitoring and compliance but is only likely to be effective if a few key products are likely to continue to account for a large proportion of sales and the pricing of other products is expected to remain closely related to the benchmark products. (d) The price cap may be to particular product terms (eg 'hidden charges'). Again, this approach could simplify monitoring and compliance and may increase the overall level of price transparency for customers, though it may result in a 'waterbed effect' whereby other charges increase.54 92. The CC will seek a basis for the price cap which will restrict the extent to which a firm's market power is reflected in prices. The basis of a price cap may take a variety of forms: (a) Prices may be benchmarked to the prices of products in analogous markets that are determined by competition. In practice, this may only be feasible in limited circumstances due to the lack of an analogous market. (b) Prices may be determined on the basis of input cost data and an approved return on capital. This resembles the approach adopted by many sectoral regulators but generally requires a highly resource-intensive regulatory process backed by extensive information-gathering and enforcement powers to be effective. (c) A hybrid approach may be taken whereby an initial price reduction is determined on the basis of input cost data and an approved return on capital, with subsequent changes to the level of the price cap being updated by reference to an index that is representative of input cost changes after incorporating current productivity gains.55 The CC will wish to use an index which has robust data sources which cannot be influenced by the parties subject to the price control. Use of such an index may provide a broad approximation to a competitive price outcome in the short term but is at risk of departing significantly from such an outcome in the medium to long term. 93. The CC will generally require that price caps are accompanied by measures to prevent circumvention risk that may arise, for example, through the merged entity restricting the supply or service levels of price-controlled products or reducing product quality. ## Section 3: Recommendations 94. The CC can decide to make recommendations to others, either on their own or in combination with other measures as part of a solution to an AEC. The most common instances where the CC is likely to use recommendations are where it does not have jurisdiction to implement undertakings or orders directly, for instance where the area concerned is governed by a regulator or government department. Recommendations may also be included as a 'fallback' remedy, if it is uncertain whether the CC will be able to achieve its preferred remedy itself—for example, if this depends on parties being prepared to offer satisfactory undertakings.56 95. Recommendations will be directed to the party that is best able to implement the necessary action. It will, of course, be for the person to whom a recommendation is addressed to decide whether to act on the recommendation. The Government has made a commitment to give a public response to any recommendation made to it within 90 days of the publication of a CC report. In its response, the Government will set out where it does or does not propose to make changes in light of the report, or where it proposes to consult on options. The Government will take into account all public policy and welfare considerations, including considerations of Better Regulation, in making its assessment. 96. The CC has made recommendations in five market investigations to report to date (April 2013)—Home Credit, ROSCOs, PPI, Groceries, *BAA Airports*. Recommendations have been used to address a diverse range of market features and have had structural and behavioural elements, for example: (a) Improvements to the information provided to customers. For example, in Home Credit, the CC made a recommendation to BIS to require additional information on the Annual Statement that already had to be produced by lenders subject to the Consumer Credit Act. (b) Changes to the policy and regulatory framework applying to a market. In BAA Airports, the CC made recommendations to the Department for Transport (DfT) and CAA about future airport regulation and airports policy. (c) Changes to the operation of rail franchising. In *ROSCO*s, the CC made recommendations to the DfT and to Transport Scotland about the operation of the rail franchise system, for example the introduction of longer rail franchise periods. (d) Changes to the operation of the planning regime. In *Groceries*, one element of the remedies package was a recommendation to the Department for Communities and Local Government (CLG) that a competition test for grocery store developments should be introduced into the planning system. 97. The fact that recommendations are not binding on the party to which they are addressed represents an intrinsic risk to their effectiveness as a remedy. A recommendation may not be accepted, may not be implemented in a way that is consistent with the CC's intentions, or may become redundant following a change of policy. There may be a risk to the effectiveness of a wider package of remedies, if the success of other measures in the package is dependent on a recommendation being followed. 98. In evaluating the effectiveness of a recommendation as a potential remedy, the CC will form a view on the likelihood that the recommendation will be acted on and the timescale over which this might be expected to occur. In reaching this view, the CC will have regard both to the stated policy of the body to which the recommendation is to be directed and to the possibility that that stated policy may change, either in light of the CC's recommendation or subsequent events. 99. Before making a recommendation, the CC will consult with the body to which the recommendation may be directed as well as parties likely to be affected by it. This will enable the CC to understand the benefits and risks of implementing the recommendation, to inform decisions about the specification of any recommendation, as well as informing the CC's judgement about the likelihood of the recommendation being accepted. 100. When considering the specification of a recommendation, the CC will normally consider a range of factors including: (a) what change is required to remove or reduce the obstacle to competition that has been identified; (b) who is best placed to take the action necessary to effect the necessary change; (c) how that change might be best achieved by the party to which the recommendation is addressed; and (d) the likelihood of a recommendation being implemented, the timescale within this would happen under different assumptions and the likelihood that change, if implemented, would be sustained. 101. In relation to these factors, the CC will have regard to the degree of complexity and the number of institutions involved in making the change. Recommendations that are relatively straightforward to specify and to introduce are generally more likely to be implemented than recommendations which are more complex or which require closely coordinated action by a large number of bodies. 102. There may sometimes be a trade-off between these factors. For example, the ideal outcome from a competition perspective might be very difficult to achieve in a reasonable timescale, whereas it may be possible to achieve a material improvement in competition by means of a recommendation that can be implemented more quickly. In such circumstances, the CC will weigh up the relative merits of increased certainty of implementation against the possibility of achieving a better outcome, but with less certainty or over a longer timescale. www.competition-commission.org.uk
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## Cataloguing Standards For A2A Descriptive Standards The General International Standard for Archival Description, ISAD(G), 2nd edition, Ottawa, 2000, provides principles of multi-level description, definitions and rules for the application of elements of description and a proposed minimum set of data elements for international data exchange. The International Standard for Archival Authority Records (Corporate, Personal and Family), ISAAR (CPF), Ottawa, 1996, gives general rules for the establishment of archival authority records that describe corporate bodies, persons and families named as creators in finding aids. The National Council on Archives Rules for the Construction of Personal, Place and Corporate Names, NCA Rules, London, 1997, give precise rules for the structure and content of authority records for personal, place and corporate names when used as access points in archival description, thus ensuring consistency and facilitating data exchange. Long Term Intentions The aim of the National Archives Network must be the delivery of consistent and appropriate archival descriptions and shared authority data. To reap the full benefits of retrieval and information exchange archivally and across domains we must, wherever possible, achieve full ISAD(G) conformity supported by ISAAR(CPF) compliant authority records contributing to National Name Authority Files. Such conformity, where it already exists, will be accommodated immediately in the network. However it is recognised that individual repositories at present catalogue to a range of standards, that all are likely to have legacy finding aids that bear little obvious relationship to modern standards, that most are likely to have cataloguing backlogs and that all are very hard pressed. For all these reasons it is appropriate to plan for the minimum conformity necessary to achieve our common goals and to recognise that some aspects of conformity may more readily be put in place after retroconversion to electronic form than before. Proposed Rules for Minimum Conformity 1. That we all produce multi-level archival description in accordance with ISAD(G)'s basic four rules: - describe from the general to the specific - provide information relevant to the level of description - link each description to its next higher unit of description - avoid redundancy of information in hierarchically related archival descriptions. 2. Local variations in naming levels of description will of course continue but we shall all abide by the common ISAD(G) terminology of: Fonds Sub-fonds } Series } with further subs as required Sub-series } File Item for data exchange purposes. 3. We shall identify those levels used in our archival descriptions according to the definitions laid out in ISAD(G)'s glossary of terms: Fonds: the whole of the documents, regardless of form or medium, organically created and/or accumulated and used by a particular person, family or corporate body in the course of that creator's activities and functions. Sub-fonds: a sub-division of a fonds containing a body of related documents corresponding to administrative sub-divisions in the originating agency or organisation or, when that is not possible, to geographical, chronological, functional or similar groupings of the material itself. Series: documents arranged in a filing system or maintained as a unit because they result from the same accumulation or filing process, or the same activity; have a particular form, or because of some other relationship arising out of their creation, receipt or use. File: an organised unit of documents grouped together either for current use by the creator or n the process of archival arrangement because they relate to the same subject, activity or transaction. A file is usually the basic unit within a record series. Item: the smallest intellectually indivisible archival unit, eg a letter, memorandum, report, photograph, sound recording. Subgroups: when the creating body has a complex hierarchical structure each subgroup (sub-fonds, sub-series) has as many subordinate subgroups (eg sub-sub-series) as are necessary to reflect the levels of the hierarchical structure of the primary subordinate administrative unit. 4. The highest level of entry in any archival description offered to the network will comprise, at a minimum, the data elements considered essential by ISAD(G) for international data exchange, supplemented by those submitted as equally essential by the Society of Archivists and/or the Public Record Office when its review took place in September 1998: Reference code Title Creator(s) Abstract Creation dates Extent and form Access conditions Level of description 5. That at file level reference code, title or abstract, creation dates and level of description shall be mandatory. 6. That level of description and at least one of the data elements named at 4. above be used at every level of description. 7. That the data elements defined as mandatory for the top level of description shall be employed thus: Reference code; country code as specified in ISO 3166 followed by repository code as specified by HMC followed by local repository specific code. Title: a formal or given title that encompasses all the records being described. Creator(s): individual name(s) of the organisation(s) or individual(s) responsible for creating and accumulating the records being described, formulated according to the NCA Rules. Abstract: a brief summary of the scope and content of the material being described. Creation dates: the first and last date(s) of creation of the records being described (not predominant dates, not accumulation dates and not dates of originals if those being described are copies). Extent: the number of records (or, at fonds level, the number of series) being described. and Form: the broad physical form(s) of the records being described (not record type). If appropriate at fonds level broad physical form can be replaced by series (thus, eg, 36 series rather than 10,333 files, volumes and discs). Access conditions: any conditions that restrict or affect access to the records being described (not conditions that restrict use of the records once access has been gained). Level of description: the hierarchical level, in ISAD(G) terminology, of the material being described. 8. That corporate and personal and family names, when included in archival descriptions as creator(s), immediate source of acquisition, place of deposit, location of originals or as access points, and that place names, when included as access points, shall be formulated according to the NCA Rules (the NCA Rules themselves are about to be reviewed with the aim of reconciling differences between them and AACR2, 1999 revision). 9. To ensure that the names formulated under 8. above shall form the basis of/conform to authority records making up National Name Authority Files, that the type of authority record each one is shall be noted together with the country code as specified in ISO 3166 and the repository code as specified by the HMC. 10. That subject terms when used as access points shall, whenever a potential match is found, be formulated in accordance with the UNESCO Thesaurus.
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# Country Programme Evaluation ## Afghanistan Jon Bennett (Team Leader) Jane Alexander, Douglas Saltmarshe, Rachel Phillipson, Peter Marsden ## Department For International **Development** Evaluation Report Ev696 # Country Programme **Evaluation** Afghanistan Jon Bennett (Team **Leader)** Jane Alexander, Douglas Saltmarshe, Rachel Phillipson, Peter **Marsden** May 2009 ## Preface The evaluation of DFID's country programme in Afghanistan is one of a series commissioned by DFID's Evaluation Department. The studies are intended to improve performance, contribute to lesson learning and inform the development of future strategy at country level. Collectively the CPEs are important in terms of DFID's corporate accountability and enable wider lessons across the organisation to be identified and shared. This evaluation was carried out by a team of independent international consultants led by ITAD Ltd. The process was managed by Kerstin Hinds, Lynne Henderson and Karen Kiernan of Evaluation Department (EvD). The success of the Evaluation is due to many people and EvD would like to acknowledge the contribution made by the evaluation team itself and thank DFID Afghanistan staff and development partners who engaged with the study. The evaluation focused on DFID's programme during the period 2002 - December 2007, with updates provided for 2008. The evaluation was conducted in 2008, and included a one week inception phase carried out by EvD and Jon Bennett, the ITAD team leader for this CPE, and three weeks of fieldwork in London, Kabul and Lashkar Gah (Helmand Province) carried out by the consultancy team. In writing this report, the evaluation team has - at our request - not focussed on UK inter-departmental programmes. For the future, we think it would be worth trying to develop a cross-Whitehall approach for some of our country evaluations. We have done this in the past on our policy related evaluations, for example on HIV and on the conflict pools. It adds complexity to the process and requires the support of a wider range of stakeholders at an early stage, but it would allow us to say more about policy coherence in international development across government. We will explore this further with UK government partners as part of implementing DFID's new evaluation policy. In accordance with EvD policy, considerable emphasis was placed on involving the country office staff during the evaluation process and on communicating findings. Despite this involvement, the country office does not necessarily agree with all the findings of the CPE; the report reflects the views of the independent consultants, and the DFID office's 'management response' can be found at the end of this report. EvD is encouraged that DFID Afghanistan has been able to use the recommendations of the CPE to inform development of its new country plan. We will be following up on the recommendations to ensure that DFID, in Afghanistan and Corporate Divisions, does give them due consideration. Nick York Head of Evaluation Department ## Acknowledgements The team is indebted to all those who generously gave their time and expertise to contribute to the richness of the information gathered. In the UK, we particularly thank Kerstin Hinds and Lynne Henderson at DFID's Evaluation Department for steering the process; and, in Afghanistan, Marshall Elliot and his team, notably Sabir Naziri. Corrie Bell assisted with research and graphs and the team's internal quality assurance was done by Hilary Thornton. Full responsibility for the text of this report rests with the authors. In common with all evaluation reports commissioned by DFID's Evaluation Department, the views contained in this report do not necessarily represent those of DFID or of the people consulted. ## Abbreviations | AALP | Afghan Alternative Livelihoods Project | |------------|----------------------------------------------------------| | ACBAR | Agency Coordinating Body for Afghan Relief | | ACSF | Afghan Civil Society Forum | | ADB | Asian Development Bank | | ADIDU | Afghan Drugs Inter-Departmental Unit (UK) | | AIA | Afghanistan Interim Authority | | ANDS | Afghanistan National Development Strategy | | ARDS | Afghanistan Reconstruction Development Services | | AREU | Afghanistan Research and Evaluation Unit | | ARTF | Afghanistan Reconstruction Trust Fund | | ASP | Afghanistan Stabilisation Programme (DFID) | | CDC | Community Development Council | | CHAD | Conflict and Humanitarian Affairs Department (DFID) | | CN | Counter-Narcotics | | CNTF | Counter-Narcotics Trust Fund | | COIN | Counter-Insurgency | | CPE | Country Programme Evaluation (DFID) | | CSO | Civil Society Organisation | | CWA | Consent Winning Activities | | DAC | Development Assistance Committee (OECD) | | DFID | Department for International Development | | DFIDA | DFID Afghanistan | | DPA | Development Partnership Arrangement (UK) | | EC | European Commission | | EUSR | European Union Special Representative | | EvD | Evaluation Department of DFID | | FCO | Foreign & Commonwealth Office | | GCPP | Global Conflict Prevention Pool | | GDP | Gross Domestic Product | | GoA | Government of Afghanistan | | GOF | Global Opportunity Fund | | IDP | Internally Displaced Person | | IDLG | Independent Directorate of Local Governance | | I-ANDS | (Interim) Afghanistan National Development Strategy | | HARDP | Helmand Agriculture and Rural Development Programme | | HLP | Horticulture and Livestock Project | | IARCSC | Independent Administrative Reforms and Civil Service | | Commission | | | IDC | International Development Committee | | IDLG | Independent Directorate of Local Governance | | IMF | International Monetary Fund | | IOM | International Organisation for Migration | | ISAF | International Security Assistance Force | | JCMB | Joint Coordination and Monitoring Board | | MAIL | Ministry of Agriculture, Irrigation and Livestock | | MCN | Ministry of Counter-Narcotics | | MISFA | Microfinance Investment Support Facility for Afghanistan | | MOD | Ministry of Defence (UK) | | MOI | Ministry of Information | ## Abbreviations | MRRD | Ministry of Rural Rehabilitation and Development | |----------------|------------------------------------------------------------------| | NATO | North Atlantic Treaty Organisation | | NDF | National Development Framework | | NEEP | National Emergency Employment Programme | | NGO | Non-Governmental Organisation | | NJP | National Justice Programme | | NPP | National Priority Programme | | NRAP | National Rural Access Programme | | NSID | National Security, International Relations and Development | | NSP | National Solidarity Programme | | ODA | Overseas Development Assistance | | OECD | Organisation for Economic Cooperation and Development | | PAM | Performance Assessment Framework | | PAR | Public Administration Reform | | PFM | Public Finance Management | | PRBS | Poverty Reduction Budget Support | | PRR | Priority Restructuring and Reform | | PRT | Provincial Reconstruction Team | | PRSP | Poverty Reduction Strategy Paper | | PSD | Private Sector Development | | QIP | Quick Impact Project | | RALF | Research in Alternative Livelihoods Fund | | SAF | Stabilisation Aid Fund | | SAIC | Staff Appointed in Country | | SCNIAP | Strengthening Counter Narcotics Institutions Afghanistan | | Project (DFID) | | | SEPAP | Second Public Administration Programme (DFID) | | SSPSRL | Support for Strategic Planning for Sustainable Rural Livelihoods | | SSR | Security Sector Reform | | SU | Stabilisation Unit (UK) | | TA | Technical Assistance | | TCAP | Transitional Country Assistance Programme (DFID) | | TSP | Target Strategy Paper | | UN | United Nations | | UNAMA | United Nations Assistance Mission to Afghanistan | | UNDP | United Nations Development Programme | | UNHCR | United Nations High Commissioner for Refugees | | USAID | United States Agency for International Development | | WB | World Bank | | WFP | World Food Programme | ## Executive Summary S1 This report is an evaluation of the Department for International Development's (DFID) country programme in Afghanistan from January 2002 to December 2007, commissioned by the Evaluation Department of DFID (EvD) and undertaken by ITAD Limited, an independent consultancy company. The team spent two weeks in London interviewing key stakeholders in Whitehall, and then undertook fieldwork in Kabul and Lashkar Gah (Helmand Province) during April 2008, with these locations reflecting the focus of DFID's Afghanistan programme. This report was then prepared and subject to review and comment by EvD and DFID Afghanistan. S2 The evaluation period is 2002–2007, with updates provided for 2008. It covers (i) the final year of humanitarian assistance led by DFID's Conflict and Humanitarian Affairs Department (CHAD), (ii) the Transitional Country Assistance Plan (TCAP) and (iii) the 2005/6 Interim Strategy for Afghanistan, which was subsequently extended to 2008. S3 Afghanistan is a uniquely complex country, socially and politically. The evaluation notes the constraints and pressure that DFID staff are under and the high levels of commitment demonstrated throughout the history of the programme. Where the evaluation identifies problems, these should in no way reflect poorly on the professionalism of those involved; rather, it is an opportunity retrospectively to learn from the strengths and weaknesses of DFID's approach to a volatile and intense environment that offers very few easy answers. ## Political And Development Context S4 Afghanistan is a "fragile state", one of the poorest countries in the world, and is off-track on progress towards all the Millennium Development Goals. Since the foreign intervention to replace the Taliban in 2001, there have been some marked improvements in health and education, and 4.8 million refugees have returned to their homes (though just as many have migrated to Iran and Pakistan). By 2008, protracted conflict in many areas, global price rises in wheat (a staple food) and periodic drought meant that periods of extended emergency could be anticipated. S5 Economic growth has settled at around 10% per annum and foreign debts have been cancelled. Domestic revenues are only about 8% of Gross Domestic Product (GDP). By contrast, in 2007 illicit opium comprised 47% of GDP. The poppy sector constitutes the largest source of export earnings; its illegal nature not only implies significant lost tax revenue to government but also breeds lawlessness, which undermines economic confidence and social cohesion. S6 There is visible economic activity and improvement of infrastructure in many parts of the country, yet persistent unemployment and high levels of corruption underline the need for international commitment to long-term, balanced development and good governance in Afghanistan for many years to come. In a rare national opinion survey undertaken in 20081, two-thirds of Afghan respondents gave a positive assessment of the performance of central government, although the proportion of those saying that the government is doing a bad job has almost doubled since 2007. The government's performance is judged most positively with respect to the provision of education and healthcare, but least positively in the economic arena and in combating corruption. S7 Following the defeat of the Taliban government, the December 2001 Bonn Agreement saw a collective determination by donors to lend maximum support to the new interim government. Within three years, there were successful presidential and parliamentary elections - supported by DFID - with a high turnout. Political stability, however, remains precarious. By originating in a foreign military intervention, the state building effort in post-Taliban Afghanistan became perceived by many Afghans as tied to the power of foreign troops and capital. This has challenged the legitimacy of the state and lent credence to the propaganda of the insurgency. Levels of insurgency increased from 2006 onwards. S8 Total annual Overseas Development Assistance (ODA) to Afghanistan more than doubled during the period 2002–2006, from $1.3 billion to just under $3 billion. This brings the total since 2002 to almost $11 billion. Only about one-third of development expenditures are controlled by the Government, with most of USA funds being off-budget. S9 Afghanistan receives a low proportion of aid per capita; due to its poor absorptive capacity, by 2006 the country had spent only 23% of what it had been granted for the development budget since 2001. Moreover, levels of aid effectiveness have drawn some criticism. Recent evidence suggests that for every $100 spent only $20 actually reaches Afghan recipients. Between 15 and 30% of aid money is spent on security for aid agencies, and 85% of products, services and human resources used by agencies are imported and provide few jobs for Afghan workers2. S10 The 2006 London Conference launched the Afghanistan Compact; this and the Interim Afghanistan National Development Strategy (I-ANDS) lays out the framework for international engagement with Afghanistan until 2011 in a number of vital areas: security, governance (including human rights and rule of law), social and economic development and cross-cutting themes such as counter-narcotics (CN), gender equity and anti-corruption. DFID has supported the ANDS process - essentially a Poverty Reduction Strategy Paper (PRSP) for the country - through to its final presentation in 2008. ## The Uk And Dfid In Afghanistan S11 The UK is one of 36 nations involved in Afghanistan since 2001. Its efforts are coordinated by the Foreign and Commonwealth Office (FCO), DFID and the Ministry of Defence (MOD). Aside from a large UK military expenditure, DFID has the biggest civilian expenditure. On conflict prevention, resolution and dialogue all three departments have, until 20083, accessed a common fund: the Global Conflict Prevention Pool (GCPP). The FCO has an additional portfolio through the Global Opportunity Fund (GOF). The MOD and FCO support security sector reform, and the counter-narcotics strategy is led by the Afghan Drugs Inter-Departmental Unit (ADIDU). S12 The UK is the third largest development aid donor to Afghanistan, maintaining about 10% of total ODA since 2003, with just over £100 million per year since 2004/5. The majority of funding has been through central government, notably the Afghan Reconstruction Trust Fund (ARTF), which by early 2008 accounted for 47% of DFID's Afghanistan budget. S13 DFID's assistance since setting up the office in Afghanistan can be traced through four phases: - 2001–2003 Essentially a limited humanitarian effort - funds through United Nations (UN), International Organisation for Migration (IOM), Red Cross and non-governmental organisations (NGOs) - with longer-term commitments foreseen. At the Tokyo donor conference in 2002, DFID pledged £200 million over five years (2002/3–2007/8), part of a wider $4.5 billion pledge made by the international community. - 2003–2005 The Transitional Country Assistance Programme (TCAP) designed as a relatively short-term plan with a long-term strategy, to cover the duration of the Transitional Administration in Afghanistan. It was informed by a government/international agency report 'Securing Afghanistan's future: Accomplishments and the Strategic Path Forward', prepared for the International Conference in Berlin, March 2004. Based on a World Bank assessment that Afghanistan needed $28 billion over seven years, the UK increased the pledge made at Tokyo to at least £500 million over the same five-year period. - 2005–2006 Following national elections, the Interim Strategy for Afghanistan 2005/6, a three-pillar programme - state building, economic management and aid effectiveness, and livelihoods. This built upon government ownership and capacity, with upwards of 70% of DFID funds being channelled through the national budget and national programmes. The ANDS (essentially equivalent to a poverty reduction strategy, though also covering security) was under preparation, and understood by DFID to be the ideal mechanism to provide a necessary strategic framework for the long term. - 2006–2008 The fourth phase of DFID's development strategy was marked by its commitment to the ten-year Development Partnership Arrangement (DPA), under which it announced its commitment to spending £500 million over three years. This phase was characterised by the continuation of the 2005/6 Interim Strategy for Afghanistan coupled with emphasis on supporting the UK's increasing focus on Helmand province. - At the International Conference in Support of Afghanistan (Paris, June 2008), the UK announced an additional £613 million for the period 2008- 2012/13 which was to be channelled through the Afghan Government4. In 2008/09 this included a further £60 million through the Afghanistan Reconstruction Trust Fund (ARTF). S14 By 2007, there were 58 projects in the DFID Afghanistan portfolio with an aggregate value of about £520 million. The programme was dominated by the World Bank managed ARTF - classified as a DFID "project" - with DFID's aggregate contribution towards it totalling £317 million funded through the central Treasury Account in Afghanistan5. Without the ARTF, other "live" programmes had a total value of £201 million, 11 of which were valued at over £5 million. ## Relevance Of Dfid'S Programme S15 The TCAP - and, indeed, the subsequent 2005/6 Interim Strategy - was predicated upon several assumptions: first, that the formal political transition process would result in a stable political settlement; second, that conferring legitimacy on the state means building it from the centre first - with a particular emphasis on economic management - then extending to provincial and local levels; and third, that formal institutions (judicial, legislative, banking, private sector) are the pillars of growth. S16 DFID placed a strong emphasis from the outset on management of the economy. The aim from the start was to create a strong public finance system in order to implement the National Development Framework (NDF) and enable the government of Afghanistan (GoA) to lead the coordination of development activities. The quality of technical assistance (TA) has been high, but there are drawbacks in terms of scope and sustainable results. For example, the "standard package" assistance to the Ministry of Finance has failed to convert ARTF procedures into a regularised budget formulation process at the speed originally envisaged (the closure on the ARTF has been extended twice: from 2006 to 2010 and recently to 2020). S17 DFID's assistance to revenue-raising through taxation has been effective and efficient, but DFID did not articulate the strategic challenge of how to foster a "social contract", a tangible demonstration of representative democracy. If not balanced with clear evidence of benefits elsewhere in the system, taxation alone risks reinforcing public opinions of a predatory state. S18 DFID's state building strategy has had a strong focus on technical assistance and capacity development of formal state institutions, particularly in the executive branch of government. Drawing on its long-standing experience in public administration reform (PAR), DFID has helped achieve initial results in the areas of civil service reform. Until recently, relatively little attention was given to developing a political economy and conflict analysis to underpin the strategic choices made. DFID has given little attention to accountability issues and the demand side of governance, including the monitoring and advocacy role of civil society and other accountability mechanisms. S19 Prior to late 2007, the conflict agenda was pursued primarily through the Global Conflict Prevention Pool (GCPP), which had a global budget of approximately £245 million between 2004/5 and 2006/7. Some 46% of this was allocated to Iraq and Afghanistan, and expenditure on these two countries has dwarfed all other GCPP outlays. In Afghanistan, the share of Security Sector Reform (SSR) expenditure within overall investments has decreased from about £12 million in 2004 to almost zero in 20086. This is regrettable in a country that is in the midst of building a new security sector and is facing multiple challenges relating to SSR. The security sector is the one element of the government's ANDS for which a sectoral strategy is still lacking. S20 In the country as a whole, the UK division of labour, and in particular the FCO lead on rule of law and justice issues, led to a marginalisation of DFID's role on governance, an area in which it has a comparative advantage and experience from other fragile states. Six years on, DFID is now giving renewed attention to the rule of law and justice sector as well as to sub-national governance - an important evolution of its approach to state building since these are major impediments to effective state building in Afghanistan. S21 The objectives of DFID's livelihoods programme are twofold. Firstly, it is to maximise opportunities for rural Afghans to make a legal living; and secondly, through the stability that derives from increased income and employment, to increase confidence in the state. This means tackling key constraints such as access to markets and credit, labour opportunities and training. From 2006, DFID moved from areabased poverty focused programming through NGOs to increased funding of central government programmes, and a consequent change in approach to pro-poor interventions. There was now an emphasis on funding technical assistance (TA) and capacity building within key ministries such as the Ministry of Rural Rehabilitation and Development (MRRD) and the Ministry of Agriculture, Irrigation and Livestock (MAIL) through, for example, the Support for Strategic Planning for Sustainable Rural Livelihoods (SSPSRL) project. Support here was strategically appropriate, given the importance of the agricultural sector in Afghanistan. Likewise, the National Solidarity Programme (NSP), National Emergency Employment Programme (NEEP) and Microfinance Investment Support Facility for Afghanistan (MISFA) have direct links to poverty alleviation. S22 But more upstream programming has consequences, not least the fact that the GoA's capacity at national level is limited. Aside from the issue of geographic focus, DFID had a well-balanced rural sector programme in support of the GoA, which included capacity building of ministries plus a good mix of development, infrastructure, poverty reduction and CN-related projects. However, cutting the Badakhshan programme prevented further learning from an interesting initiative. S23 DFID has a well-established reputation with respect to donor harmonisation and in upholding Paris Declaration principles with government and partners. The early engagement through the ARTF was directly relevant to needs expressed by the Interim Government at that time, and DFID's flexibility and responsiveness were appreciated by government and other donors alike. DFID has conformed well to some of the central tenets of its fragile states policy including long-term engagement, support to donor coordination and the use of innovative aid instruments, although less well in areas such as prioritising governance reforms that will address the causes of fragility. ## Assessing Risks S24 The balance of risks within DFID's Afghanistan portfolio - as assessed in project memoranda and evaluated regularly in output to purpose reviews - moved from low–medium risk in 2004/5 to medium–high risk in 2006/7. This risk inflation has been driven by two factors: firstly, the security situation in Afghanistan; and secondly, the difficulty associated with delivering a well-performing programme given current government capacity constraints in Afghanistan. Programme risk has also been heightened by the political imperative to engage in "difficult" areas. By mid-2007, eight of DFID Afghanistan's 31 live programmes were high risk, with a total value of £110 million, representing 25% of the live portfolio. S25 Where risk analysis has been weak, this has mainly been due to a lack of robust DFID methodology on differentiation of risk types (macro, fiduciary, capacity, conflict); this impedes accurate assessment. Moreover, there has sometimes been a tendency to express existing weaknesses within the Afghanistan government as programme threatening risks within programme design - and later to express this again as a reason why the programme failed to meet expectations. This avoids the need to identify specific mitigation strategies that should be built into the programme to ensure the risk is dealt with. S26 The UK's ten-year Development Partnership Arrangement (DPA) with Afghanistan, signed in 2006, committed DFID to furthering its on-budget support (through the ANDS) with the intention of moving towards Poverty Reduction Budget Support (PRBS) on condition that the appropriate administrative, technical and financial systems could be established to support this. Given the fragmented and uncoordinated nature of international aid to Afghanistan, the declaration was both timely and appropriate. However, DFID and the Afghan government do not have a system in place for mutual review and assessment of the commitments (initially £330 million over three years), although this was specified in the agreement. With 80% of DFID's funding being channelled to the Afghan government, this would seem an important element of risk management, as well as being required by the UK's conditionality policy (2005). ## The Uk And Dfid In Helmand S27 Militarily, the international community moved from peacekeeping to counter-insurgency in 2006; it was at this time that the decision for the UK military to deploy to Helmand was taken. S28 DFID is committed to a "whole of government" approach, recognising the links between political, security and development issues as reflected in the OECD DAC Fragile States Principles (2007). Maintaining the right balance between this commitment and putting into practice a strategy and portfolio has proved to be a significant challenge. DFID was continually under pressure to demonstrate that it was contributing to the Helmand effort both through its contributions to tri-departmental mechanisms, and through its bilateral programme. To some extent this constrained the choices available to DFID and undermined the coherence of its overall strategy. S29 It was some time before the UK Government as a whole had a shared vision over the link between security and development and the means to achieve these goals. Pursuing multiple objectives in Helmand was initially problematic because approaches towards counter-insurgency, stabilisation, counter-narcotics, peace and development were not necessarily mutually reinforcing. S30 DFID's perception of Quick Impact Projects (QIPs) in Helmand as being "rapidly implemented projects that serve as down payments on promises of political and economic progress" was challenged recently by an independent evaluation commissioned by the Stabilisation Unit7. Within the work carried out by the Provincial Reconstruction Team (PRT), (the QIPs in particular), there was dissatisfaction over procurement, construction quality, lack of monitoring and over the role of interpreters. On the positive side, support for police training was well received and DFID support through line ministries (particularly MRRD) was seen as being effective8. S31 Support through the cross-Whitehall GCPP (and subsequently the Stabilisation Aid Fund) provided a funding mechanism that could be used for security spending, including non-ODA spend. In this respect, it protected DFID's bilateral programme budget from the wider security demands of HMG while opening possibilities for innovative, pro-development, approaches to stabilisation. From 2007, pressure on the DFID bilateral programme to divert funds to Helmand started to reduce due to the increased role proposed for the Stabilisation Aid Fund (SAF). ## Effectiveness And Efficiency Of Dfid'S Support S32 Staffing of the DFID office in Kabul was limited by the "light footprint" approach agreed by DFID's top management. This effectively imposed a cap on international staff levels (six) prior to 2006, which meant that the ratio of staff between Kabul and London was 6:9. This was deemed wholly unrealistic by heads of office at that time, given DFID's delivery objectives. Since then staff ratios have improved, but staff pressure to deliver on HMG priorities has been immense. Security constraints have limited engagement with local and provincial government restricting data gathering and personal knowledge of projects. S33 The FCO criticised DFID for failing to ensure sufficiently senior staff were present at Whitehall meetings. The evaluation found this to be the case, particularly during the crucial meetings in 2005/6 over the deployment and scope of work expected of UK departments in Helmand. The evaluation is unable to comment on whether a more regular senior DFID representation would have influenced what was essentially a preordained decision over the deployment. S34 DFID has ensured that thorough independent reviews are carried out for all the large projects in its portfolio, particularly where there have been indications of poor performance. Impact assessment has been difficult, partly due to the weaknesses in project-level results frameworks, but also due to the inherent difficulties of measuring impact in an insecure environment. For example, DFID activities towards developing poverty data sets and strengthening the national statistics function have to date rendered few results. Added to this is the familiar difficulty of measuring impact of capacity building and institutional reform. S35 DFID's performance management is based on the scores given to projects at purpose and output levels. From 2001 to mid-2006, 74% of DFID Afghanistan projects over £1 million were scored "completely" or "largely" successful. This compares well with the DFID average of 61.8% across all fragile states in the same time period. However, given the dominance of a handful of projects (notably the ARTF), these figures should be treated with caution. If one deducts the ARTF in 2006/7, 48% of the total size/value of the "live" (i.e. ongoing) projects was unlikely to achieve set targets. S36 Not surprisingly, smaller projects performed better than the larger more complex government-run National Solidarity Programme (NSP), National Emergency Employment Programme (NEEP) and the National Rural Access Programme (NRAP), but even these have shown solid improvement over the past 12–24 months. S37 Projects under economic management have performed relatively well, notably DFID's timely and effective inputs into the ARTF as the central mechanism for support to the government. The ARTF investment window includes activities in three areas: infrastructure, public sector capacity building and community development. Under the last of these - the sector that has received a majority of funding - are national rural development/service delivery projects such as the National Solidarity Programme (NSP) and Microfinance Investment Support Facility for Afghanistan (MISFA), as well as the provincial Helmand Agriculture and Rural Development Programme (HARDP). These projects would not have been able to get off the ground without DFID's support. Combining core project funding with the use of TA has enabled DFID to maintain flexibility while also providing information to support and influence multilateral agencies. S38 Within the state building portfolio, the consequences of under-staffing have been apparent. Only 25% of projects achieved high score rates (scores of 1 or 2 in output to purpose reviews) from 2002 to 2006. This was skewed by the Afghanistan Stabilisation Programme (ASP) and Strengthening Counter Narcotics in Afghanistan Project (SCNIAP), the two largest but also worst performing programmes. As part of the ASP, the performance of the Provincial Stabilisation Fund was poor, with only a few projects completed and no progress at all in the area of administrative reform. DFID took appropriate steps to end its support to both ASP and SCNIAP. S39 Different choices within given resources could have been made. For example, greater priority could have been given earlier to security and justice work, given that the rule of law sector was consistently highlighted as one of the most critical areas for addressing state fragility, and where progress was sorely lacking. This should arguably have been given priority over support to central government institutions, or to counter-narcotics institution building through SCNIAP, where progress depends on wider reform in the justice sector. S40 Some cross-cutting issues have received relatively little attention in the DFID portfolio. Despite some impressive outputs in the above projects - and notwithstanding the strong gender focus in DFID's support for elections - the overall integration of gender, human rights and social exclusion issues has been weak throughout the portfolio. There is no mention of gender issues or women's rights in the TCAP or Interim Strategy, despite the government's own stated commitments in this area. DFID has, however, made efforts to integrate cross-cutting issues into the ANDS by placing a staff member in the ANDS secretariat since 2006 with this specific brief, though there is little evidence of tangible results. S41 Efforts to institutionalise counter-narcotics as a cross-cutting issue within government have also had little success. The Ministry of Counter Narcotics has no executive power (or money), only advisory responsibilities. It has suffered from the absence of a minister for a period of a year and then the appointment of weak ministers. DFID has demonstrated strong analysis in the sector, but progress on the Counter -Narcotics Trust Fund (CNTF), for example, has had little government buyin. ## Impact And Sustainability S42 DFID is keenly aware of the difficulties of assessing and demonstrating impact in the Afghan context. The lack of good national or provincial data and security constraints on access to beneficiaries (for both DFID staff and partners) impedes the measurement of progress or decision making. DFID's practice of putting its aid funds through common systems adds to the usual problems of attribution in development aid. Evidence of the results of specific inputs in a multi-funded project is therefore often related more to aid effectiveness than to wider developmental impacts. Moreover, in all programmes, security constraints prevent staff monitoring either outputs or impact in any consistent manner. S43 Progress has been made in building up a more professional, merit-based civil service with DFID support. For example, tangible results can be seen from DFID's support to coordination, strengthening the Ministry of Finance and helping create an effective public administration while ensuring all assistance is recorded on budget. Early financial and capacity support to ARTF has been exemplary, demonstrating good practice in relation to the Paris Declaration and principles of aid effectiveness in fragile states. S44 The impact of the ARTF on the government's legitimacy and ability to deliver, particularly outside Kabul, remains open to question. Capacity in the provinces to deliver services has been largely neglected and budget execution has been highly variable. Whereas the Ministry for Reconstruction and Rural Development (MRRD) spent 71% of its development budget in 2005/6, the Ministry of Interior spent only 32%, education 24%, and agriculture 22%. S45 DFID nevertheless has an extremely good track record on aid effectiveness issues in Afghanistan. Pledges have translated to disbursements very quickly, and DFID has provided procurement capacity to facilitate rapid and transparent utilisation of donor resources. Rapid, high-quality, early TA to the telecoms sector contributed to high levels of investment and mobile phone usage. S46 Corruption remains a fundamental challenge. DFID has contributed incremental improvements through, for example, the Tax Administration Reform Project, but the problem is more profound. Justice institutions remain the least developed among formal oversight organisations. S47 The state building portfolio may have focused too much on building technical capacity, primarily in Kabul, while downplaying issues of political legitimacy, especially at the local level. DFID's crucial support to the elections in 2004/5 contributed to the political transition process that was necessary to establish the core institutions of the state. However, sustainable impact is impaired by the inability of the government to establish national unity linked to political settlement; this cannot be addressed by the kind of technical and financial support provided by DFID to date. S48 Public administration reform has been bolstered through the DFID-supported Second Public Administration Programme (SEPAP) project, and DFID has added significant technical value throughout. However, progress towards the objective of improving government capacity at central and local levels with strengthened links between them was limited. Improving government leadership on PAR with increased on-budget donor support has also proved elusive. The World Bank lead in this sector, and its relatively larger resources, brings into question the continuing need for DFID's support to PAR beyond 2008. S49 Nonetheless, there is evidence that the National Solidarity Programme (NSP), to which DFID has contributed substantial funding has contributed to enhancing state legitimacy. To date, the programme had led to the election of over 15,000 Community Development Councils (CDCs), and the financing of over 17,000 projects. $244 million has also been disbursed in grants to the communities9. S50 Opium poppy cultivation in Afghanistan rose for the second successive year in 2007, to 193,000 hectares, driven by growing cultivation in the south, south west, and, to a lesser extent, the east. Cultivation in Helmand rose by 48%. In 2008, the country's overall poppy cultivation fell by 19% to 157,000 hectares, but in Helmand (the single largest producing province) it remained the same as 200710. Many experts suggest caution over attributing this to the counter-narcotics strategies of the international community; the reductions in total cultivation are largely due to economic (high wheat prices) and environmental (drought) factors, and could easily be reversed11. In Afghanistan's 34 provinces, 18 are now poppy free as opposed to just 6 in 200612. But there is an asymmetry between the expectations of donors and government for rapid changes in the opium economy, and the ground reality. Counter-narcotics (CN) efforts are a combination of economic development, provision of social services, and better governance and the rule of law - in other words, massive sustained financial commitment, political vision and stamina13. S51 By its own admission, the UK has had greater success in restructuring the police force and criminal justice institutions around CN than it has in actually reducing production through promoting alternative livelihoods14. The political economy of opium poppy cultivation in Badakhshan15 and Nangarhar provinces16, for instance, shows the contribution to sustained reduction of poppy growing made by combining CN policies implemented by local government with multi-faceted NGO programmes that cover livelihoods, social development, particularly with a focus on women and girls, and capacity building. Programmes such as Afghan Alternative Livelihoods Project (AALP) and Research in Alternative Livelihoods Fund (RALF) have also made valuable contributions to producing alternatives to poppy. S52 Technical Assistance (TA) does not automatically equate to capacity development, even if training is included. Without an explicit analysis of the incentives and disincentives for reform provided by TA, DFID has not been able to weigh up the value-added of TA compared to other aid instruments. Looking at the broader canvas of massive TA inputs by all donors - $1.6 billion since 2002 - the impact has been questioned17. 15 Saltmarshe, D. 'Integrated Rural Rehabilitation to Improve Livelihoods and Curb Poppy Production', evaluation report for DFID, June 2006. 16 Mansfield, D. 'Water Management, Livestock and the Opium Economy: Resurgence and Reductions: Explanations for Changing Levels of Opium Poppy Cultivation in Nangarhar and Ghor in 2006–07', AREU, May 2008. 17 Michailor, S. 'Review of Technical Assistance and Capacity Building in Afghanistan', April 2007. ## Recommendations For Dfid Afghanistan: - Now may be the time to reconsider whether Public Administration Reform (PAR) should be the central plank of DFID's state building programme. It is unclear whether DFID continues to have a comparative advantage on PAR if a strong lead from the World Bank (WB) is in place. DFID should develop a clear analysis and argument for its continued support to PAR if this is to remain central to the state building portfolio. - Significantly greater attention to rule of law and justice is warranted. Support to National Justice Programme (NJP) has been very positive; DFID has a comparative advantage in relation to other donors. Traditional justice systems will need to be considered, though with caution in respect of human rights issues. DFID should draw on its experience in other fragile states. Options to gradually extend the reach of formal systems into communities (e.g. community paralegals) should be considered. - The National Solidarity Programme (NSP) overall is a "high-risk, highreturn" success story. However, the governance dimension of Community Development Councils (CDCs) is complex and NSP has not yet demonstrated its impact on local governance. The future role of CDCs within sub-national governance needs careful consideration, while ensuring that the social capital built up through NSP to date is used effectively. New support for UN Habitat's work on urban CDCs and links with municipalities offers opportunity for learning about their interplay with formal governance structures. DFID should develop a clear strategic view on the role of CDCs in sub-national governance. This needs to be linked to the generation of policy regarding the development of provincial structures: the provincial and district assemblies and the role of line ministries. - DFID has not fully explored the value of engaging more fully with Afghan civil society, including improved relationships with NGOs as intermediaries. More attention should be given to corruption and accountability mechanisms (including the role of NGOs and Civil Society Organisations (CSOs) in monitoring and advocacy). - DFID (and other donors) have not fully used the accumulated expertise NGOs have in maximising farm-related income opportunities, employing a country-wide approach to reduce vulnerabilities to poverty and offering alternatives to narcotics production. DFID should place greater emphasis on the issue of investment in agriculture, including an integrated "value chain" approach to agriculture that addresses issues of land, water, credit management and labour. - Assumptions around gender and human rights, and the corresponding dialogue with Afghans including Afghan women in leadership positions have not been fully explored. This is not about having a new "women's rights" programme, but about ensuring effective integration into future programmes, building on successful examples such as DFID's support to the elections. DFID should seek opportunities to support Afghans to lead appropriate, culturally sensitive approaches to improve the treatment of women in Afghanistan. - The DAC Fragile States Principles could usefully stimulate discussion on the importance of shared analysis among donors of context and causes of fragility; "do no harm" issues in relation to state building; the need for greater attention to social inclusion, gender and human rights issues; and the risks of bilateral aid allocations leading to "pockets of exclusion" within Afghanistan. DFID is already engaged in a useful debate around these principles. DFID should continue to use the principles to further donor dialogue around aid effectiveness issues and challenges in Afghanistan. - The UK's ten-year Development Partnership Arrangement (DPA) with Afghanistan requires a mutual review and assessment of the commitments (initial tranche of £330 million over three years, signed in 2006). DFID should ensure that adequate monitoring and review processes are in place for the DPA in line with similar commitments elsewhere in the world. ## For Dfid Globally: - Understanding the political economy and state building context of fragile states required early investment in robust analysis. DFID Afghanistan undertook such analysis in 2008, but perhaps this should have been earlier. DFID should ensure that programmes are framed within an early understanding of conflict dynamics, state legitimacy and political settlement in advance of more technocratic issues. - The devolution of DFID's offices to country level has consequences and the right balance of staff between London and Afghanistan was not always met. There needs to be greater senior management realism regarding the scale of the challenge - and what DFID needs to deliver effectively - in a highprofile protracted conflict arena. In this regard, DFID should ensure consistent senior management engagement at Whitehall level, and ensure that staff ratios and skill mix between London and the country are sufficient. - TA does not automatically equate to capacity development, even if on-thejob training is included. The transition from multi-donor trust fund to general budget support requires longer-term capacity building. The creation of professional cadres needed by both the public and private sector should involve supporting further education and private professional training bodies in addition to civil service training on the job. - In view of the overwhelming size of the informal sector in developing countries (let alone post-conflict developing countries), private sector development is unlikely to begin in the Ministry of Commerce. On the other hand, as demonstrated by MISFA, rapid development of a small-scale financial sector is possible even in difficult post-conflict conditions. DFID should do more to consolidate and deepen its understanding and experience of private sector development in the particular conditions of post-conflict economies. - The debate over appropriate resources required to meet targets set by framework agreements such as the 2006 Afghanistan Compact has not been effective; thus there has not been a clear understanding among donors of resource levels needed in each sector, and of the relationship between these sectors. For the UK, underpinning all interventions should be a shared crossdepartmental consensus on the scale of investment needed to meet the challenge; this should then inform the influencing strategy pursued by DFID vis-à-vis other donors. - DFID's comparative advantage on governance issues within HMG has not been given sufficient recognition in Afghanistan. DFID should advocate its role on governance, and ensure that the division of labour agreed in future HMG strategies recognises governance as a central element of economic and social development. - The division of labour agreed among donors in Afghanistan was driven largely by political bargaining among donor countries. As a result, the security and justice sector - arguably the most crucial sector - has performed badly. DFID should develop effective ways of communicating lessons learned at ministerial level and try to ensure that these lessons inform engagement in other fragile states in future. - There is as yet no proven relationship between stabilisation and longer-term development demonstrated in Helmand. Delivering assistance in ways that will have a developmental impact on the lives of Afghans requires longer time-frames, specialised expertise and sophisticated forms of interaction with target beneficiaries. The context of HMG's military and political engagement in Afghanistan made it particularly difficult to assess the relevance and appropriateness of DFID's strategic choices against the standard evaluation criteria for a development programme. Consideration should be given by DFID, with other government departments, to the most suitable way of evaluating DFID programmes operating in such a context in future, including whether a joint HMG evaluation framework should be developed. ## Table Of Contents Preface i Acknowledgements iii Abbreviations v Executive **Summary** vii Recommendations xviii Table of **Contents** xxi 1 Introduction 1 Methodology 1 Limitations 2 Report Structure 3 2 Context 5 Socio­economic Context 5 Political Context 7 Development Assistance 10 DFID in Afghanistan 12 Summary Chapter 2 15 3 Programme **Relevance** 17 Evolution of Strategy 17 Strategy alignment with Afghanistan's Priorities 19 Alignment with HMG priorities 25 Portfolio Profile 26 DFID's programme in Helmand 29 Approach to Cross­Cutting Themes 30 Alignment with DFID Corporate Policy 31 Management of Risks 33 Approach to Partnerships 35 Results Focus 37 Summary Chapter 3 39 4 Programme Effectiveness and **Efficiency** 41 Delivery on Strategy 41 Measuring Results in the DFID portfolio 43 Delivery on Gender Issues 47 Working with other UK Departments 48 DFID staff time, numbers and efficiency 49 Summary Chapter 4 51 5 Programme Impact and **Sustainability** 53 Improving Governance 53 Improving Security 55 Capacity Building,Technical Assistance and Corruption 56 Counter­Narcotics 57 Gains in aid effectiveness 59 Summary Chapter 5 60 6 Lessons and **Recommendations** 61 Strengths and Weaknesses 61 Recommendations 62 7 Management **Response** 67 List of **Tables** Table 1. Evolution of objectives within DFID Afghanistan programme 18 Table 2. Summary of Ratings for Risk and Performance for DFIDA projects 2007/8 34 List of **Figures** Figure 1. ODA Disbursements from the top 5 donors to Afghanistan 11 Figure 2. UK Bilateral Expenditure in Afghanistan 2002/3–2007/8 13 Figure 3. Chart comparing spend on state building programmes with total DFIDA spend 22 Figure 4. T otal DFID spend (all programmes) and proportion on ARTF 2003/4–2008/9 27 Figure 5. Portfolio Score Ratings 2006/7 43 Figure 6. Proportion of aid distributed, committed and pledged by top ten donors to Afghanistan 2002–2011 44 List of **Boxes** Box 1. Afghanistan Reconstruction Trust Fund (ARTF) 21 Box 2. NGOs and DFID's Integrated Rural Rehabilitation to Improve Livelihoods and Curb Poppy Production project 24 Box 3. From the Global Conflict Prevention Pool (GCPP) to the Stabilisation Aid Fund (SAF) 26 Box 4. DFID Expenditure in Helmand 29 Box 5. National Solidarity Programme 42 Box 6. Afghanistan Stabilisation Programme 46 List of **Annexes** Annex 1. Annex 2. Annex 3. Annex 4. Annex 5. Annex 6. Annex 7. Terms of Reference A1­1 Persons Consulted A2­1 List of Reference Documents A3­1 Afghanistan Country Programme Evaluation Matrix A4­1 Timeline of Key Events A5­1 Table Showing Net Disbursements A6­1 On The State Building Portfolio A7­1 ## 1. Introduction 1.1 Against a background of a substantial increase in resources and a focus on poverty reduction and achievement of Millennium Development Goals (MDGs), DFID has adopted a policy of decentralisation in order to achieve greater relevance, responsiveness and impact for its aid resources. DFID's office in Afghanistan, first established in late 2001, has been able to design and implement programmes of humanitarian and development assistance with increasing delegated authority. Like most offices, it has been subject to the policy of "more with less", though, as a fragile state, Afghanistan has to some extent been protected from the stringent staff cuts imposed elsewhere. The huge challenges and opportunities of Afghanistan - and the substantial resources committed by all Whitehall departments - place DFID at the very centre of a debate over how best to engage in an ever-changing fragile state arena while increasing the effectiveness of the aid budget and learning lessons to improve delivery performance and impact. 1.2 The Evaluation Department of DFID (EvD) has contracted the company ITAD Ltd to undertake a series of Country Programme Evaluations (CPEs) from 2007 to 2009 with the aim of assessing the relevance, efficiency, effectiveness, impact and sustainability of DFID assistance at country level. Each CPE takes a five-year perspective; in the case of Afghanistan, the focus is 2002–end 2007 with updates provided for 2008. The Afghanistan CPE looks at development performance within the context of post-war reconstruction, periodic environmental crises and, in some parts of the country, protracted conflict. The evaluation also covers a period when DFID was obliged to form part of an increasingly comprehensive cross-Whitehall approach to counter-insurgency and counter-narcotics, and when there were substantial UK troop commitments on the ground as part of the North Atlantic Treaty Organisation (NATO)/International Security Assistance Force (ISAF) engagement. ## Methodology 1.3 The evaluation is timed to fit in with the end of an interim Country Assistance Plan (CAP) cycle, and at a time when the new Country Plan (CP) is under preparation. It gives greater emphasis to strategy and policy than to projectspecific issues. In the case of Afghanistan, security constraints meant that time and travel in country were restricted, so the team was reduced accordingly. The exercise was conducted in four stages. An initial five-day inception period was undertaken by the team leader and DFID Evaluation Department in London (with video contact with Kabul) in late March/early April 2008. This was to collect documentation, conduct initial interviews and to adjust the evaluation approach to issues raised by key stakeholders. 1.4 An inception note was issued to summarise the work at this point (see Terms of Reference (TOR) in Annex 1). For the second stage, the full evaluation team of five consultants spent one week in London interviewing DFID, Foreign & Commonwealth Office (FCO) and Ministry of Defence (MOD) staff overseeing the Afghanistan programme, as well as some independent academics and non­ governmental organisations (NGOs). The third stage was a one-week field visit to Kabul by a team of four independent consultants, with two of them staying a further week in Helmand Province and Kabul in April 2008. The fourth stage was again a four-day period of London interviews followed by initial feedback of key findings to the country office. A summary list of persons consulted is given in Annex 2. The exercise was guided by a matrix of pertinent questions (presented in Annex 3). The main report was then drafted by the team leader and circulated for comment and report finalisation. 1.5 As far as possible, the evaluation has used DFID's own criteria of "success" of programmes and projects, citing the reviews and PRISM scores obtained throughout the period. On some of the major issues (the UK's Helmand policy, counter-narcotics and civil society, for instance) the challenges inherent in such a volatile and changing environment - and the fact that, for confidentiality reasons, most of the respondents cannot be named or directly cited - the evaluation exercises its own judgment based on a summation of "prevailing views" over the five year period, as well as the long-term Afghanistan experience of the evaluation team itself. The evaluation acknowledges, however, that such judgements, though evidence-based, cannot be definitive, and should therefore be treated as a contribution to an ongoing debate. ## Limitations 1.6 The Afghanistan CPE is a complex evaluation model given the political events, the growth of the office over time, regional priorities and DFID's obligations towards alignment with UK government objectives in the country. This latter issue made it particularly difficult to evaluate the relevance and appropriateness of DFID's strategic choices, given these were in many instances constrained by the context of the HMG strategy. Consideration should be given in future to the most effective way of evaluating DFID programmes operating in such a context. 1.7 The timeline of events (Annex 4) provides an outline of the environment in which DFID operated. The CPE was subject to the same constraints as all DFID staff coming under Duty of Care obligations that restricted movement in the country. In Helmand, for instance, during fieldwork the team was subject to "lock down" in the Provincial Reconstruction Team (PRT), with all meetings being held inside the military camp. Even in Kabul, DFID pools all vehicles with the Embassy, and external meetings required prearrangement of an armed protection team to accompany the consultants. DFID documents for the fiveyear period were fairly comprehensive. Given the sensitivities surrounding the UK government's engagement with Afghanistan, some documentation was graded confidential or higher and therefore could not be quoted by the CPE team. Although this has placed limits on the team's ability to explain or to appreciate the background to certain programme decisions, much of the overriding strategic context is well known and within the public realm. 1.8 No primary data collection or commissioned studies were undertaken, and the limited extent to which the team has been able independently to verify the evidence needs to be borne in mind when reading the report. A final constraint was the absence of some staff due to "breather breaks" - after every six weeks in post, staff take two weeks home leave, meaning that at any one time only about 75% of staff are in situ. ## Report Structure 1.9 The CPE report is structured as follows: Chapter 2 describes the country context in Afghanistan, the level of development assistance and DFID's own history of assistance since 2001. Chapter 3 then looks at DFID's strategy over the period: its relevance, its alignment with corporate policy and with the government of Afghanistan (GoA) and other partners, how risk was assessed, and how it expected to use the resources available. This leads to a review of the programme's effectiveness and efficiency in Chapter 4, where the different projects, instruments and levels of staff engagement are examined. In so far as documented evidence is available or the views of informants can be triangulated, the contribution of these different interventions to broader strategy objectives and key policy themes are also addressed. Chapter 5 examines the extent to which medium-term impact of DFID's support can be ascertained, while placing the results in the context of Afghanistan's overall development progress for the period under review. In Chapter 6, conclusions are drawn regarding DFID's strengths and weaknesses, and a set of lessons and recommendations are presented that may guide future assistance in Afghanistan and be of use for DFID globally. A final chapter 7 is a management response provided by DFID Afghanistan. This discussed any areas where they agree or disagree with the independent country programme evaluation. 1.10 Afghanistan is a uniquely complex country, socially and politically. DFID staff have worked often beyond the call of duty and under stress. Where the evaluation identifies problems, these should in no way reflect poorly on the commitment and professionalism of those involved; rather, it is an opportunity retrospectively to learn from the strengths and weaknesses of DFID's approach to a volatile and intense environment that offers very few easy answers. ## 2. Context 2.1 This section presents an overview of the situation in Afghanistan during the period of the evaluation in order to provide the context for DFID's assistance. It also describes the pattern of development and emergency aid provided to Afghanistan from 2002 to 2008, and summarises DFID's support within that. ## Socio-Economic Context 2.2 Afghanistan is one of the poorest countries in the world and is off-track in progress towards all the Millennium Development Goals18. Over half the population live on less than US$1 a day19. The 2005 United Nations Development Programme (UNDP) Human Development Index ranks Afghanistan as 173 out of 178 countries listed; life expectancy is 47 years; 25% of all children die before their fifth birthday - 600 children every day. The maternal mortality rate is the second highest in the world. 2.3 Some progress has been made since the removal of the Taliban government in 2001. The new currency has proved stable; the number of functioning health clinics has increased by 60%; and over five million children are back in school - one third of them girls20. Over 13,000 primary and secondary schools have been reconstructed. The process of achieving quality education is going to be much slower than simply increasing the numbers; nevertheless, nearly 1,500 people are receiving teacher training, a third of teachers are women; and 1.2 million illiterate people are participating in literacy courses. 2.4 Since 2001, 72 new hospitals and clinics have been built. UN agencies, in coordination with the Afghan Ministry of Public Health, have administered 16 million vaccinations against childhood diseases, saving an estimated 30,000 lives. Programmes of water chlorination and well reconstruction are tackling water­ borne diseases across the country21. Infant mortality rates dropped from around 165 per 1,000 live births in 2001 to about 135 per 1,000 in 200622, and 40,000 fewer infants are dying each year compared with during Taliban rule. 2.5 Since 2001, over 4.8 million refugees have returned to their homes. However, the number of returning refugees has been offset by the fact that Afghans continue to migrate to Pakistan and Iran in search of work. As a result, the Afghan populations in Pakistan and Iran are not significantly less than they were in 2002. 2.6 Almost 45% of Afghanistan's population is under 15 years of age - only the Gaza Strip and a few African states have a similar age structure. In 2006, the population numbered just over 31 million, with enormous increases in urban areas; by 2015, it is set to reach 35.5 million, by 2025, 45 million. Thus, each year over 500,000 additional people join the queue for food, housing, jobs and medical care. By March 2008, the price of wheat flour had risen 100% since the previous year, and the UN World Food Programme anticipated a steep increase in the number of Afghans - 2.5 million currently - in need of emergency food aid23. 2.7 When DFID opened an office in Afghanistan for the first time in late 2001, Afghanistan was a country ravaged by war and natural disasters. Agricultural production had been heavily affected by drought. Afghanistan had never had more than minimal industry and this had effectively ceased to function. The majority of skilled professionals had left the country, and government services had ceased, resulting in a dramatic decline in social indicators. Total (non­ opium) GDP at this point is estimated to have been only about $4 billion. In reassessing the situation in Afghanistan at the beginning of 2002, the international community also took serious account of the fact that the country had been affected by a major drought since 1999 and that the anticipated largescale return of refugees from Pakistan and Iran would place a significant strain on an already fragile economy. Afghanistan therefore met many of the criteria for what were termed "fragile" or "failed" states. 2.8 Economic growth has been estimated at 29% in 2002, 16% in 2003 and 8% in 200424. As is common in post-conflict economies, the early growth path settled at about 10% over the next three years. In 2002, Afghanistan's debt to the International Monetary Fund (IMF) and Asian Development Bank (ADB) stood at about $18 million. With an early grant of £12.7 million, DFID was able to pay off these arrears in 2003. This was only a fraction of the total foreign debt. The vast majority (80–90%) was bilateral debt owed to Russia and to Arab countries - this also was written off by them in 2003. 2.9 The government is gradually improving its own revenue base, through customs and taxation. The share of public sector operating expenditures financed by domestic revenues rose rapidly to 67% by 2006, though it has fallen back since as the increase in the size of the government budget has exceeded the rate of increase in revenue collection. The government's Medium Term Fiscal Framework projects domestic revenues to reach 10% of GDP and fully fund operating costs by 2011. 2.10 A factor that tends to reduce government accountability, sustainability and the overall coherence of the reconstruction effort is the low proportion of the national budget that is currently centrally controlled by the government. Only one-third ($1.03 billion) of the total budget in 2005 was directly managed by the Ministry of Finance (this is referred to as the "core budget" and includes both external aid and government revenues); the other two-thirds of expenditure passed through an "external budget" - through private contractors and NGOs. A majority of this off-budget spending is from United States Agency for International Development (USAID) funds25. 2.11 Meanwhile, economic development is jeopardised further by the recovery of opium production in the insecure southern provinces. Afghanistan is now the largest producer in the world of illicit opium; it dominates the Afghan economy comprising almost half of GDP26. The poppy sector constitutes the largest source of export earnings. Its illegal nature not only implies significant lost tax revenue to government but also breeds lawlessness, which undermines economic confidence and social cohesion. 2.12 The greatest future growth potential lies in exploitation of gas and mineral resources, and of transit trade, primarily between Iran and Pakistan27. Continued recovery and expansion in agriculture will bring the broadest-based growth. ## Political Context 2.13 The US-led military intervention in Afghanistan of October 2001 was broadly supported by the international community, as was the Bonn Agreement of December 2001, which set out a road map for a democratic process. Most donors also showed a collective determination to lend maximum support to the new interim government. The willingness to strengthen the Afghan governmental infrastructure was a reversal of the previous policy of DFID and most other donors in relation to the Taliban government of 1996–2001. 2.14 Through the Bonn Agreement, the international community promised a broadbased and democratic government. In effect, though, they produced a change of regime through a military strategy that handed power to faction leaders. The Afghanistan Interim Authority (AIA) established by the Agreement had a narrow ethnic political base, initially dominated by ethnic Tajiks. Many Pashtuns were excluded from power - a factor that has fed discontent both within and outside the Taliban28 - and those in power have been reluctant to change this29. 2.15 The USA's dominant role as the major donor left the rest of the donor community in a relatively powerless position to influence outcomes. The US-led intervention reinstated the fragmented power dynamics that had characterised the pre-Taliban period of the Mujahidin government of 1992–96, with many of the former Mujahidin commanders and militia leaders re-establishing their previous fiefdoms (giving particular prominence to the Tajiks and the Shura Nazar). Notwithstanding the underpinning that international military and political support gave him, the Interim President, Hamid Karzai, therefore had to strike deals with these multiple power holders in order to secure a minimal level of acquiescence to his leadership role. His efforts were rendered more complex by simultaneous deals that the US military initially negotiated with particular power holders in the south of the country in pursuit of its efforts to find high-value targets such as Osama bin Laden. There was a prevailing policy of tactical accommodation and "warlord democratisation"30. The policy has led to the re-emergence of what has been characterised as a "rentier state" and the creation of institutions and structures unlikely to be sustainable in the long run31. 2.16 The counter-terrorism process sat uneasily with state building objectives. The fact that the Afghan state relies almost entirely on external capital and the provision of military support undermines its domestic legitimacy. Thus, the "conversation" between the centre and the periphery is characterised by "hedging" and "spot contracts" rather than durable solutions towards lasting peace32. Furthermore, the US practice of working through US contractors to deliver programmes and projects, including the provision of technical assistance, led to reluctance on the part of the US to direct funds through the Afghan government or to give priority to building the capacity of governmental infrastructure. 2.17 The presentation by the insurgents of a "puppet" state upheld by the US-led coalition has been used to justify a consistent campaign of terrorism aimed at undermining the new state. To this end, terrorist attacks have been directed at members of the Afghan National Army, the Afghan National Police, government ministers, state officials, aid workers, religious leaders voicing support for the government and personnel working on reconstruction projects. The insurgents also use strategies to intimidate and generate fear within the population33. This has compelled the aid community to withdraw its personnel and projects, in particular from large areas of the south, severely constraining the ability of donors to visit project areas for the purpose of monitoring and evaluation. 2.18 Whilst there are positive indicators of progress with the completion of the presidential and parliamentary elections, the end of the Bonn process and the signing of the London Afghanistan Compact (January 2006), these gains remain perilously fragile. Nevertheless, the political process culminated in elected institutions of state with a relatively high turnout of voters for the 2004 Presidential elections and the 2005 Parliamentary and Provincial Council elections. There is also a fledgling Afghan National Army (ANA), and some 60,000 former combatants have been demobilised, although ensuring successful reintegration and the extension of disarmament programmes to illegal armed groups will require sustained intervention. There is visible economic activity and improvement of infrastructure in many parts of the country, yet persistent unemployment and high levels of corruption underline the need for international commitment to long-term, balanced development and good governance in Afghanistan for many years to come. 2.19 A recent study of local perceptions of peace operations suggests that for some communities in Afghanistan, as elsewhere, assistance is welcome regardless of the donor's military identity or political objective34. For some non-Taliban aligned communities, accepting and participating in aid projects has become a gesture of defiance against the insurgency. Yet at the same time, the simultaneous US-led intervention in Iraq provided the Taliban with a political foundation on which to draw both resources and recruits from the wider Islamic world on the grounds that Afghanistan was subjugated by a "US-led invasion". Afghanistan thus became a cause célèbre within the global Islamic community, alongside Iraq, Palestine, Lebanon and Chechnya. 2.20 In the spring of 2006, the UK, Canada, Denmark and Holland, as key contributors to the International Security Assistance Force (ISAF), decided to join US forces in deploying their forces outside Kabul to the provinces of Helmand, Kandahar and Uruzgan. This provided further justification for a new phase in the insurgency, with their support base already strengthened by public discontent over the search methods used in counter-terrorism operations, the detention of Afghans at Bagram and other US bases, and the high level of civilian casualties generated in air strikes conducted during counter­ insurgency operations35. The insurgents were also able to draw on public disappointment with the "corrupt" government and police force36. 2.21 The level of insurgent and terrorist activity increased sharply in 2007. Afghanistan remains roughly divided between the generally more stable west and north, where security problems were linked to factionalism and criminality, and the south and east characterised by an increasingly coordinated insurgency. A worrying trend was the gradual emergence of insurgent activity in the far north­ west of the country, an area that had been calm, as well as encroachment by the insurgency into Logar and Wardak provinces, which border Kabul37. 2.22 The UK government faced particular challenges in taking on responsibility for Helmand. It represented a major shift from the stabilisation role that UK had hitherto played in the area centred on Mazar-e-Sharif, in which it had effectively contributed to a calming of tensions between two major power holders in that region. 2.23 Although the Helmand brief was also one of stabilisation, there was only one local power holder of any significance. Helmand had long been the major centre for opium production and its political dynamics reflected both a relatively weak tribal structure and the strong power base of a particular family connected to the opium trade and to international criminal networks. Helmand accounted for over 50% of the country's opium poppy cultivation in 2007/08 and was also the most important province in terms of heroin processing and trafficking38. This created potentially huge obstacles to the complex task of assisting the Afghan authorities to extend and exercise their authority and influence across the country39. On the one hand, Helmand had historically maintained a pronounced independence from central government while, on the other, the individuals controlling the drugs trade in the province had very high-level links with officials in both local and national government as well as a modus vivendi with the local Chief of Police. 2.24 Finally, one of the reasons Afghans can be "hired but not bought" is that they have an acute sense of history and of the relatively brief presence of foreigners; the insurgents and their would-be supporters know there is hardly anything unique to the latest incarnation of "bringing peace and development to Afghanistan". ## Development Assistance 2.25 Following the fall of the Taliban regime in 2001, the international community pledged $4.5 billion to support the country's recovery in the first five years. Total Overseas Development Assistance (ODA) to Afghanistan more than doubled during the period 2002–2006, from $1.3 billion to just under $3 billion, bringing the total to almost $11 billion. Yet Afghanistan receives a lower aid per capita than most post-conflict nations; and by 2006, due to its low absorptive capacity, the country had only spent 23% of what it has been granted for the development budget40. Over 66% of ODA is currently spent outside the government's (non-military/security) budget. 2.26 There are some alarming statistics on aid effectiveness in general in Afghanistan. Integrity Watch Afghanistan, for example, reports that for every $100 spent only $20 actually reaches Afghan recipients. Aid agency expenditure on their own security ranges from 15% to 30%, and 85% of products, services and human resources used by agencies are imported and provide few jobs for Afghan workers41. 2.27 Figures suggest that a number of major donors direct a disproportionate share of their funds to the southern provinces where the insurgency is strongest. The problem is that these disparities in aid "are widely regarded as illegitimate or unjust, which undermines confidence in the state"42. In 2007/8, the most insecure provinces of Nimroz, Helmand, Zabul, Kandahar and Uruzgan have been allocated more than $200 per person, whereas many other provinces received less than half this amount, and some, such as Sari Pul or Takhar, are allocated less than one third43. 2.28 Within the top five donors, the US has been the principal donor, accounting for 40% of all development aid to Afghanistan (Figure 1); by 2006 this had risen to 48% - just under $1,320 million. Overall, the European Commission (EC) is the second largest donor; however, its proportion of total ODA has reduced from 11% in 2002 to 7% in 2006. Averaged across the five-year period, the UK is the third largest donor. In 2002, the ODA from the UK was just over $130 million (10% of total). In the following years, the UK maintained its proportion of 8–10% of the total, amounting to just over $200 million by 2006. 2.29 The 2006 London Conference launched the Afghanistan Compact; this and the subsequent Afghan National Development Strategy (ANDS, published 2008) would lay out the framework for international engagement with Afghanistan until 2011 in a number of vital areas: security, governance (including human rights and rule of law), social and economic development and cross-cutting themes such as counter-narcotics, gender equity, and anti-corruption. A highlevel Joint Coordination and Monitoring Board (JCMB), led by the United Nations Assistance Mission in Afghanistan (UNAMA), was established in April 2006 to oversee and support the strategic implementation of the Compact. The JCMB's network of sectoral working groups monitors progress and identifies activities to achieve the Compact's benchmarks. Lending political support to this whole process is a group of key donors, including the US, Italy, UK, Germany, EC and the European Union Special Representative (EUSR), Spain and Japan. ## Dfid In Afghanistan 2.30 DFID's Conflict and Humanitarian Department (CHAD) set up an office in Kabul in late 2001 and managed the bulk of DFID funding until handing over to the West Asia Desk at the end of March 2003. Initially, DFID took a "light footprint" approach following many years of support through NGOs and the UN. £7 million was spent in 2000/1 and £50 million in 2001/2 on humanitarian assistance; this included support to refugees, immediate reconstruction needs and support to health and education programmes. A large proportion of funds were channelled through multilaterals, primarily the UN. 2.31 DFID allocations increased significantly over the period 2003–2007, settling down to about £100 million in 2006/7. These allocations were complemented by aid from other UK sources of about £20 million per year from 2004 onwards (Figure 2). * Includes CDC investments, non-DFID debt relief, contributions from other government departments, British Council and Global Conflict Prevention Pool. Source: Statistics in International Development. 2.32 The UK is one of 36 nations involved in Afghanistan since 2001. Its efforts are coordinated by the Foreign and Commonwealth Office (FCO), DFID and the Ministry of Defence (MOD). Aside from military expenditure (estimated at £1.6 billion since 200144), DFID has the largest expenditure. In addition to DFID's development programme, there are three strands to the UK strategy: - Support to the security environment (MOD and FCO contributions to security sector reform). - Conflict resolution and prevention dialogue, much of which has come through the (now closed) Global Conflict Prevention Pool (GCPP)45, and Global Opportunity Fund (GOF), both administered by FCO. - Good governance/rule of law, also utilising GCPP and GOF funds, but including the counter-narcotics strategy led by the Afghan Drugs Inter- Departmental Unit (ADIDU). Prevention Pool and a new Stabilisation Aid Fund (SAF). 2.33 DFID's assistance since setting up the office in Afghanistan can be traced through four phases: - 2001–2003 Essentially a limited humanitarian effort - funds through UN, International Organisation for Migration (IOM), Red Cross and NGOs - with longer-term commitments foreseen. At the Tokyo donor conference in 2002, DFID pledged £200 million over five years (2002/3–2007/8), part of a wider $4.5 billion pledge made by the international community. - 2003–2005 The Transitional Country Assistance Programme (TCAP), designed as a relatively short-term plan with a long-term strategy to cover the duration of the Transitional Administration in Afghanistan. It was informed by a government/international agency report "Securing Afghanistan's future: Accomplishments and the Strategic Path Forward", prepared for the International Conference in Berlin, March 2004. Based on a World Bank assessment that Afghanistan needed $28 billion over seven years, the UK increased the pledge made at Tokyo to at least £500 million over the same five-year period. - 2005–2006 Following national elections, the Interim Strategy for Afghanistan 2005/6, a three-pillar programme - state building; economic management and aid effectiveness; and livelihoods. This built on government ownership and capacity, with upwards of 70% of DFID funds being channelled through the national budget and national programmes. The ANDS (essentially equivalent to a poverty reduction strategy, though also covering security) was published in mid-2008 and was understood by DFID to be the ideal mechanism to provide a necessary strategic framework for the long term. - 2006–2008 The fourth phase of DFID's development strategy was marked by its commitment to the ten-year Development Partnership Arrangement (DPA), under which it announced its commitment to spending £500 million over three years. This phase was characterised by the continuation of the 2005/6 Interim Strategy for Afghanistan coupled with emphasis on supporting the UK's increasing focus on Helmand province. ## Summary Chapter 2 - Afghanistan is off-track on all MDGs. Despite some significant social and economic improvements since 2001, social discontent is on the rise and increasing population and basic food prices may lead to further destabilisation. Only about one-third of expenditures are controlled by the Government; - with most USA (by far the largest donor) funds being off-budget. - Economic development is particularly jeopardised by the full recovery of opium production in the insecure southern provinces; illicit opium now comprises 47% of GDP. - Through the Bonn Agreement of December 2001, most donors showed a collective determination to lend maximum support to the new interim government. Successful presidential and parliamentary elections in 2004/5 saw a high turnout. - By originating in a foreign military intervention, the state-building effort in post-Taliban Afghanistan became perceived by many Afghans as tied to the power of foreign troops and capital. This has challenged the legitimacy of the state and lent credence to the propaganda of the insurgency. Levels of insurgency increased in 2007 and spread to other areas of the country. - Helmand had historically maintained a pronounced independence from central government; however, individuals controlling the drugs trade in the province have high-level links at all levels of government. - Afghanistan receives a low proportion of aid per capita; due to its low absorption capacity, the country had, by 2006, only spent 23% of what it has been granted for the development budget. - The UK is the third largest donor, maintaining about 10% of the total ODA to Afghanistan since 2003. DFID's programme evolved from an ad hoc humanitarian programme in 2001/2 to a three-pillar programme from 2005 - livelihoods; economic management and aid effectiveness; and statebuilding - with spending over £100 million, the majority of which has been on-budget support through the GoA. ## 3. Programme Relevance 3.1 This chapter discusses the relevance of DFID's strategic approach and programming to the needs of Afghanistan from 2002 to 2007. It examines how risk was assessed, how choices about aid instruments have been made, and how DFID decided to work with government and other development partners. ## Evolution Of Strategy 3.2 The evaluation period, 2002–2007 is covered by (i) the final year of DFID's Conflict and Humanitarian Affairs Department (CHAD)-led humanitarian assistance, (ii) the Transitional Country Assistance Plan (TCAP) and (iii) the 2005/6 Interim Strategy for Afghanistan, which was subsequently extended to 2008. The initial priorities identified by CHAD were largely determined by concern to provide ongoing support to those who continued to be affected by the drought of 1998–2002. This led to continued funding for UN World Food Programme (WFP) and the UN High Commission for Refugees (UNHCR), to provide assistance in drought-affected areas and to internally displaced persons (IDPs) and returning refugees. 3.3 To focus on humanitarian aid in the first instance was an appropriate response by DFID. By 2003/4, after five years of drought, the annual harvest increased by 80% and DFID moved to a protracted recovery approach, concentrating on longer-term reconstruction and support for government institutions. In the forthcoming Transitional Country Assistance Plan (TCAP) some UN agencies, NGOs and the Red Cross continued to receive significant funding from DFID, mostly for the reintegration of returning refugees and IDPs. However, in the longer term it was assumed that the government's National Solidarity Programme would facilitate improved access to livelihoods for those who continued to be affected by displacement and drought. 3.4 The transition in strategies from 2001 is outlined in Table 1. After 2003, the reintegration of refugees and IDPs became a residual element of the humanitarian programme. The Bonn Agreement was an interim arrangement pending the 2004/5 Presidential and Parliamentary elections (which DFID was to support), so this objective also was short-lived. The remaining three objectives of the TCAP evolved into what was to become a three-pillar programme under the 2005/6 Interim Strategy for Afghanistan: state building; economic management and aid effectiveness; and livelihoods. The evaluation will, therefore, concentrate primarily on these three key strands within the DFID programme that effectively provided its framework from 2003 onwards. Interim Strategy for Afghanistan (ISA), 2005/6 (extended to 2008) Transitional Country Assistance Plan (TCAP), 2003–2005 Humanitarian Programme 2001–2003 and support to the Afghan Transitional Authority - Programme based on three pillars, each with its own discrete set of objectives; - Run by CHAD, with humanitarian objectives determined under each funded project; - An effective development partnership between Afghanistan and the international community; - Implementation of the Bonn Agreement; - State building: to address the weaknesses in state institutions and to help ensure that sustainable development can be financed and delivered; - In 2002/3, approximately 50% of DFID's funds were spent on humanitarian assistance. The remaining 50% was TA to central ministries, ARTF and some NGO livelihoods programmes. - An effective central government that re­ establishes national unity on the basis of strong institutions. This includes support to central financial institutions and the ARTF; - Enhancement of human security and support to sustainable rural and urban livelihoods; - Economic Management and Aid Effectiveness: to strengthen the public finance system, which is central to the development and implementation of a National Development Strategy; - The reintegration of returned refugees and internally displaced people into communities of their choice. - Alternative Livelihoods: to help reduce dependence on the opium economy and to help regenerate rural economic growth. 3.5 The adoption of MDGs as genuine targets to direct strategy was not considered appropriate in immediate post-conflict Afghanistan. This was in line with emerging good practice on aid effectiveness in fragile states, which emphasises state building as the central objective. The TCAP - and, indeed, the subsequent 2005/6 Interim Strategy - was predicated upon several assumptions: first, that the formal political transition process led by the UN Special Representative of the Secretary-General (SRSG) Brahimi would result in a stable political settlement; second, that conferring legitimacy on the state means building it from the centre first, then extending to provincial and local levels; and third, that formal institutions (judicial, legislative, banking, private sector) are the pillars of growth. 3.6 Retrospectively, some of these assumptions have been questioned, but it would be disingenuous to suggest they were incorrect at the outset. Afghanistan had not seen a stable government since the 1970s, and the Bonn Agreement presented an ambitious opportunity to build institutions of governance capable of providing citizens with physical and economic security, a radical change from the factional and conflict-ridden polity that had prevailed for decades. This has led to deep forms of international intervention in the sovereign affairs of the country. 3.7 DFID's 2005/6 Interim Strategy retained the above assumptions, and although it was initially only for one year, it was then extended for a further three years pending the completion of the Afghan government's Afghanistan National Development Strategy (ANDS). The ANDS was published in 2008. 3.8 After 2006, it became increasingly clear that the materially weak central state was unable to foster the social and political cohesion necessary to build its legitimacy46. The insurgency in the south was one manifestation of this; so too was the economic challenge that came from a growing illicit trade across porous Pakistan and Iran borders. Militarily, the international community had moved from peacekeeping to counter-insurgency. As the security of the international mission predominated - and as the political focus of Whitehall shifted to a Helmand-centric view of countering the growing insurgency - DFID found itself less able to focus concertedly on development issues in a conflict environment. 3.9 The depiction of Afghanistan as a "post-conflict" country with a stable government at the helm was being increasingly challenged by 2007. DFID had maintained a steadfast strategy for five years based around support for an emerging government and the building of the architecture of a viable state. What remained were a number of broader questions. By financially backing and conferring legitimacy upon Kabul-based central institutions perceived by many as predatory and corrupt, were international donors becoming part of the problem rather than the solution? Sequentially - and in accordance with a much more limited view of what is possible at this stage in Afghanistan's history - should DFID have limited its investment to provincial or district programmes with a more direct impact on poverty reduction? And finally, if the HMG policy in Helmand demands the thorough inclusion of DFID in a civil-military nexus, to what extent does this challenge the coherence of a longer-term development strategy in Afghanistan? ## Strategy Alignment With Afghanistan'S Priorities 3.10 In 2003, the GoA elaborated a strategy for the country's reconstruction through its National Development Framework comprising 12 national programmes. The documents set out outcome targets to be achieved by 2015 to align with the MDG framework. DFID concentrated on a strategy for service delivery that was perceived as an entry point for triggering longer-term pro-poor social and political change47. 3.11 The initial phase of DFID's support in 2002/3 included support for capacity building of the Afghan Interim Administration (AIA) and its successor Transitional Government, with a particular focus on the Ministry of Finance. While limited in scope, this was both clear and appropriate at the time, given the emphasis on humanitarian assistance and immediate recovery, and the importance of establishing sound public financial management systems to allow resources to begin to flow through government. 3.12 DFID's goals and strategy for its economic management programme remained the same from the TCAP onwards - to support the creation of a strong public finance system in order to implement the National Development Framework (NDF) and to enable the government to lead the coordination of development activities. The key underlying - and now standard - aid effectiveness assumption48 was that the sustainability of reconstruction programmes started with foreign capital depends on developing the capacity to manage the economy. 3.13 This in turn depended on implementation of a fair and effective revenue collection system, a modern annual budget formulation process, and a modern monetary system with currency and other financial operations controlled by the Central Bank49. In addition, private sector development was seen as the ultimate source of long-term growth. 3.14 DFID's assistance to revenue-raising through taxation has been effective and efficient, but DFID did not articulate the strategic challenge of how to foster a "social contract", a tangible demonstration of representative democracy. If not balanced with clear evidence of benefits elsewhere in the system, taxation alone risks reinforcing public opinions of a predatory state. 3.15 The Afghanistan Reconstruction Trust Fund (ARTF, Box 1) was to become the key mechanism to strengthen the government's ability to coordinate and deliver its own development agenda. Through this, DFID took the strategically appropriate decision to fund government recurrent costs - primarily teachers and other public sector salaries –intending to both revive the public sector and to pump incomes quickly into the economy. ## Box 1. Afghanistan Reconstruction Trust Fund (Artf) The ARTF is a multi-donor trust fund administered by the World Bank in support of Afghanistan's reconstruction efforts. It has been the donor community's response to the national authorities' strong and consistent request for a single, predictable, accountable source of un-tied funding for the recurrent budget, which is the government's top priority. From May 2002, when it was set up, until December 2007, the Fund has disbursed $2.3 billion from 26 donors. The UK is the largest single donor to the ARTF, with a quarter of all contributions. The ARTF has two windows: a recurrent and an investment window. Through the recurrent window, the ARTF finances the salaries and wages of over 250,000 nonuniformed civil servants (most of them outside Kabul) plus operation and maintenance expenditures. Through the investment window, the ARTF finances (currently 11) investment projects, all of them national priority programmes (NPP) defined by the government of Afghanistan in their National Development Strategy and approved by a joint donor-government Management Committee. Cumulative approvals for investment projects since 2002 amount to $600 million. The government first funds its budget and after an initial review of eligibility by the World Bank's monitoring agent, is refunded from the ARTF. The ARTF does not fund military or security related expenses. 3.16 The UK's ten-year Development Partnership Arrangement (DPA) signed in 2006 committed DFID to furthering its on-budget support (through the ANDS) and the intention of moving towards Poverty Reduction Budget Support (PRBS) on condition that the appropriate administrative, technical and financial systems could be established to support this. The DPA was essentially a reiteration of DFID's firm support for the Paris Declaration principles relating to good donor practice and government ownership. Given the fragmented and uncoordinated nature of international aid to Afghanistan, the declaration was both timely and appropriate. 3.17 The Interim Strategy 2005/6 defined state building as an explicit pillar for the first time. Support to parliamentary and provincial elections in 2005 marked the end of the Bonn process. DFID continued supporting the technical, supply side of state building through a focused programme on central government capacity building, including public administration reform (PAR), civil service reform and strengthening government administration at national and sub-national levels. 3.18 The size of the state building portfolio has been small in comparison to the other two key areas of DFID's programme, less than 8% of the overall programme (Figure 3). Programme choices show a desire to make progress on issues of governance and technical capacity building of state institutions on the one hand, and to contribute to the stabilisation and counter-narcotics efforts of HMG on the other. While these are not mutually exclusive, delivering on these two objectives simultaneously has proved to be a huge challenge given the limited resources available. 3.19 Political economy and conflict analysis were not undertaken, and therefore did not underpin the strategic choices made. A key assumption was that donor support for strengthening central government would, over time, "increase capacity, improve service delivery and thereby help to build political legitimacy throughout the country"50. But until recently, DFID has given less attention to accountability issues, the demand side of governance and sub-national governance, which are also essential to broadening state legitimacy. 3.20 The USA dominates assistance to Afghanistan's security and justice institutions, even where other countries are nominally in the lead. This has largely defined the options for the UK. DFID made significant efforts early on in 2002 to identify opportunities for engagement, and to work with FCO and MOD to support analysis of the sector (broadly defined). Nevertheless, limited resources and staffing, as well as the division of labour agreed among donors (with policing and justice led by Germany and Italy respectively) appears to have been a key factor in DFID's decision not to prioritise this sector. 3.21 Different choices within given resources could have been made, however. Greater priority could have been given earlier to security and justice work, given that the rule of law sector was consistently highlighted as one of the most critical areas for addressing state fragility, where progress was sorely lacking. This should arguably have been given priority over support to central government institutions, or to counter-narcotics institution building through SCNIAP, where progress depended on wider reform in the justice sector. 3.22 More recently, £10.6m has also been committed to the HALO Trust for work on de-mining following the Secretary of State's visit to Afghanistan51. While this is located within the state-building portfolio, and represents a significant proportion (20%) of funds spent by the state-building team in 2007/08, it is more difficult to see the strategic value of this programme in relation to statebuilding. 3.23 The Interim Afghanistan National Development Strategy (I-ANDS) and Afghanistan Compact (January 2006) reshaped the governance area, linking it to rule of law and human rights as a sector. DFID did not, however, take the opportunity to redefine its approach in line with this shift. Although DFID's Interim Strategy 2005/6 had separated state building from economic management for the first time, the state building component did not link public administrative reform to rule of law and human rights issues in line with the I- ANDS/Compact sector strategy (beyond small-scale support to security sector reform through the GCPP). 3.24 In developing a livelihoods strategy DFID included some extremely useful commissioned research on poppy substitution as well as technical assistance and capacity building work within the key social sector government ministries. As we shall see, the decision to end this work, in part due to the shift of attention towards Helmand, but also to the further concentration of the portfolio around government-led programmes has, in the judgement of the evaluators, led to missed opportunities in further exploring the political and developmental dynamics around the poppy industry. ## Box 2. Ngos And Dfid'S Integrated Rural Rehabilitation To Improve Livelihoods And Curb Poppy Production Project From 2002 to 2006, DFID supported an innovative NGO provincial consortium in Badakhshan and a farmers' development programme in the Hazarajat. Although the programme was primarily focused around livelihoods, it had a strong social dimension, including action on drug addiction. There was a gender component and also work was being undertaken in schools in respect of raising awareness among children, particularly female children, on the social consequences of a drug economy. The programme placed a strong emphasis on the National Solidarity Programme (NSP) and the development of Community Development Committees (CDCs), so in addition to livelihoods, it had an important institutional dimension. There was also a small output concerned with enterprise development, the utilisation of business development services and revitalisation of the private sector. Finally, there was a capacity building component of technical support to local government. These and a number of other projects were discontinued in 2006. The stated reasons behind this were high transaction costs, portfolio rationalisation, the desire to channel increased support to the government, and a focus on Helmand. This has left the Livelihoods Programme with a somewhat skewed portfolio in terms of geographic involvement. The decision to increase support to the rural ministries is understandable. Although the FAO Saleh (Hazarajat) programme has been maintained to end-2008, the heavy investment of resources in one highly complex and relatively rich province (Helmand) is less understandable. Risk could be spread by exploring other development agendas such as farmer groups, NGO consortia livelihood programmes, governance/livelihood interface, extending the capacity building of provincial structures, continuation of CN action research and so on. Innovations have been possible in the programmes undertaken but mainstreaming of achievements was cut short by a change in policy. A more rounded, innovation-related, CN-orientated and risk-averse livelihood programme with a measure of geographic spread would have been a natural progression from what was taking place prior to 2005. The debate relates also to the competence of government delivery mechanisms, as well as to the issue of advocacy (see elsewhere in the report). Where there is political will and sufficient competence, ministries such as the MRRD can deliver programmes with a relatively high measure of success, such as the NSP programme. The evaluation of the poorly performing CNTF points to donor preferences exacerbating weak management capacity, for example, the lack of provincial and thematic prioritisation, poorly formulated projects and slow disbursement procedures52 . NGOs and contractors have played a significant role in NSP, MISFA and NRAP and have been instrumental in driving forward programme implementation across a wide range of programmes. Without their contributions, the successes of these large government programmes would be greatly reduced. ## Alignment With Hmg Priorities 3.25 Working relationships between the FCO, MOD and DFID since the UK's reengagement in the country in 2002 have been helped by the relatively small size of the UK contingent in Kabul (in comparison, for example, with the USA). Close working relations between Embassy staff, British military commanders, and DFID have also helped promote a coherent public face to UK policy in Afghanistan. Despite this, the evaluation found different interpretations by the various HMG Departments on how a number of crucial issues such as counternarcotics should be addressed. 3.26 HMG's primary and more immediate focus on counter-insurgency and counter­ terrorism - particularly with the UK's engagement in Helmand since 2006 - presents particular challenges for DFID. HMG has pursued simultaneous multiple objectives - counter-insurgency, counter-narcotics, stabilisation, peace and development - under an assumption that each is mutually reinforcing. This is not necessarily the case. Research points to the fundamental tensions that exist between long-term state building goals and the political short-term imperatives of counter-insurgency and counter-narcotics efforts in Afghanistan to date53. 3.27 From 2005, there was a rationalisation of DFID's programme driven by the "more for less" approach that saw a reduction in the scope of the portfolio but not in the overall scale of financial support. This coincided with a considerable shift in resources towards Helmand (notably through the Helmand Rural Development Programme) while the wider geographic spread of the programme was curtailed. 3.28 HMG political imperatives towards a "comprehensive approach" to counter­ insurgency in the south presented particular challenges to the coherence of DFID's overall strategy. Time-bound targets from the Cabinet Office demanded increasing staff resources and time. Initially DFID posted only relatively junior persons to meetings held in London, a situation that was rectified in 2008 by placing one of the two Deputy Heads of Office in London. 3.29 DFID's Interim Strategy from 2005/6 onwards was not updated to reflect significant changes in the focus of the portfolio following the Helmand decision. It included reference to DFID's earlier contributions to the political transition process and to Security Sector Reform through the UK's inter-departmental GCPP (see Box 3), but it has become increasingly outdated and does not sufficiently address the connections and tensions between political, security and development objectives. "We are now in a situation in which we are simultaneously trying to pursue quite different objectives that stretch from counter-insurgency, counter-terrorism, counter-narcotics, state building, development, and democratisation. Very few of these issues are logically connected and each one of them could be pursued on its own" Turquoise Mountain Foundation submission to UK Defence Committee Report 2007. ## Portfolio Profile 3.30 Over the five-year period the key instruments used were TA (relatively lowcosts, almost all at central ministry levels), joint-donor trust funds (the ARTF and CNTF, see below), humanitarian and livelihood projects through NGOs and the Red Cross/Crescent, contributions to ongoing UN programmes (mainly humanitarian and livelihoods) and research (surveys and policy). 3.31 By 2007, there were 58 projects in the DFID Afghanistan portfolio with an aggregate value of about £520 million. The programme was dominated by the WB-managed Afghanistan Reconstruction Trust Fund (ARTF) - classified as a DFID "project" - with DFID's aggregate contribution towards it totalling £317 million funded through the central Treasury Account in Afghanistan54. Without the ARTF, other "live" programmes had a total value of £201 million, 11 of which were valued at over £5 million. ## Box 3. From The Global Conflict Prevention Pool (Gcpp) To The Stabilisation Aid Fund (Saf) 55. Rather, The Afghanistan Strategy in the Global Conflict Prevention Pool (GCPP) received ministerial approval in June 2002. The evaluation has not undertaken a review of the GCPP, but notes the widely held view that the lack of clear strategic guidance for GCPP work prior to December 2007 meant that no consistent criteria were applied to funding decisions there was a tendency to "shop around" for funding from various windows, with the GCPP often described as "a place of last resort". As part of an effort to enhance UK capability to prevent, manage and resolve conflict and to build peace in a strategic and coherent manner, the Comprehensive Spending Review of September 2007 announced the merger of the Africa CPP and the Global CPP into one 56. £58 million out of a Conflict Prevention Pool (CPP) and creation of a new fund, the Stabilisation Aid Fund (SAF), for "conflict stabilisation activity in volatile or hostile areas" £73 million budget will need to be ODA eligible in 2008/9 and 2009/10, and £108 million out of £123 million in 2010/11. 3.32 Within the economic management portfolio, the financial dominance of the ARTF has increased over the evaluation period (Figure 4). However, since this has been partly driven by the creation of an investment window through which specific development projects could be selected for "preferenced support by donors"57, the significance of this rising dominance is not as great as might be first thought. An independent evaluation of the Trust Fund described 85% of the funds (those used to fund recurrent costs) as "de facto budget support"58. 3.33 DFID's state building approach and strategic choices from 2003 were shaped by a combination of factors in addition to the assumptions set out above. Firstly, the need to limit the number of sectors in which DFID engaged, in line with requirements set out by the Afghanistan Interim Administration; secondly, the division of labour agreed in HMG that allocated the lead on governance and rule of law to FCO; and thirdly, limited staff resources, which constrained the ability of DFID to adopt a wider range of instruments, partnerships and approaches within the chosen sectors. 3.34 Since 2006, DFID's state building approach has evolved to combine a continued focus on strengthening public administration with more attention to the rule of law, accountability, anti-corruption and sub-national governance issues. The evaluation supports the recent shift in direction of the state building programme, support. 58 Scanteam, et al, 'Assessment, Afghanistan Reconstruction Trust Fund', 2005. including a renewed focus on the rule of law/justice sector and on sub-national governance - two of the major impediments to effective state building in Afghanistan. 3.35 Prior to late 2007, the conflict agenda was pursued primarily through Global Conflict Prevention Pool (GCPP), which had a global budget of approximately £245 million between 2004/5 and 2006/7. Some 46% of this was allocated to Iraq and Afghanistan, and expenditure on these two countries has dwarfed all other GCPP outlays. In Afghanistan, the share of Security Sector Reform (SSR) expenditure in overall investments made through the GCPP has decreased from about £12 million in 2004 to almost zero in 200859. This is a regrettable omission in a country that is in the midst of building a new security sector and is facing multiple challenges relating to SSR. The security sector is the one element of the government's ANDS for which a sectoral strategy is still lacking. 3.36 DFID's conflict work has also evolved, including new work on conflict mediation and reconciliation. As late as 2006, the consensus was that the International Security Assistance Force (ISAF) was essentially a peace enforcement operation; only in the last two years has this assumption been challenged by renewed insurgency, with the requirement for DFID's interventions to be "conflict sensitive". This has involved a three-tier approach: (a) influencing donors and ISAF towards the notion that counter-insurgency should now explore political as well as military channels; (b) that the political settlement should also include a renewed emphasis on governance; and (c) that this should include building capacity within civil society (beyond the reach of ISAF and the government) and include investments in local media, for example. 3.37 DFID had not had a conflict advisor to pursue this agenda until late 2007, but the evaluation judges that such strategies should have begun much earlier since it is precisely the dearth of conflict analysis and alternative options that has led to HMG tensions outlined in this report. 3.38 As the need for humanitarian support diminished in 2003/4, DFID began to develop a livelihoods programme that incorporated at its inception a poppy substitution dimension. This included cross-sectoral programmes such as those in Badakhshan and the Hazarajat (and the HARDP programme from 2006). The TCAP incorporated a strong and quite detailed sustainable livelihoods component that served DFID well from 2003 to 2006. 3.39 DFID's Interim Strategy of 2005/6 was less clear in defining alternative livelihoods and, from here onwards, DFID moved away from area-based poverty-focused programming through NGOs and increasingly towards funding TA and capacity building within key ministries (MRRD and MAIL) through, for example, the Support for Strategic Planning for Sustainable Rural Livelihoods (SSPSRL) project. Support here was strategically appropriate, given the importance of the agricultural sector in Afghanistan. Likewise, the National Solidarity Programme (NSP), National Emergency Employment Programme (NEEP) and Microfinance Investment Support Facility for Afghanistan (MISFA) have direct links to poverty alleviation. 3.40 Arguably, the most significant challenge to the more conventional approaches to long-term development has been the counter-narcotics (CN) programme. The dominant USA policy has been one of enforcement, including aerial spraying of crops and prosecution. The UK has so far successfully persuaded the USA to refrain from this in Helmand. Although alternative livelihoods have been explored through household-based approaches to rural livelihoods, little room is left for a holistic approach by donors, one that would take into account socio­ economic systems at village, district and provincial levels. ## Dfid'S Programme In Helmand 3.41 On the wider counter-insurgency effort in Afghanistan there has, since 2006, been a cross-Government Comprehensive Approach Working Group with participation from the Cabinet Office, FCO, DFID, MOD and the PCRU with the stated objective of 'improved joined-up approaches to civilian-military planning and training'60 . The Secretary of State himself has recently stated that this comprehensive approach includes the ability to "engage, stabilise and develop" in a seamless continuum ranging from 'kinetic' engagement (counter­ insurgency) to Afghan-owned development61 . 3.42 DFID's obligations towards a "stabilisation" agenda has included providing 90% of the Stabilisation Unit (SU) funding. Development Advisors were attached to inter-donor Provincial Reconstruction Team (PRT) in Mazar-e-Sharif, Bamyan and Kandahar since 2003, prior to the UK's lead from 2006 in the PRT Helmand. ## Box 4. Dfid Expenditure In Helmand In 2006/7 DFID spent around £16 million of its £102 million Afghanistan budget in Helmand. This included £4 million of the £6.2 million UK fund for Quick Impact Projects (QIPs) and £10 million for its Helmand Agriculture and Rural Development Programme (HARDP). In 2007/8 DFID spent a further £8.1 million. This included £3 million for HARDP and £3 million for QIPs. The PRT based in Lashkar Gah has now 128 staff. As well as seconded staff, DFID had in place a Development Advisor in the PRT and a liaison officer operating between Kabul and Helmand until June 2008, and now has the liaison officer plus two permanent staff in Helmand and a third post co-funded with Stabilisation Unit. 3.43 Until 2008 DFID funded Quick Impact Projects (QIPs) delivered by the PRT in Helmand. Within the PRT, DFID is the lead UK Department on development matters, providing £7.2 million since April 2006 to support the implementation of over 296 QIPs. The purpose of QIPs is to reinforce short-term security, provide a stabilising influence through project delivery and support the extension of the government's legitimacy and authority to insecure areas. There are, however, often marked differences in the underlying objectives set for QIPs. The MOD has tended to focus on the role of QIPs in generating "consent" (and therefore force protection) and facilitating "conflict termination". The FCO tended to view them more as instruments of political engagement or strategic communication. DFID focused more on their contribution as "local community-based rapid effect programmes", a bridge to future more sustainable development initiatives62. 3.44 The cross-Whitehall GCPP, and subsequently the Stabilisation Aid Fund (SAF), provided a funding mechanism that could be used for security spending, including non-ODA spend. In this respect, it protected DFID's budget from the wider security demands of HMG while opening possibilities for innovative, prodevelopment, approaches to stabilisation. While the DFID "script" shows that £16 million of programme funds was spent in Helmand in 2006/7, much of this was through national programme expenditure (i.e. through national ministry programmes). Staff placements and QIPs funding would account for considerably less. From 2007, pressure on the DFID bilateral programme to divert funds to Helmand started to reduce due to the increased role proposed for the SAF63. ## Approach To Cross-Cutting Themes 3.45 DFID has not had a strategy for integrating the cross-cutting themes of gender, human rights and social exclusion issues into its programme. The Interim Strategy 2005/6 says that "the highest immediate priority is to […] establish the rule of law within a democratic political system that safeguards human rights", but does not expand on how this might be achieved. There is no mention of gender issues or women's rights in the TCAP or Interim Strategy, despite the government's own commitments in this area (as set out in the Compact and I­ ANDS), and the prevalence of serious violations of women's rights in Afghanistan both prior to and since the fall of the Taliban. 3.46 DFID has, however, made efforts to integrate cross-cutting issues into the ANDS by placing a staff member in the ANDS secretariat since 2006 with this specific brief. The officer was successful in defining a process whereby these issues might be included, but many issues have been marginalised since they were either inconvenient or politically sensitive. For example, the National Action Plan for Women (NAPWA), which contains specific gender benchmarks for all sectors, has still not been ratified by the President as is required. There is no easy answer to this: gender will for a long time be one of the intractable issues to which only incremental improvements can be made; DFID is not alone in its trial and error approach. 3.47 Efforts to institutionalise counter-narcotics as a cross-cutting issue have also had little success. The Ministry of Counter Narcotics has no executive power (or money), only advisory responsibilities. It has suffered from the absence of a Minister for a period of a year and then the appointment of weak ministers. CN is perhaps too politically sensitive, probably as a result of opium-related corruption reaching to the highest levels of the government. Respondents argued that a more sensible approach to ensure cross-cutting CN policy would have been to have a commission located in the office of the President. 3.48 One consequence of the slow uptake of CN issues in government is the general absence of social exclusion issues - particularly those relating to women and children - here, and, by extension in the DFID portfolio, until very recently. The Afghanistan Alternative Livelihoods Project (AALP), for example, was concerned with ensuring that the ANDS contained an agreed government policy on mainstreaming of counter-narcotics issues in rural development programmes; yet no consideration was given, as reflected in indicators, of how this might relate to women and children or their role in poppy production. ## Alignment With Dfid Corporate Policy 3.49 The initial governance strategy for Afghanistan from 2003 was largely in line with the governance Target Strategy Paper (TSP) with its focus on strengthening state capability and strong emphasis on public financial management64. However, the strategy was less in line with the TSP's emphasis on the demand side of governance including the role of civil society, and its emphasis on security and justice, rule of law and conflict issues. 3.50 The White Paper in 2006 brought with it a new focus on state responsiveness and accountability alongside capability - set out in further detail in DFID's 2007 governance publication65, which emphasised the importance of democratic politics. DFID's approach in Afghanistan has started to evolve in line with these changes, and an analysis of capability, accountability and responsiveness issues was carried out in 2007. It highlighted lack of access to justice and a functioning justice system as a key driver of state fragility. 3.51 The Security and Development Strategy (2005) states that DFID will make conflict and security analysis "routine practice". It was agreed that ten priority countries would take forward implementation of the strategy initially, including Afghanistan. DFID Afghanistan recognises that this has not been undertaken consistently. Work has started recently on the Understanding Afghanistan project, supported by an enhanced state building programme team (including a conflict adviser). Undoubtedly, DFID would have benefited from such analysis in earlier years; it would also have enhanced DFID's contribution to wider HMG discussions on state building and stabilisation, informing a more grounded view of the longer-term outlook in Afghanistan. 3.52 DFID's conditionality policy paper 'Rethinking Conditionality', (March 2005)66 flags the fact that Transitional Results Matrices are currently being piloted in some fragile states, to help apply the poverty reduction strategy principles of a unified, country-owned plan. As already stated, the direct link to MDGs in Afghanistan was agreed to be inappropriate in the early days. Reducing the risk of funds being misused through weak administration or corruption was very definitely an objective and the primary purpose of the ARTF. The latter's performance assessment framework (PAM, sometimes referred to as PAF) introduced in 2005/6 can be regarded as an early example of the transitional results matrix suggested in the Conditionality Paper. 3.53 The Afghanistan programme has conformed well to some of the central tenets of DFID's 2005 policy on working in fragile states. This includes setting realistic expectations, and ensuring long-term engagement through the ten-year Development Partnership Arrangement; and donor coordination and the use of innovative aid instruments (such as the ARTF), where DFID has been instrumental in achievements to date and has supported the government's leadership role. 3.54 Elements of the fragile states policy where DFID made less progress include understanding the political economy, where there has been little attention to such analysis until recently. DFID has prioritised its investment in "good enough governance" reforms by focusing on Public Finance Management (PFM) and PAR, and its economic management support has aimed to provide some of the basic skills and tools - the "plumbing" (to quote the Adam Smith Institute) - to develop a consensus around effective policies. However, priorities have not been clearly linked to an analysis of those aspects of state failure with the greater potential to exacerbate fragility67. The more recent focus on rule of law and the justice sector was partly a response to governance analysis carried out in 2006 that identified this as a key driver of fragility. 3.55 The OECD DAC Fragile States Principles68 were endorsed in April 2007 - while they post-date much of the evaluation period, they build on many of the central tenets of DFID's 2005 policy. They have not yet informed donor dialogue in Afghanistan, but have the potential to add value by highlighting the importance of shared analysis of context and causes of fragility (Principles 1 and 4); "do no harm" issues in relation to state building (Principles 2 and 3); the need for greater attention to inclusion, gender and human rights issues (Principle 6); and the risks of bilateral aid allocations leading to "pockets of exclusion" within Afghanistan (Principle 10). ## Management Of Risks 3.56 In all major programmes, risk factors are discussed both internally and with partners, written into project memoranda and reviewed regularly in output to purpose annual reviews. The balance of risks within the Afghanistan portfolio has moved from low–medium risk in 2004/5 to medium–high risk in 2006/7. By 2008, the overall fiduciary risk assessment for public finance management (PFM), corruption and taking into account the activities of the ARTF Monitoring Agency, was assessed as high69. Risk inflation has been driven by two factors: firstly, the security situation in Afghanistan; and secondly, the difficulty associated with delivering a well-performing programme given current government capacity constraints in Afghanistan. By mid-2007, eight of DFID Afghanistan's 31 live programmes were high risk, with a total value of £110 million, representing 25% of the live portfolio. Risk was heavily concentrated in a few large-value programmes. 3.57 The security threat is always unpredictable and outside of DFID's control. There has, however, been a tendency to express existing weaknesses within the Afghanistan government as programme threatening risks within programme design - and later to express this again as a reason why the programme failed to meet expectations. Such tautology ducks the responsibility for identifying specific mitigation strategies that should be built into the programme to ensure the risk is dealt with. 3.58 DFID and the Afghan government do not have a system in place for mutual review and assessment of the commitments in the ten-year Development Partnership Agreement (£330 million over three years, signed in 2006), although this was specified in the agreement. With 80% of DFID's funding being channelled to the Afghan government, this would seem an important element of risk management, as well as being required by the UK's conditionality policy (2005). 3.59 In the absence of a DFID methodology on differentiation of risk types (macro, fiduciary, capacity, conflict), we find that, the ostensibly "stable" ARTF has a higher risk category than some of the Helmand projects. The lack of differentiation is only one factor. The political imperative to engage in "difficult" areas (bolstered by the proportionality principle of using other agency programme documents) has meant that some projects were not thoroughly scrutinised. For example, DFID staff recognise that limited access and security constraints impaired appropriate design or management of some projects in Helmand. DFID funded 300 new wells in the province, but did not carry out a geological survey because of the security situation. The area is prone to drought, the water table has subsequently lowered and some of the wells have run dry70. Factors such as the absence of the rule of law, patronage systems, the fragile political settlement and corruption did not feature in DFID's risk analysis in the Interim Strategy, despite each having been cited frequently as major factors that continue to undermine state legitimacy and authority71. 3.60 Table 2 shows performance against risk categories for all live projects in 2007/8. DFID's review process (often undertaken externally) provides a scoring of 1 to 4 (with 1 and 2 being on target, but 3 and 4 requiring review). 3.61 The risk analysis underpinning individual programmes has been mixed, and weak in relation to the two large state building programmes that have performed very poorly - the £20 million Afghanistan Stabilisation Programme (ASP) and the £12.7 million Strengthening Counter Narcotics in Afghanistan Project (SCNIAP). At the approval stage of ASP, DFID recognised that the risks and political profile were high, but considered that these had been adequately addressed (including fiduciary risks) and an acceptable mitigation strategy developed. The significant risks of disbursing the full allocation of £20 million in one tranche at the outset were not considered, and risks in relation to the capacity and will of the Ministry of Interior were not set out in programme documentation. Performance 1 2 3 4 Not given Total High 1 1 4 1 7 14 Medium 11 4 1 18 34 Risk Low 2 2 Not given 8 8 Total 1 12 8 2 35 58 3.62 During design of SCNIAP, the risks identified included the "killer risk" (high likelihood, high impact) that a technical assistance project of this nature would not be able to achieve its purpose given the huge profits involved in the drugs trade, the power of the narco-mafia and its strong influence on government. However, the risk analysis suggested the alternative was "to do nothing". Mitigating steps identified were, for example, lobbying the Afghan government to take action against members of the government involved in the narcotics trade; and supporting reform of the rule of law and justice sector (including the MOI (Ministry of Information), police, judiciary, etc.). The latter would have required a significant shift in DFID strategy and priorities (one which has only taken place recently). 3.63 Risk analysis underpinning the more recent programmes in the state building portfolio has been more consistent and robust, reflecting an improvement in this aspect of programme design and a willingness to learn lessons from past experience. 3.64 There was little evidence from DFID Afghanistan Livelihoods Unit data that risks were being adequately monitored, managed and reported on. The type of response that would be expected if there was active risk management would be changes in the log frame and modification of the risk factors or improvements in mitigation approaches. This was rarely seen to occur, although there have been positive changes in the last two years. ## Approach To Partnerships 3.65 In general terms, DFID has gained a well-founded reputation as being a trustworthy and professional partner for both government and donors. Influence was primarily by "being there" and in leading by example; combining consistency of purpose with responsiveness in funding and actions; providing good quality consultants; and liaison between other donors. As the situation has developed, DFID Afghanistan (DFIDA) has taken policy decisions that have seen the enhancement of some relationships at the expense of others, notably a diminishing link with Afghan civil society. 3.66 *Government*. DFID has developed a strong relationship with the Afghan government at the central level. It has gained a well-deserved reputation for responsiveness, flexibility, predictability and political maturity in this relationship, and has prioritised responding to the government's most urgent priorities where possible, particularly in the early phase through rapid TA inputs, support to national programmes, and a fairly rapid move away from reactive, emergency forms of assistance. DFID has taken a proactive approach in its engagement with the government, and has demonstrated innovation and an appetite for risk that has been appreciated by the government given the very fragile environment. The government has been appreciative of DFID's position in relation to the ARTF as the largest contributing donor, which has influenced the Netherlands and Nordic countries to increase the percentage of their development assistance channelled through the budget, and is gradually having an incremental impact on the US. 3.67 DFID's engagement with provincial and local government has been limited, largely due to staffing and security constraints that make travel and interaction outside Kabul so difficult. The lack of a clear framework for sub-national governance has meant that entry points for programmatic engagement at the sub-national level have been very limited, and DFID has chosen to engage on these issues from the central level (e.g. through ASP and more recently the Independent Directorate of Local Governance, IDLG). Though appropriate, it has meant that DFID relies heavily on secondary sources to develop its own understanding of sub-national governance issues. 3.68 *Donors*. DFID took a relevant decision to be a lead player in donor harmonisation in view of the quite weak coordination among donors throughout the five-year period. In particular, DFID took a high profile lead in supporting the ARTF, but underpinned this by analytical collaboration with the World Bank and IMF, thus complementing financial leadership with intellectual rigour. 3.69 Through the ARTF, DFID was also able to demonstrate its commitment to donor harmonisation and to influence other donors accordingly. Yet the unbalancing presence of the USA, the lack of autonomy of USAID, and the ineffectiveness of UNAMA (and other UN agencies) has made this something of an elusive target. Over time, DFID and other donors began to work around the UN and there is some evidence of influence over USAID over on-budget support for Afghanistan. On CN policy, the UK Government (led by ADIDU) has made substantial efforts (and achieved success) in influencing the USA against using punitive approaches to poppy reduction (aerial spraying). 3.70 DFID's partnership with the World Bank has been strengthened not only through the ARTF but also on the PAR and capacity building of government programmes. This has included strategic support to enhance the World Bank's technical capacity (e.g. by providing seconded staff to work on PAR, and more recently funding for a World Bank post on sub-national governance). 3.71 On economic issues, DFID could have exerted more influence on some of its partners, in particular the IMF. DFID's March 2005 paper, 'Fighting Poverty to build a safer World: A strategy for security and development' argues that the IMF should be pushed to incorporate assessments of conflict issues into its lending programmes. The IMF had only a one-person Resident Rep's office in Kabul and was very dependent on DFID for quality, on-the-ground, reporting and support. While most economists interviewed by the CPE team felt strongly that DFID was indeed influential with the IMF, the fact that the IMF programme in Afghanistan is very similar to any other in a post-conflict country and that the important and obvious potential links between taxation and state building are not explored in any project documentation suggests that opportunities to push the frontiers in this particular area were not fully exploited. 3.72 *The UN*. DFID provided humanitarian support through WFP during 2003 and also to the UNHCR winter fund of the same year. From 2004, it responded to appeals to assist with refugee and IDP return (UNHCR and IOM) and to the Afghan drought appeal. At a more strategic level, it provided support to monitor food security. As time progressed, there was disappointment with UNAMA leadership and the UN. The UNDP management of the CNTF was one example of what was perceived as poor UN performance. 3.73 DFID's attempts to establish pooled funding arrangements through multilateral agencies have not always been effective. For example, the Support to the Centre of Government (SCoG) programme was originally envisaged as a multi-donor pooled funding arrangement managed by UNDP. By early 2008, DFID and USAID remained the only contributing donors, and UNDP has not added significant value to the project's management and impact, sub-contracting most of the project's outputs to the main TA provider. 3.74 *Civil society*. Neither the TCAP nor the Interim Strategy has any specific programmatic approach to supporting civil society. The evaluation would argue that this lack of focus on Afghan civil society has, in turn, limited its work on social exclusion, human rights and women's empowerment. This was despite some useful early partnerships with a small number of NGOs through its support to the elections in 2004/572. 3.75 The International Development Committee (IDC) in their recent enquiry recommended that DFID should help "to establish a robust civil society capable of holding the government to account"73. The largest ARTF-funded GoA projects are in fact delivered through NGOs, but the GoA has determinedly treated NGOs purely as service deliverers on a par with contractors. Some NGOs have moved from a focus on service delivery to an advocacy and policyinfluencing role, but have found it difficult to access donor funds for this. This is particularly important at the sub-national level where NGOs tend to have integrated programmes rather than stand-alone projects. Significant tensions exist between the Afghan government and NGOs, and DFID, along with other donors, may have shied away from supporting NGOs due either to lack of resources or to obligations towards alignment with government policy. ## Results Focus 3.76 The performance monitoring frameworks attached to the TCAP and the Interim Strategy were robust and sufficient to capture progress at the country strategy level. While some indicators inevitably point to process rather than impact, they provide a clear picture of what DFID's efforts were set to achieve. Through output to purpose reviews (OPRs) DFID appears to have monitored the indicators in a balanced and realistic manner, and has used the frameworks effectively to highlight areas where progress is still needed. 3.77 In the economic management portfolio in the earlier part of the five-year span, donor actions were aimed at getting funds flowing - the process of agreeing and identifying objectives, establishing and ensuring funding streams, and ensuring a degree of coordination. Results were therefore primarily measured in these terms. Only at the beginning of 2006 did donors, prompted by the decision to go beyond recurrent funding to investment funding in the ARTF, begin to think about measuring impact. DFID has tended to rely on the World Bank for regular reviews of the ARTF, though DFID strongly promoted the performance assessment framework for the ARTF, an important advance in donor monitoring. However, it does not yet move beyond outputs to outcome/impacts. 3.78 Results frameworks for programmes within the state building portfolio have been mixed in quality, with notable improvements and greater consistency in the design of the newer programmes. Monitoring and review have generally been regular and robust, and DFID has ensured that thorough, independent reviews are carried out, particularly where there have been indications of poor performance. Impact assessment has been difficult in almost all programmes, partly due to the weaknesses in project-level results frameworks, but also due to the inherent difficulties of measuring impact in an insecure environment. Added to this is the notorious difficulty of measuring impact of capacity building and institutional reform. 3.79 In the livelihoods sector, it was not until 2006 that reviews could be seen to be regularly taking place. By and large, project memoranda and log frames had a robust results focus. In the early area-based livelihoods work, the indicators were too input-oriented, and qualitative achievements were not adequately picked up. With increasing amounts of resources being spent through the ARTF, monitoring and reporting shifted to the coordinating agency and indicators and reporting inevitably tended to be of a more general and aggregated nature. ## Summary Chapter 3 - DFID's initial funding of humanitarian programmes - livelihoods for returning refugees and drought mitigation - was an appropriate response. - The decision of DFID to inject the major part of its funding (between 70–80% since 2004) through the government was an appropriate response to the depleted character of the state infrastructure. Its major programmes were primarily presented as peace dividend reconstruction rather than effort towards MDG assistance as an achievement. - DFID's assistance to revenue-raising through taxation failed to take account of the political importance of the "social contract" (to foster representative democracy). If not balanced with clear evidence of benefits elsewhere in the system, revenue-raising may simply confirm public opinions of a predatory state and work against improving government legitimacy. - Political economy and conflict analysis were not undertaken until 2008, and therefore did not underpin the strategic choices made. Little attention has been given to accountability issues and the demand side of governance. DFID could arguably have played an important, supporting role earlier on the rule of law and justice sector reform. - The loss of the Badakhshan programme took away a qualitative dimension of the livelihoods portfolio and inhibited the potential for a more system-wide approach towards alternative livelihoods. Nevertheless, it showed the value of a consortia approach to reducing donor transaction costs. - within the In DFID's risk analysis there has been a tendency to express existing weaknesses Afghanistan government as programme threatening risks within programme design - and later to express this again as a reason why the programme failed to meet expectations. Such tautology ducks the responsibility for identifying specific mitigation strategies that should be built into the programme to ensure the risk is dealt with. - DFID's risk analysis lacks a robust methodology and therefore is not consistent across the five-year period; the deficiencies were notably in poorly performing pro ects such as SCNIAP and ASP. - SAF that DFID has channelled QIPs money through pooled sources such as the GCPP and opened possibilities for innovative, pro-development, approaches to stabilisation. - DFID has a well-established reputation with respect to donor harmonisation and in upholding Paris Declaration principles with government and partners. - DFID has largely complied with emerging principles for working effectively in fragile states, although there has been room for improvement in areas such analysis, attention to "do no harm" issues and focusing on non-discrimination and inclusion. - A lack of focus on Afghan civil society has limited DFID's work on social exclusion, human rights and women's empowerment. - Until 2006, programme results focused on the processes rather than impacts, perhaps understandable given that government capacities and institutions were being built from a very low base. There has been much improvement in log frames since then. Access and security continue to inhibit access to programme sites and testing of results. j as context ## 4. Programme Effectiveness And Efficiency 4.1 This chapter reviews the three main pillars of the Afghanistan programme, the extent to which DFID's strategy has been effective at delivering results and whether aid resources have been used efficiently. It also discusses efficiency issues with respect to the DFID Afghanistan office. ## Delivery On Strategy 4.2 DFID's early flexibility, timeliness and the scale of its support for humanitarian programmes undertaken by UN, NGOs and the Red Cross/Crescent led to the settlement of returning refugees and IDPs. Though not a large component of the portfolio in recent years, the "watching brief" is retained and 10% of the 2007/8 overall spend was on humanitarian support. 4.3 The strategy from 2003 onwards saw some important results. Through its economic management support strategy DFID can take some credit for the fact that IMF revenue collection targets were met for five years and a Poverty Reducing Growth Facility (PRGF) has consequently been kept on track. A new currency was introduced and the Central Bank was re-established. An independent Public Expenditure and Financial Accountability (PEFA) by the World Bank found Afghanistan systems comparable to middle-income country standards74. 4.4 Continued support for the ARTF has proven strategically important with significant results (see Chapter 5). However, activities towards developing poverty data sets and strengthening the national statistics function did not materialise. Private sector led growth and sustainable increase in trade was intended for support but the form this took was poorly defined. This is hardly surprising when the DFID Interim Strategy 2005/6 confesses there is "little consensus on what will drive growth in the medium term". 4.5 With its state building work, DFID's support to the 2004/5 presidential, parliamentary and provincial elections ensured that they were carried out effectively, thus fulfilling one of the key pledges within the Bonn Agreement. The support to the ARTF promoted an effective development partnership between Afghanistan and the international community, which was to continue in subsequent years. The TCAP also began the process of strong and largely effective support to line ministries, assisting their restructure and helping them attract and manage increased budget allocations. 4.6 The three-pillar 2005/6 Interim Strategy (extended to 2008) consolidated gains made in the previous two years. There were some significant achievements through individual programmes such as the Second Public Administration Programme (SEPAP). However, a key objective of the state building pillar - improved government capacity at central and local levels with strengthened links between them - was not achieved. Improving government leadership on public administration reform (PAR) with increased on-budget donor support has also proved elusive. 4.7 DFID's livelihoods programme has seen improvements over time in the quality of management systems and reporting, with no major divergences between objectives and outcomes. DFID's Livelihoods Unit has developed an increasingly sophisticated debate about the extent to which growth should be pro-poor; one notable success has been the National Solidarity Programme (NSP, see Box 5). The Interim Strategy recognised, however, that the government's capacity to meet basic social needs and embark on the process of poverty eradication could take up to 12 years. ## Box 5. National Solidarity Programme The NSP objectives were twofold: i) to strengthen local governance with an emphasis on inclusive participation, and ii) to build confidence by demonstrating that the new government was capable of delivering a "peace dividend". The NSP was delivered through the Ministry of Rural Rehabilitation and Development (MRRD) using ARTF resources. Community Development Committees (CDCs) were supported through contractors and NGOs. By the end of Phase II in 2010, it is intended that 90% of rural communities will have received a single block grant. 75 Since its inception in September 2003, the NSP has covered 193 districts in all 34 provinces in Afghanistan, reaching 22,500 rural communities (10.5 million people) and establishing 10,000 CDCs. A World Bank survey identifies significant evidence of increased public confidence in the system of government, improved community relations, improved state–civil society relations and the empowerment of CDCs. Block grant disbursements to CDCs amounted to $166.1 million by early 2008. These have been spent on more than 4,000 sub-projects including access to basic services such as power, roads, drinking and irrigation water, and education. The NSP represents a major development success in post-Taliban Afghanistan. However, there are some concerns that the approach allows for the possibility of "elite capture" by peripheral actors adept at using the right language to attract funds. CDCs are expected to act as local governance structures that override pre-existing arrangements. CDC capacities remain low, as do their inclusiveness and sustainability. Extreme poverty and widespread illiteracy, in conjunction with social pressures, continue to constrain the development of village-level civil society 76 . DFID's support to the NSP from its inception has been critical to its continuation and growth. In 2007, it front-loaded contributions to NSP for three years to cover a funding gap. Moreover, DFID's Afghan staff have provided valuable institutional memory and continuity in the office's relationship with NSP. In the view of the evaluators, DFID's unobtrusive yet consistent and responsive support has been a major factor in the success of NSP. ## Measuring Results In The Dfid Portfolio 4.8 DFID's performance management is based on the scores given to projects at purpose and output levels. If a project largely or wholly meets its objectives, it is scored 1 or 2. A project in need of amendment would score 3 (or sometimes 4), whereas a project requiring either major revision or closure would be 4 or 5. Scoring data has been collected from Project Completion Reports and Annual Reviews. 4.9 From 2001 to mid-2006, 74% of DFID Afghanistan projects over £1 million were scored "completely" or "largely" successful. This compares well with the DFID average of 61.8% across all fragile states in the same time period. However, given the dominance of a handful of projects (notably the ARTF), these figures should be treated with caution. If one deducts the ARTF, in 2006/7, 48% of the total size/value of the live (i.e. ongoing) projects were unlikely to achieve set targets (Figure 5). 4.10 Not surprisingly, smaller projects performed better than the larger more complex government-run National Solidarity Programme (NSP), National Emergency Employment Programme (NEEP) and the National Rural Access Programme (NRAP), but even these have shown solid improvement over the past 12–24 months. 4.11 A more harmonised approach from donors is a challenge DFID has confronted from the outset of its Afghanistan programme. In general, there have been increasingly high transaction costs within a number of key ministries in attempting to coordinate the numerous donors that provide assistance. The continual proliferation of small to medium-sized bilateral initiatives often duplicate each other and use different reporting frameworks, financial years, and accounting mechanisms. Moreover, many donors (the UK being among the honourable exceptions) have failed to translate pledges into actual commitments and disbursements (see Figure 6). *USA figures: $22,800,000 pledged (2002–11), of which $10,400,000 committed and $5,023,000 disbursed (2002–2008). 4.12 One way of addressing this has been DFID's timely and effective inputs into the ARTF as the central mechanism for support to government economic management. The ARTF investment window includes activities in three areas: infrastructure, public sector capacity building and community development. Under the last of these - the sector that has received a majority of funding - are national rural development/service delivery projects such as the NSP and MISFA, as well as the provincial HARDP programme in Helmand. These projects would not have been able to get off the ground without DFID's support. Combining core project funding with the use of TA has enabled DFID to maintain flexibility while also providing information to support and influence multilateral agencies. 4.13 Preferencing in ARTF allowed DFID to legitimately claim its funds were going to rapid impact projects in the wider community whilst still supporting government systems via the ARTF. Technical assistance to the Ministry of Finance also (in theory) backs up the capacity development aim of linking ARTF procedures into a longer-term planning and budgeting process. 4.14 DFID's practice of putting its aid funds through common systems adds to the usual problems of attribution in development aid. Evidence of the results of specific inputs in a multi-funded project is therefore often related more to aid effectiveness than to wider developmental impacts. Moreover, in all programmes, security constraints prevent staff monitoring either outputs or impact in any consistent manner. 4.15 In the state building portfolio, by 2006, the overall success rate (scores of 1 or 2 in reviews) was 25%. The value for money77 was only 4.5%. To a large extent, this was skewed by two of the largest programmes in the portfolio - the Afghan Stabilisation Programme (ASP) and the Strengthening Counter Narcotics in Afghanistan Project (SCNIAP) - both of which scored very poorly on all aspects. The ASP fell far short of achieving its purpose (Box 6); for example at completion, training had only been provided to 639 trainees against a target of 14,423; the performance of the Provincial Stabilisation Fund had been poor, with only 22 projects complete and only 14 provincial development plans prepared; there had been no progress at all in the area of administrative reform; and arrangements for district infrastructure had been unsatisfactory. After withdrawing from the ASP, DFID has worked on identifying alternative means of supporting the Afghan government's efforts to improve sub-national governance, including initial support for the Independent Directorate of Local Governance (IDLG). 4.16 The Strengthening Counter Narcotics in Afghanistan Project (SCNIAP) was confounded by significant capacity problems within the MCN, and the SCNIAP steering committee was reported never to have met during the year in which DFID was supporting the project. The programme was transferred to the British Embassy in 2007. 4.17 Other projects within the state-building portfolio have had better results. Public administration reform (PAR) in Afghanistan has been focused on the most fundamental elements of building government systems (in this sense it can be seen as reconstruction, rather than reform). The Second Public Administration Programme (SEPAP) is the longest-running programme within DFID's state building portfolio. Although the mid-term review recorded that there were initial problems with lack of capacity and weak technical skills in some areas, the programme has managed to adapt and keep pace with changes in the government PAR agenda and DFID has added significant technical value. ## Box 6. Afghanistan Stabilisation Programme The Afghanistan Stabilisation Programme (ASP) is a national programme that was designed in 2004 to "establish basic security and good governance in the district and provinces of Afghanistan". Its purpose was to reverse the deteriorating security situation in many areas of the country by delivering visible benefits to provinces and districts. The programme was highly ambitious and high risk, but, with no alternatives on the table, DFID made a single payment of £20 million directly to the government in support of the Governance and Reconstruction component of the programme in March 2004, and was the first major donor to provide support. The component included training, establishment of a Provincial Stabilisation Fund ($2.5 million for reconstruction projects in each province), administrative reform and district infrastructure. The Minister of Interior was responsible for delivery. Since its inception, ASP was criticised extensively by donor and external commentators for its poor performance. DFID's 2005 review showed programme weaknesses including poor outreach to the regions, slow progress, lack of transparency and accountability and poor coordination and consultation with stakeholders. The review warned of "potentially catastrophic consequences" if institutional weaknesses were not quickly addressed. Despite these shortcomings, the ASP was given a second chance and, with strong endorsement from President Karzai, DFID continued to support it. But by the end of 2006, there was little evidence of tangible benefits on the ground. In March 2007, DFID's support ended and it was agreed that the unspent balance of funds would be reallocated to NSP. A recent commentator concluded that ASP has been "disastrous" and "assailed by multiple political and administrative problems" Several lessons emerge: (i) the purpose set for the programme was poorly defined and over-ambitious in its aim; it was conceived as a response to the deteriorating security situation without a realistic sense of what could be achieved; (ii) delivering at the subnational level in the absence of a clear and effective framework for sub-national governance proved to be highly problematic; (iii) transferring full resources available ($36.6 million, totalling 77% of donor funding) for the programme at the outset meant that DFID took on huge risk exposure and lost the ability to leverage this resource in relation to effective performance; (ii) failure to comply with DFID best practice in terms of programme design (including development of a log frame) meant that progress was difficult to monitor and assess, particularly at purpose level; and (iii) the risk analysis set out at the project's approval stage was weak and mitigation steps proved to be insufficient. 4.18 By the end of 2006, DFID's internal review of SEPAP concluded that "mixed progress" had been achieved in Priority Restructuring and Reform (PRR) of key ministries. Important achievements included reform of the Finance and Rural Development ministries where political leadership has been strong. The Independent Administrative Reforms and Civil Service Commission (IARCSC) 78 . had developed merit-based and transparent recruitment procedures, including a new Independent Appointments Board (IAB) for senior grades. However, recruitment had not always been transparent. Greater support for the IARCSC was needed to support their leadership in an ambitious and complex area79. 4.19 Central reform of government agencies has seen good progress, especially the Cabinet Secretariat and the Chief of Staff's office in the Office of the President. Progress on PRR across the Office of the President is well advanced, and was supported through additional TA inputs from DFID. 4.20 In 2005/6, almost £45 million was spent on the livelihoods sector, a tenfold increase on the previous year. £20 million was contributed over three years to the government's Micro-Finance Investment Support Facility of Afghanistan (MISFA), which gives small loans of around £100 to the poor. Nearly 75% of those receiving loans are women. So far, over £83 million worth of small loans have been given to about 243,000 Afghans, to help shopkeepers, tailors, farmers, builders and others. 4.21 TA and capacity building within key ministries has seen some important results. In 2005, the Ministry of Agriculture, Irrigation and Livestock (MAIL) was reported to be able to spend only 13% of its budget. By 2007, this had increased to 60% of its budget. 4.22 In supporting coordination at central level, DFID has brought donors together to form a technical working group to develop and gain funding for the Ministry of Rural Reconstruction and Development (MRRD) Afghanistan Rural Enterprise Development Programme currently being formulated. DFID has also been active in the Alternative Livelihood working group in the Ministry of Counter- Narcotics (MCN). It has been successful in setting three high-level CN-relevant mainstreaming indicators, and has pushed hard for regular donor meetings on NRAP and the Horticulture and Livestock Project (HLP). 4.23 DFID support to rural reconstruction programmes has been an effective use of resources. DFID gave £18 million in 2005/6 to the National Rural Access Programme (NRAP), which has generated over 15.8 million days of labour. Around 9500km of rural roads have been built or repaired, as well as schools, health clinics and water schemes. DFID also provided £17 million over three years to support the NSP (see Box 5). £10 million was given to the Helmand Agricultural and Rural Development Programme (HARDP) in 2006, which has so far completed over 200 wells and most of 50km of road; with a further 700 wells and 200km of road under construction. ## Delivery On Gender Issues 4.24 In DFID's support to elections, detailed attention was given to gender issues during design, implementation and review of projects. For example, within the civic education programme that DFID supported prior to the 2004 presidential elections, 137 of the 412 civic education trainers were women, and training of Afghan election staff included gender issues; 14,500 audio tapes distributed were specifically designed to encourage female participation in the affairs of Afghanistan; 531,501 women were reached through the civic education process preceding the 2004 presidential elections, against a target of 328,800. As a result, 41% of registered voters were women. 4.25 The integration of gender or social exclusion issues at state institutional levels has been less impressive. Apart from small-scale support to the Ministry of Women's Affairs80, there is little evidence to suggest that DFID's programme has given attention to the integration of women into the PAR process more widely, or that it has made efforts to align with the government's commitment to greater participation of women professionals at all levels of the civil service81, including through affirmative action policies82. 4.26 In the livelihoods portfolio, the NSP and MISFA both had a fairly strong focus on the role of women. It was stated, for example, that up to 75% of the MISFA (micro-credit) programme was focused on women. But neither this nor the NSP project memoranda had indicators for how to report impact on women83. ## Working With Other Uk Departments 4.27 Much effort has been put into working relationships between the MOD, FCO and DFID in Kabul and Helmand and these were generally reported as positive and constructive. A great deal of effort was expended on cross-Whitehall discussions to explain the rationale, objectives and ways of working of each department to the others. One difficulty frequently cited is the turnover of staff, demanding constant briefings, some of which are missed. 4.28 In the initial three years (2001–2004) effective working between DFID, FCO and the MOD was impaired by not co-locating DFID with the Embassy in Kabul, and improvements in post-2005 liaison when all departments were co-located bear this out. A core task of the new Stabilisation Unit is to draw lessons from previous operations on effective inter-departmental working. 4.29 DFID has established a close and effective working relationship with the Governance and Political sections of the Embassy in Kabul. The MOD led on security; FCO led on governance, rule of law and human rights; and DFID led on economic and social development. However, this meant that DFID could not easily draw on its global experience on core governance work, notably in the security and justice sector. 4.30 In counter-narcotics, DFID worked closely with other government departments through the Afghan Drugs Inter-Departmental Unit (ADIDU), formed in 2004. ADIDU was created to bring about a coordinated multi-faceted approach to CN in Afghanistan. Between 2005 and 2008, ADIDU was allocated £130 million, of which DFID contributed about half out of its core budget (i.e. not the Afghanistan budget itself), earmarked for livelihoods. The lion's share of the budget (about £44 million per year) went towards government policing, judiciary and prosecution services around CN. In addition to funding, DFID has provided strong support to ADIDU through seconding staff to the unit. 4.31 A perennial challenge within the CN strategy has been whether an alternative livelihoods support can be offered following poppy eradication. The UK's view is that this creates perverse incentives for farmers to grow more poppies if such support is the reward. Moreover, as ADIDU staff have argued, if the sole response capacity resides with weak government entities such as the MCN, then DFID should consider supporting more immediate and effective agents (NGOs or contractors, for instance) to undertake this work while sustainable government institutions are still being built. It should be noted that DFIDA is providing valuable support to the mainstreaming of CN approaches in MAIL and MRRD. In addition, the research and dissemination undertaken by RALF and linked to AREU has produced positive results. The recent 'Economic Incentives' policy document brings together six years of CN research and experience of diversified livelihoods. ## Dfid Staff Time, Numbers And Efficiency 4.32 Since opening the DFID office in Kabul, one of the key constraints to programme efficiency has been the difficulty in recruiting staff for Afghanistan, even more so in finding staff willing to live in the provinces84. An inappropriate level of staffing for the ambitious scale of the Afghanistan programme is a key theme that underpins many of the findings of this evaluation. 4.33 Until 2006, there was not an efficient distribution of staff between Kabul and London given DFID's delivery objectives. The "light footprint" approach agreed by DFID's top management effectively imposed a "cap" on international staff levels (6), which meant that the ratio between Kabul and London was 6:9, deemed wholly unrealistic by Heads of Office at that time. There had also been a high Staff Appointed in Country (SAIC) turnover throughout the five-year period. The TCAP review of 2004/5 reported significant problems with staffing levels given the high level of demands on the office. It has been difficult for such a small team to maintain the depth of programme engagement necessary to continually influence strategic direction. 4.34 By the end of the evaluation period, staffing levels had increased (even as the security situation has deteriorated), and the length of time that staff were choosing to stay in Afghanistan had also increased, with more staying for up to 18 months. In early 2008, there were 38.5 staff members (19 UK staff in Kabul, 2 UK staff in Helmand, 3.5 in London, 3 secondees to World Bank and other UK departments, and 11 SAIC). The pressures on the office were still immense, particularly due to the continued high level of political interest in the programme. 4.35 Support to capacity building of state institutions requires a high level of staff and advisory capacity. The evaluation found that the staffing made available to deliver on DFID's state building and governance strategy fell far short of what was needed to deliver on expectations at ministerial level and in HMG. A fulltime governance adviser was not in place in Kabul until mid-2006. Taking breather breaks into account, there has been an equivalent of three full-time staff responsible for delivering on the state building agenda, which the evaluation finds insufficient. 4.36 The shift away from multiple projects and the focus on Helmand from 2005/6 began a period of particular pressure on staff. Security went through a marked decline that resulted in the shift of the DFID office to the Embassy compound and increased restrictions on staff movement. Ensuring the security of DFID partners also became a major constraint to programme quality. Meanwhile, a constant element of staff activity has been responding at short notice to questions from Whitehall and Westminster. 4.37 Poor and intermittent service delivery of Quest and other IT systems to DFID Afghanistan has made it more difficult for the team to deliver on its objectives, and has contributed to long working hours. ## Summary Chapter 4 - Projects under economic management have been undertaken efficiently. Creating an effective development partnership between Afghanistan and the international community, particularly with respect to the ARTF, has been largely achieved. However, projects through trust funds tend to score better on aid effectiveness than on development impacts. Activities towards developing poverty data sets and strengthening the national statistics function did not materialise. - There have been successes in DFID-supported elections, restructuring priority line ministries and in initial steps towards tackling corruption. Latterly, there has also been some progress in donor coordination around the process of restructuring the justice sector. Public administration reform (PAR) has also had some success through the SEPAP project, and DFID has added significant technical value throughout. - Yet some of the weakest projects have been in the state building portfolio. The ASP and SCNIAP were the largest, but also the worst performing programmes. Within ASP, the performance of the Provincial Stabilisation Fund was poor, with only a few projects completed and no progress at all in the area of administrative reform. Efforts to improve government capacity at central and local levels and strengthen links between them have not produced good results; indicators of progress on the functioning of government Helmand) were not met. - Despite strong analysis, DFID has not been able to make much progress on counter-narcotics. The CNTF has had little government buy-in. - TA and capacity building within key ministries has seen some important results in the livelihoods sector; notably in the MAIL. Risk-spread and learning through alternative livelihoods projects (rural development, business development services, marketing, trade development, etc.) could have been improved by retaining some elements within the livelihoods programme in areas other than Helmand. - MISFA and NSP, Despite some impressive outputs in programmes such as integration of gender and social exclusion issues has been weak throughout the portfolio. Environmental issues were covered at project level only. - Prior to 2006 there was not an efficient distribution of staff between Kabul and London given DFID's delivery objectives; since then, staff ratios have improved, but staff pressure to deliver on HMG priorities has been immense. at provincial level (including ## 5. Programme Impact And Sustainability 5.1 In this section, we discuss the impact the programme has had on improving governance and security in Afghanistan. Impact would usually relate to progress on MDGs for poverty, health, education, etc., but since the DFID programme objectives were explicitly not about poverty reduction, we discuss here the sustainability of the various programme elements, and the extent to which DFID has added to national capacity. ## Improving Governance 5.2 DFID is keenly aware of the difficulties of assessing and demonstrating impact in the Afghan context. The lack of good national or provincial data and security constraints on access to beneficiaries (for both DFID staff and partners) impedes the measurement of progress or decision making. DFID Afghanistan recognises the importance of sharing the burden of monitoring with other donors and has also begun exploring increased use of national staff and independent consultants to carry out monitoring missions. 5.3 Early research pointed to the specific implications of aid effectiveness for longterm peace building and security, highlighting the value of DFID's support to coordination, strengthening the Ministry of Finance and helping create an effective public administration while ensuring all assistance is recorded on budget85. Nevertheless, it is difficult to assess the collective impact of DFID's interventions on high-level goals such as state building, peace building and security. 5.4 At a programmatic impact level, however, the economic management portfolio has contributed discernible results. The ARTF has been in line with best practice principles for structuring and managing trust funds in post-conflict situations, and DFID's support is in accordance with the Paris Declaration's principles regarding Ownership, Alignment, Harmonisation and Mutual Accountability for donor funding86. Since May 2002, the ARTF has mobilised $2.4 billion from 28 donors through government systems. Around 85% of all disbursement out of ARTF has funded government's recurrent costs including around 50% of the government's total wage bill since 2002/3. The ARTF supports salaries of about 220,000 civil servants each month, over half of whom are outside Kabul. 5.5 However, the impact of the ARTF on the government's legitimacy and ability to deliver, particularly outside Kabul, remains open to question. Capacity in the provinces to deliver services has been largely neglected. Budget execution is therefore highly variable. Whereas the Ministry for Reconstruction and Rural Development (MRRD) spent 71% of its development budget in 2005/6, the Ministry of Interior spent only 32%, education 24%, and agriculture 22%. In April 2007, Afghanistan Research and Evaluation Unit (AREU) research showed that "very little of the non-salary Ordinary Budget had been spent outside Kabul, meaning that provincial and district-level civil servants have had few funds to carry out their duties. This has caused government support to drop among provincial civil servants and residents of rural areas."87. 5.6 More broadly, some progress has been made in building up a more professional, merit-based civil service with DFID's support88. The Priority Reform and Restructuring (PRR) process allowed staff in key departments to be placed on an elevated pay scale for a fixed term in exchange for restructuring. By March 2007, new job descriptions had been written for over 43,000 positions, and 7,800 of these had been filled through the new "merit-based" selection process. The World Bank reports that there is "little doubt" that ministries that have undergone a serious PRR process, such as the Ministry of Public Health and the Ministry of Rural Rehabilitation and Development, have benefited in terms of higher pay and better performance89. 5.7 In state building, DFID made important contributions to marked improvements in public administration reform. The early provision of technical assistance to create a database to address the problem of "ghost workers" enabled the Ministry of Finance to engage in transparent discussions with ministries on budgetary claims. The Ministry of Defence staff figure was reduced from 400,000 to 8,000 as a result of this support. 5.8 DFID's support to the elections in 2004/5 contributed to the political transition process that was necessary to establish the core institutions of the state, including Afghanistan's first democratically elected parliament in over 30 years. The Presidential elections in 2004 and the Parliamentary and Provincial Council elections of 2005 both saw high turnouts at the polls: 70% of the 11 million registered voters voted in 2004, 51.5% of the 12.5 million registered voted in 2005. The election was viewed as free, fair and transparent by nearly all parties concerned, and took place with little violence or disruption. All major ethnic and religious groups won representation in parliament, in addition to the strong showing by women. 5.9 PAR reforms to date have failed to enhance the legitimacy of a state still viewed by many as corrupt, inefficient and a vehicle for patronage and inter-group competition; and that patronage remains a dominant element in the recruitment of staff90. Public accountability is the least advanced element of Afghanistan's PAR strategy, with formal oversight institutions, notably on justice, being slow to develop. The current role of Afghan NGOs/CSOs is more that of project implementer than defender of public accountability, and by 2006 only two NGOs were monitoring government performance and working on integrity issues91. 5.10 Through its earlier work, DFID was able to demonstrate the value of working with civil society, but this was not sustained. For example, the Afghan Civil Society Forum (ACSF) was able to reach insecure areas where UN civic educators were unable to reach, and to work successfully with local mullahs and communities to encourage people to vote. The ACSF Project Completion Report noted that "over and over again, it showed that those NGOs with good links to leaders (traditional and religious) had better access to communities (including women) and could cope better in insecure environments". 5.11 In the livelihoods portfolio there is evidence that the National Solidarity Programme (NSP), to which DFID has contributed substantial funding has contributed to enhancing state legitimacy. To date, the programme had led to the election of over 15,000 Community Development Councils (CDCs), and the financing of over 17,000 projects. $244 million has also been disbursed in grants to the communities92. 5.12 The creation of CDCs have "introduced a dramatic change in the development resources available to many communities in the country, and where these resources have been converted to successful sub-projects, the acceptance and legitimacy of the programme, and by extension the government, has been expanded."93. There are some outstanding problems with delayed disbursements of block grants and the consequences (political as well as developmental) of removing the possibility of second block grants to CDCs has not been fully appreciated94. ## Improving Security 5.13 Evidence suggests that insecurity and criminality are on the increase and threaten to jeopardise the developmental progress made since 200195. Confidence in the government, particularly in its ability to provide rule of law and a fair judicial system, is very low. Central government does not enjoy full support from all regions and social groups, and is itself fragile and deeply factionalised96. 96 British and Irish Agencies Afghanistan Group (BAAG), evidence submitted to the International Development Committee, sent on 23 April 2008. 5.14 With high levels of insecurity in Helmand in particular, farmers continue to turn to poppy as the crop most certain to provide a financial return; and if they move to wheat because of international price rises, this may not be directly to do with success in the CN strategy97. Integrating CN with counter-insurgency may thus be a flawed approach - there are linkages between the poppy industry and insurgents, but the political economy is far more complex than this. 5.15 DFID's perception of QIPs in Helmand as being "rapidly implemented projects that serve as down payments on promises of political and economic progress - buying time for a government to establish its own capacity to deliver public services…. supporting and cementing political settlements between populations and their government at local levels"98 has been challenged by an independent evaluation. The Tribal Liaison Office (TLO), commissioned by the Stabilisation Unit, undertook a focal group(s) assessment of local Afghan perceptions and reached rather different conclusions. Within the work carried out by the PRT (the QIPs in particular), there was dissatisfaction over procurement, construction quality, lack of monitoring and over the role of interpreters. From 2008, the UK no longer funded QIPs99. Outside of QIPS, on the credit side, support for police training was well received and that DFID support through line ministries (particularly MRRD) was seen as being effective100. ## Capacity Building, Technical Assistance And Corruption 5.16 According to a 2006 OECD survey, very little of the technical assistance provided by donors was through coordinated programmes consistent with the government's strategy, and just one-third of donor analytical work was undertaken jointly101. The lasting capacity building impact of massive TA inputs - $1.6 billion - is doubtful102, and there are commonly held views that the capacity building objective of TA in Afghanistan has remained largely an empty concept103. 5.17 TA does not automatically equate to capacity development, even if training is included. DFID's TA inputs are recognised as high quality in comparison to other donors, and DFID has made progress in guiding how TA should be used within government. However, DFID does not appear to have weighed up the value-added of TA compared to other aid instruments for achieving state building objectives, or to have carried out explicit analysis of the incentives and disincentives for reform provided by TA. This is particularly in relation to sustainable capacity building where there is often a high risk of temporary capacity substitution rather than skills transfer or sustainable reform. Research suggests that TA in Afghanistan is currently a "gap-filling option with little lasting impact in terms of capacity building. Given the magnitude of its overall cost, there is a sense of the significant opportunity cost for the country104." 5.18 TA projects in DFID's economic management portfolio have had mixed results. They were set up to strengthen the policy environment through capacity building and introducing "good budgeting principles that focus on achieving service delivery, [including] unified current and capital budgets based on available resources allocated to priority programmes105". 5.19 Annual estimates of recurrent and investment budgets have been produced but institutional arrangements are not wholly transparent; bureaucratically correct procedures and decisions are invariably hampered by ministers' political agendas. There have also been problems with disbursement of NSP funds through the ARTF. By early 2008, NGOs were owed $13 million that should have been released six months previously. The fact that the deadline for ARTF integration into the national budget has now been extended twice (from 2006 to 2010 and now to 2020) can be interpreted as evidence that progress on improving the policy environment has been limited. 5.20 DFID has been acutely aware that tackling corruption at all levels of government is an arduous challenge. The purpose of the Tax Administration Reform project was to develop a "professional [tax] administration that is supported and trusted by business and the community [with] a transparent system of rights, responsibilities and safeguards within tax collection106". New tax laws have been enacted, and, to this extent, the legislative basis for a sound and transparent tax system has been put in place. However, the extent of corruption and its reduction has not been measured by the project107. Furthermore, DFID project staff were concerned that other (mostly US-funded) actions on corruption in the public sector have been conducted in a punitive fashion that runs the risk of undermining progress in the DFID project. ## Counter-Narcotics 5.21 Opium poppy cultivation in Afghanistan rose for the second successive year in 2007, to 193,000 hectares, driven by growing cultivation in the south, south west, and, to a lesser extent, the east. Cultivation in Helmand rose by 48%. There is some good news, though. In 2008, the country's overall poppy cultivation fell by 19% to 157,000 hectares, but in Helmand (the single largest producing province) it remained the same as 2007108. Many experts suggest caution over attributing this to the counter-narcotics strategies of the international community; the reductions in total cultivation are largely due to economic (high wheat prices) and environmental (drought) factors, and could easily be reversed109. In Afghanistan's 34 provinces, 18 are now poppy free as opposed to just 6 in 2006110. Sustainable reductions in poppy cultivation can only be achieved with improved security, economic growth and governance rather than a set of limited activities around counter-narcotics111 . 5.22 As we have seen, in 2006 DFID shifted its resources away from integrated rural livelihoods in Badakhshan. The evaluation found some evidence to suggest that reductions in development activity in the area have resulted in greater instability in these original pilot areas, with local power holders becoming more belligerent. The political economy of opium poppy cultivation in Badakhshan is such that sustained reduction of poppy growing is seen only where local government administrations actively implement CN policy in conjunction with a multi-faceted NGO programme that cover livelihoods, social development, particularly with a focus on women and girls, and capacity building112. It is interesting to note that similar conclusions have been drawn from Nangarhar Province113. 5.23 The UK is a designated "partner nation on counter-narcotics", supporting the Afghan Government to implement the National Drug Control Strategy (NDCS). By its own admission, the UK has had greater success in restructuring the police force and criminal justice institutions around CN than it has in actually reducing production through promoting alternative livelihoods114. There is an asymmetry between the expectations of donors and government for rapid changes in the opium economy and the ground reality that would suggest a far longer period of time to see the opium economy dwindle. Quick-impact 110 http://www.fco.gov.uk/en/fco-in-action/uk-in-afghanistan/Counter-Narcotics/afghanistan-CN- FAQ. 111 AREU, ibid. 112 Saltmarshe, D. 'Integrated Rural Rehabilitation to Improve Livelihoods and Curb Poppy Production', evaluation report for DFID, June 2006. 113 Mansfield, D. 'Water Management, Livestock and the Opium Economy: Resurgence and Reductions: Explanations for Changing Levels of Opium Poppy Cultivation in Nangarhar and Ghor in 2006–07', AREU, May 2008. 114 See, for example, British Embassy Kabul reports on http://www.britishembassy.gov.uk/servlet/Front?pagename=OpenMarket/Xcelerate/ShowPage&c=Pa ge&cid=1079976715832 projects have had very limited sustainable results. Effective CN efforts are a combination of economic development, provision of social services, and better governance and the rule of law - in other words, massive sustained financial commitment, political vision and stamina115. ## Gains In Aid Effectiveness 5.24 DFID has an extremely good track record on aid effectiveness issues in Afghanistan, widely recognised by other donors, government, civil society and implementing partners. It added value early on through timely support to the Afghanistan Assistance Coordination Authority (AACA), which allowed the Afghan Transitional Authority to take a strong lead on donor coordination from 2002, and also helped provide procurement capacity to facilitate rapid and transparent utilisation of donor resources. Within the state building strategy, DFID has shown leadership and positive influence on other donors, leading to improved impact on the ground. For example, during the elections in 2004/5, DFID's responsiveness, leadership and early commitment to the process allowed the work of planning, registration and civic education to start on time, and put pressure on other donors to commit the necessary resources. 5.25 DFID is aware that the debate over appropriate resources required to meet targets set by framework agreements such as the Afghanistan Compact has not been effective. Huge sums have been spent on for-profit, private contracting firms and consultants and there has not been a clear understanding among donors of resource levels needed in each sector, and of the relationship between these sectors. As stated in Chapter 2, Afghanistan's aid per capita is remarkably low, yet total foreign aid accounts for 90% of public expenditure in Afghanistan116. The dilemma for all donors, including DFID, is that almost 50% of the country - mainly the most-needy rural areas - is inaccessible to foreign aid workers and the situation is getting worse117. 5.26 In a context where some two-thirds of foreign assistance bypasses the Afghan government budget, thereby undermining efforts to build effective state institutions, DFID's decision to channel the vast majority of its resources to government has undoubtedly been correct, and the gains made by the Afghan government as a result of the funding flows through ARTF can be largely credited to DFID's leadership role and influence in securing donor support. $800 million was spent on development activities through government systems in 2006/7, compared to only $400 million in 2005, highlighting improvements in government systems as well as increased donor flows to government. ## Summary Chapter 5 - Tangible results can be seen from DFID's support to coordination, strengthening the Ministry of Finance and helping create an effective public administration while ensuring all assistance is recorded on budget. Early financial and capacity support to ARTF has been exemplary, demonstrating good practice in relation to the Paris Principles. Progress has been made in building up a more professional, merit-based civil service with DFID support. - DFID has an extremely good track record on aid effectiveness issues in Afghanistan, recognised by all stakeholders. - DFID's crucial support to the elections in 2004/5 contributed to the political transition process that was necessary to establish the core institutions of the state. - Nevertheless, it is difficult to assess the collective impact of DFID's interventions on high-level goals such as state building, peace building and security. Capacity in the provinces to deliver services has been largely neglected. Sustainable impact is impaired by the inability of the government to establish national unity linked to political settlement; this cannot be addressed by the kind of technical support provided by DFID. - There have been marked improvements in public administration reform (PAR), but there may have been too much focus on building technical capacity, primarily in Kabul, while downplaying issues of political legitimacy, especially at the local level. - Evidence suggests that insecurity and criminality are on the increase. In Helmand, DFID support for MRRD has been effective to date, and support for police training has been well received. But despite some significant outputs, local perceptions of QIPs have not been positive. Delivering assistance in ways that will have a developmental impact on the lives of Afghans requires longer timeframes, specialised expertise and sophisticated forms of interaction with target beneficiaries. The UK has, since 2008, no longer funded QIPs. - Despite some very useful DFID TA inputs, notably in the economic management portfolio, TA does not automatically equate to capacity development, even if training is included. DFID has not weighed up the value-added of TA compared to other aid instruments for achieving state building objectives; nor is there an explicit analysis of the incentives and disincentives for reform provided by TA. - Corruption remains a fundamental challenge. DFID has contributed incremental improvements through, for example, the Tax Administration Reform Project, but the problem is more profound. Justice institutions are the least developed among formal oversight organisations. ## 6. Lessons And Recommendations Strengths And Weaknesses Strengths 6.1 The evaluation found the following to be the major strengths of DFID in Afghanistan: - There has been clarity and consistency of objectives; for example in supporting public financial management, enabling donor funds to flow and backing the development of core government functions. - From the outset, DFID has recognised the importance of long-term aid commitments; for example, DFID was the first to make three-year commitments to ARTF, and to sign a ten-year aid agreement. - Flexibility and responsiveness in funding has enabled both a rapid response and learning on the job. - Through investments in livelihoods research, DFID provided cutting edge and innovative development ideas to be nurtured in a complex environment. - DFID was active in promoting donor coordination and in furthering the Paris agenda on donor harmonisation; it had a proactive engagement with a wide range of stakeholders, and was comfortable in taking a lead where required. - DFID has maintained strong management structures and procedures throughout the five-year period. - There has been a high level of technical expertise from DFID; for example, in complementing the leading economic multilateral donors - World Bank and IMF - with flexible bilateral TA while also adopting a position of influence. The high quality of staff and consultants is noted by the government of Afghanistan - "I fired 60 consultants in my time as Minister of Finance, none were from DFID"118. - DFID has demonstrated high levels of commitment under significant pressures. Also staff security and well-being has been taken very seriously. ## Weaknesses 6.2 There are also some important weaknesses: - Political economy analysis was insufficient until recently. - Some parts of the economic management programme were too narrowly focused on technical issues without appreciating the wider political implications - for example, in tax administration. - There was too much attention on government functions, fiscal targets, donor flows and fiduciary risk management, and not enough on understanding the real economy in Afghanistan (e.g. economic regions, urbanisation, migration, unemployment) and its trends. For example, an analysis on economic incentives in counter-narcotics was not commissioned until 2007; a continued lack of substance to Private Sector Development (PSD) strategy even though it has been a stated priority since 2002. - Risk analysis and mitigation has been inconsistent and not linked to analysis. - Gender, human rights and social exclusion issues were not given enough prominence. - The relationship with civil society has not been well developed, especially on advocacy. - There has been an ineffective approach to integrating CN with the wider programme. - DFID has not been strong on inter-disciplinary working; there has been notable pressure to deliver programmes at the expense of seeking synergy between work streams. - Several high-profile and high-value programmes, notably within the state building portfolio, have been insufficiently staffed. Continuity across all programme strands has also been affected by the practice of staff taking twoweek rest breaks every six weeks. ## Recommendations For Dfid Afghanistan: - Now may be the time to reconsider whether Public Administration Reform (PAR) should be the central plank of DFID's state building programme. It is unclear whether DFID continues to have a comparative advantage on PAR if a strong lead from the World Bank (WB) is in place. DFID should develop a clear analysis and argument for its continued support to PAR if this is to remain central to the state building portfolio. - Significantly greater attention to rule of law and justice is warranted. Support to National Justice Programme (NJP) has been very positive; DFID has a comparative advantage in relation to other donors. Traditional justice systems will need to be considered, though with caution in respect of human rights issues. DFID should draw on its experience in other fragile states. Options to gradually extend the reach of formal systems into communities (e.g. community paralegals) should be considered. - The National Solidarity Programme (NSP) overall is a "high-risk, highreturn" success story. However, the governance dimension of Community Development Councils (CDCs) is complex and NSP has not yet demonstrated its impact on local governance. The future role of CDCs within sub-national governance needs careful consideration, while ensuring that the social capital built up through NSP to date is used effectively. New support for UN Habitat's work on urban CDCs and links with municipalities offers opportunity for learning about their interplay with formal governance structures. DFID should develop a clear strategic view on the role of CDCs in sub-national governance. This needs to be linked to the generation of policy regarding the development of provincial structures: the provincial and district assemblies and the role of line ministries. - DFID has not fully explored the value of engaging more fully with Afghan civil society, including improved relationships with NGOs as intermediaries. More attention should be given to corruption and accountability mechanisms (including the role of NGOs and Civil Society Organisations (CSOs) in monitoring and advocacy). - DFID (and other donors) have not fully used the accumulated expertise NGOs have in maximising farm-related income opportunities, employing a country-wide approach to reduce vulnerabilities to poverty and offering alternatives to narcotics production. DFID should place greater emphasis on the issue of investment in agriculture, including an integrated "value chain" approach to agriculture that addresses issues of land, water, credit management and labour. - Assumptions around gender and human rights, and the corresponding dialogue with Afghans including Afghan women in leadership positions have not been fully explored. This is not about having a new "women's rights" programme, but about ensuring effective integration into future programmes, building on successful examples such as DFID's support to the elections. DFID should seek opportunities to support Afghans to lead appropriate, culturally sensitive approaches to improve the treatment of women in Afghanistan. - The 2007 Development Assistance Committee (OECD DAC) Fragile States Principles could usefully stimulate discussion on the importance of shared analysis among donors of context and causes of fragility; "do no harm" issues in relation to state building; the need for greater attention to social inclusion, gender and human rights issues; and the risks of bilateral aid allocations leading to "pockets of exclusion" within Afghanistan. DFID is already engaged in a useful debate around these principles. DFID should continue to use the principles to further donor dialogue around aid effectiveness issues and challenges in Afghanistan. - The UK's ten-year Development Partnership Arrangement (DPA) with Afghanistan requires a mutual review and assessment of the commitments (initial tranche of £330 million over three years, signed in 2006). DFID should ensure that adequate monitoring and review processes are in place for the DPA in line with similar commitments elsewhere in the world. ## For Dfid Globally: - Understanding the political economy and state building context of fragile states required early investment in robust analysis. DFID Afghanistan undertook such analysis in 2008, but perhaps this should have been earlier. DFID should ensure that programmes are framed within an early understanding of conflict dynamics, state legitimacy and political settlement in advance of more technocratic issues. - The devolution of DFID's offices to country level has consequences and the right balance of staff between London and Afghanistan was not always met. There needs to be greater senior management realism regarding the scale of the challenge - and what DFID needs to deliver effectively - in a highprofile protracted conflict arena. In this regard, DFID should ensure consistent senior management engagement at Whitehall level, and ensure that staff ratios and skill mix between London and the country are sufficient. - TA does not automatically equate to capacity development, even if on-thejob training is included. The transition from multi-donor trust fund to general budget support requires longer-term capacity building. The creation of professional cadres needed by both the public and private sector should involve supporting further education and private professional training bodies in addition to civil service training on the job. - In view of the overwhelming size of the informal sector in developing countries (let alone post-conflict developing countries), private sector development is unlikely to begin in the Ministry of Commerce. On the other hand, as demonstrated by MISFA, rapid development of a small-scale financial sector is possible even in difficult post-conflict conditions. DFID should do more to consolidate and deepen its understanding and experience of private sector development in the particular conditions of post-conflict economies. - The debate over appropriate resources required to meet targets set by framework agreements such as the 2006 Afghanistan Compact has not been effective; thus there has not been a clear understanding among donors of resource levels needed in each sector, and of the relationship between these sectors. For the UK, underpinning all interventions should be a shared crossdepartmental consensus on the scale of investment needed to meet the challenge; this should then inform the influencing strategy pursued by DFID vis-à-vis other donors. - DFID's comparative advantage on governance issues within HMG has not been given sufficient recognition in Afghanistan. DFID should advocate its role on governance, and ensure that the division of labour agreed in future HMG strategies recognises governance as a central element of economic and social development. - The division of labour agreed among donors in Afghanistan was driven largely by political bargaining among donor countries. As a result, the security and justice sector - arguably the most crucial sector - has performed badly. DFID should develop effective ways of communicating lessons learned at ministerial level and try to ensure that these lessons inform engagement in other fragile states in future. - There is as yet no proven relationship between stabilisation and longer-term development demonstrated in Helmand. Delivering assistance in ways that will have a developmental impact on the lives of Afghans requires longer time-frames, specialised expertise and sophisticated forms of interaction with target beneficiaries. The context of HMG's military and political engagement in Afghanistan made it particularly difficult to assess the relevance and appropriateness of DFID's strategic choices against the standard evaluation criteria for a development programme. Consideration should be given by DFID, with other government departments, to the most suitable way of evaluating DFID programmes operating in such a context in future, including whether a joint HMG evaluation framework should be developed. ## 7. Management Response 7.1 We welcome the report of the Country Programme Evaluation for the period from January 2002 to December 2007. The study was timed well to feed into the development of DFID Afghanistan's new Country Plan and has helped us learn a number of lessons. 7.2 The report notes the challenging context in which the country programme has been delivered. Afghanistan is a conflict-affected, fragile state that is important geo-politically and remains one of the poorest countries in the world. Over the period, the programme has evolved from one of humanitarian response after the overthrow of the Taliban to an integrated, developmental approach as part of a broader HMG strategy both nationally as well as in Helmand. 7.3 The context has changed since the evaluation period and it was not possible for the evaluation to take on board some important developments that have taken place both on the Afghan side and in terms of UK strategy. Towards the end of the evaluation field work period, in November 2007, HMG outlined a strategy for engagement, stabilisation and development to help Afghanistan remain a legitimate state. This strategy, and subsequent updates, has helped to transform cross-Whitehall working. Strong relations on the ground with other UK government departments (MoD, FCO) mean that we can deliver on this strategy through the three D's of defence, diplomacy and development. 7.4 As noted in the report,, in mid-2008, the Government of Afghanistan published the Afghanistan National Development Strategy (2008-2013). The two strategies together provide an important evolution in the context for DFID's country programme. In addition, ministries highlighted as being unable to deliver now have new and more dynamic ministers, which should help in improving service delivery. Hence, a number of findings are less relevant and some recommendations are now of less value. 7.5 The findings indicate that much of the programme has shown high degrees of relevance, effectiveness and efficiency, impact and sustainability, including in the areas of support to economic management, progress on a more merit-based, professional civil service and local impacts through livelihoods programmes. Also, that DFID behaviour in Afghanistan demonstrates good practice in relation to the Paris Declaration on Aid Effectiveness and principles of aid effectiveness in fragile states. We also note that the evaluation points to areas of the programme that performed less well. 7.6 The report notes DFID's strong emphasis on the management of the economy, highlighting the high quality of technical assistance. While progress may have been slower than originally envisaged, it was clearly a prudent decision to extend the life of the ARTF. Together with the GoA and others, we feel that a longer term partnership is needed to maintain progress in a number of important areas supported by the ARTF. An independent evaluation of the ARTF published in August 2008 has highlighted its value, including in strengthening government systems: "The Monitoring Agent has helped put in place systems and instruments to strengthen Afghanistan's Public Financial Management"119. The financial controls built within the ARTF were based on a fiduciary risk assessment agreed with other donors. DFID finalised a Fiduciary Risk Assessment in 2008 to coincide with the preparation of a new country plan. 7.7 The evaluation questions overall the **utility of technical assistance**. Yet, elsewhere, it notes that DFID's technical assistance made an important contribution to improvements in the functioning of the Ministry of Finance. We agree that technical assistance must in part help build Afghan capacity. We believe that others have much to learn from how DFID has provided technical assistance and that it remains an important aid instrument in fragile states. 7.8 The evaluation questions the impact of the ARTF on the government's legitimacy and ability to deliver. This does not match with how the ARTF has helped the government deliver services, which a more recent survey shows is appreciated by Afghans120. It has helped deliver tangible services that have changed the lives of ordinary Afghan families. Around 6 million children are now in school, over a third of them girls - a stark contrast to when it was illegal for girls to go to school. Yet, we also recognise that public opinion also raises concerns around the lack of jobs and income opportunities121. This has been taken on board in our new country plan. 7.9 The evaluation notes that attention to linking taxation with a 'social contract' was not articulated. We agree that this is a critical element in building and securing a legitimate state and look to build that within implementation of the new country plan. 7.10 The evaluation notes that the DFID programme has evolved to have a greater focus on state-building, as a central plank of strategy, and that DFID has increasingly brought its global experience and leadership in this area to bear. We agree that more work is needed to reach out further to provincial and district governments (though elsewhere the evaluation recognises the excellent work through the National Solidarity Programme to enhance state legitimacy at local levels). DFID intends to support the roll-out of the Government of Afghanistan's sub-national governance policy. Also, new work is planned on linking informal and formal justice systems in order to enable improved functioning of the informal system. DFID Afghanistan is also intending to expand work on corruption alongside other government departments in the new country plan. 7.11 We agree that more emphasis should now be given to engagement with civil society on corruption and accountability. This is being taken forward in our new country plan. DFID has continued to strengthen its analysis of the political economy (for example, through a study, 'Understanding Afghanistan', completed in 2008, including a Strategic Conflict Assessment). 7.12 The evaluation is critical of a shift from area-based development with non-government partners to work on national programmes. Yet, the evaluation also points out that our area-based development focus in Helmand through national programmes with the Ministry of Reconstruction and Rural Development has been effective. We believe that government visibility is crucial, if it is to retain and build the confidence of its people. 7.13 Building on our experiences, the new country plan will continue to work through national programmes and help ensure they work effectively at local levels and build constructive partnerships with local administrations and non-government partners. We will continue to build on the finding DFID's flexibility allowed a good mix of funding and use of technical assistance. 7.14 The evaluation notes recent falls in **poppy cultivation**. A new initiative to sustain reductions in poppy cultivation is now being developed by the Government of Afghanistan with DFID's support that takes into account lessons from successful and unsuccessful efforts to date. 7.15 The evaluation notes that there was little attention to cross-cutting issues such as gender. We now have a Gender Equality Action Plan that helps us address this weakness. 7.16 We agree there is a paucity of good, reliable data on Afghanistan and welcome that, within these limitations, DFID's support is regarded as largely effective and efficient. The evaluation recognises that DFID has ensured that thorough independent reviews have been carried out on its programmes, while noting both the security constraints on doing this well in some areas. We agree that it is difficult to assess and demonstrate impact in the Afghan context, given the lack of good national and provincial data and security constraints. We are now working to address data paucity with the Government of Afghanistan and other partners. Internally we are improving our logframes and a new Results team will further improve how we manage for impact and measurement of performance. We are also taking steps to improve monitoring of DFID funded programmes in Helmand. 7.17 The evaluation notes that working relationships between MoD, FCO and DFID in Kabul and Helmand were generally positive and constructive, though with concerns about DFID's initial engagement in Helmand. In 2008, DFID has strengthened it engagement in Helmand with a representative located in Helmand supported by a Helmand team. We have also transferred a deputy head position to London to strengthen our engagement across Whitehall on Afghanistan. 7.18 The evaluation notes that **DFID has kept to its commitments**. We take on board the recommendation for mutual reviews with the Government of Afghanistan on progress of the 10-year Development Partnership Agreement. We are now well-placed to do this within the context of a new four-year Country Plan that will focus on state-building, growth and livelihoods, and Helmand, as part of a wider HMG strategy in support of Afghanistan. Marshall Elliot Head of Office DFID Afghanistan ## Annex 1. Terms Of Reference Terms Of Reference For Evaluation Of Dfid Country Programmes - 2008/09 Introduction DFID's performance management system is supported by periodic independent evaluations at project, programme, sector and thematic level. Evaluation Department (EvD) carry out four to five Country or Regional Programme Evaluations (CPEs or RPEs) annually. These terms of reference (ToRs) set out the scope of work for the 2008/09 period. The CPEs provide important accountability and lesson learning functions for DFID. The primary audience for the evaluations is the UK government and DFID senior managers including heads of country offices. All evaluation reports are published externally. Countries proposed for evaluation in 2008/09 are Afghanistan, Ethiopia, Cambodia, DRC and Sudan. Each evaluation will use the countries' most recent Country Assistance Plan (CAP) or equivalent, and related policy documents. Where the five year evaluation period spans two CAPs, or other strategy documents, the evaluation will relate to both. While country-led approaches are central to the way that DFID works, socio-political and environmental contexts will influence the progress and form of the development process. The CAPs articulate the country offices' plans for operationalising corporate objectives within the country context, and in most cases they will build upon or reflect the national Poverty Reduction Strategy Paper (PRSP). These plans are therefore the logical starting point for the evaluation. ## Overarching Objectives The main objectives of the country programme evaluations are to assess: - Country strategy and links to poverty outcomes and DFID's corporate objectives - Choice of aid instruments - DFID's role as a development partner - DFID's success in implementing its country strategy The CPEs will assess the DFID country programmes in terms of standard criteria although these may be customised to a degree for individual studies. The generic evaluation matrix can be seen at Annex A. It is based on DAC evaluation criteria adapted to take account of the fragile states context and considers: - The relevance of country programme objectives and the logic behind them given domestic policy objectives for poverty reduction, as well as DFID's own corporate level objectives - The effectiveness of the overall programme in achieving the objectives set out in the country strategy, including DFID's choice of aid instruments, harmonisation with other stakeholders, policy dialogue and influencing - The efficiency with which programme plans are translated into activities, including human resource and office management, collaboration and harmonisation with other stakeholders, policy dialogue and influencing, the use of financial instruments ## And To The Extent Possible Sustainability - are the reforms/ changes supported by DFID's country programme moving in the right direction and are they likely to be sustained? Has local capacity been built? Has transparency and accountability improved? Outcome - What did the country programme achieve the objectives set? Did the positive outcomes DFID achieved justify the financial and human resources used in the programme? Attribution - Given the direction of travel and external factors, overall how far did the country programme make a positive contribution to poverty reduction? How good a development partner was DFID? The success with which the programmed had mainstreamed the cross-cutting issues of poverty, gender, HIV/AIDS and environment into all of its activities. What were the variables influencing the process of inclusion? What was the impact on the achievement of wider programme objectives? Ensure that any information collected or evidence produced on multilateral effectiveness in each CPE is highlighted and forwarded to EvD. ## Methodology, Outputs & Timing The consultants will produce one study report and executive summary for each country or region. The report shall be approximately 50-60 pages long (excluding annexes) and will include detailed lessons and recommendations. The evaluation summary (EvSum), should be approximately 4 pages, and will include the response from the relevant DFID office/Department, which EvD will obtain. The other outputs required from this contract include: - Inception reports detailing the way in which each individual CPE is to be carried out and showing the customised evaluation matrix. - A presentation of preliminary findings to country offices before the end of the fieldwork for each study. - A publishable synthesis report pulling together findings across individual CPEs. In 2008/09 this will cover regional programmes and in 2009/10 it will cover fragile states. DFID also requires access to the evaluation team's interim evidence summaries, e.g. completed matrices, although it is not expected that these should be of publishable quality. Each evaluation will involve an 'inception visit' and 'fieldwork mission'. EvD and the consultant team leader will undertake the inception visit. A team of 3-6 consultants will undertake the fieldwork, generally involving up to 3 weeks in country. In some cases the inception phase may be undertaken in the UK and the fieldwork may be organised a little differently given the fragile states focus in this round of countries. The 'inception visit' has four key objectives: i. Ensuring staff in the DFID country office are fully informed about the evaluation, its purpose and how it will work. ii. Ensuring country/ regional office staff have an opportunity to feed in key questions they want the evaluation to address and decide whether they wish to undertake self-evaluation as part of the process. iii. Determining the exact nature of the individual evaluation and resolving key methodological / practical issues. iv. Ensuring the evaluation team has access to all relevant contacts - including all those who have worked in the country/ regional programme over the fieldwork period and all relevant partners. Between the inception visit and fieldwork the consultants will amend the standard evaluation framework for the study to address any country-specific issues raised during the inception visit. An inception report containing this matrix will be signed off by the country office. If the DFID country office wishes to undertake self-evaluation they will be encouraged to produce a log-frame for the entire country programme (unless this already exists), detailing the logic of their interacting projects and programmes and assessing what has been achieved. If the country office does not undertake this work and there is not clear guiding framework, the evaluation team will attempt to create a similar log frame as part of the evaluation approach. EvD will provide supporting documentation relevant to each CPE to the consultants in good time. This will include project documentation and relevant documentation about the design, implementation and monitoring/ evaluation of the country/ regional strategy and individual programmes (but not background policy information). Prior to undertaking fieldwork, the evaluation team need to be familiar with the DFID programme, the country context and the full range of DFID policy papers that are relevant to the country programme. The consultant is responsible for identifying and engaging a team of consultants appropriate to each country context from within their company/ consortium. The team must have good evaluation skills, understanding of DFID and the local context and ability in the languages of the country. The team should cover all the major sectors of the country programme and if possible should include at least one locally based consultant as a full team member. The consultant is responsible for setting up and planning the main field visit. If EvD wish DFID staff members to accompany the consultant CPE team, additional terms of reference specifying the roles and responsibilities will be developed. The planned consultancy team for each of the CPEs covered in this contract is shown at Annex B; it is recognised that there may yet be some changes to this (due to either DFID or the consultants) - particularly for the studies programmed later in the year. During the main fieldwork the sector specialists and evaluation team leader will interview DFID staff (current and past) and partners (in government, multilaterals, other donors etc.) about all aspects of the programme over the five year evaluation period - using checklists as appropriate. Web based surveys of staff and other stakeholders (e.g. other donors and NGOs) will also be trialled on a pilot basis. The evaluators will systematically scrutinise the available documentation and supplement this where possible, and then use all evidence gathered to complete the evaluation matrix. One matrix should be completed for each main sector, pillar or thematic area, and the evaluation team leader (and deputy) will use these to compile the final report. Fieldtrips outside the capital city are not a standard part of a CPE but may be used on occasion if applicable. This will be determined during the inception phase for each study. Before leaving the country the evaluation team should make a presentation to the country office on emerging findings. Within 4 weeks of the fieldwork finishing a high quality draft report of 40-60 pages (excluding annexes and with an Executive Summary) will be submitted to EvD. Following initial checks within EvD this will be sent to the country office and staff there invited to correct any factual errors and make comments. Although country offices may challenge findings they disagree with, and sometimes have additional information to support a claim, EvD will support the evaluation team to ensure that the report remains a true independent evaluation. A second draft report and evaluation summary will be produced taking account of relevant comments. These will be subject to external quality assurance against the criteria shown at Annex C. It is expected that all draft reports submitted will have been checked for typos, formatting errors and consistency of data presented. The Synthesis Report (which in 2009 will focus on fragile states), will be guided by a workshop scheduled for around June 2009 and should be completed by October 2009. It is anticipated that there will be a further meeting between the authors and relevant DFID policy leads to discuss emerging recommendations - perhaps after the first draft report has been produced and considered by DFID. This will assist in building ownership for the synthesis report. The report should be finalised within three months of the date of the workshop - including an Evsum; a follow up dissemination event may be required. Note, during 2008 the synthesis report from the last contract will be produced focusing on regional evaluations. The consultants will work to the strict deadlines set out in Annex 4 and the timeliness of the delivery of reports is of the essence. Any changes to these deliverables must be agreed in advance with EvD. Team composition and timelines will be agreed prior to commencement of each of the country studies, including the necessity of any follow up visit to the country if major issues remain unresolved. The consultancy should start in April 2008. ## Competence And Expertise Required One consultancy organisation or consortium will be appointed to deliver the outputs described above. A managing consultant with extensive evaluation experience and a track record of managing country/strategic level evaluations will be required to manage the planning and delivery of the CPEs. This individual will be expected to have strong written and oral communications skills as he/she will play a role in communicating lessons learned both to country programme personnel and to a wider DFID audience. Each CPE should have a named team leader with expertise in evaluation methodology and monitoring and performance management issues. This must include understanding of the complexities of country programme evaluation. The Team Leader must also have up to date knowledge of DFID policies and performance, planning and data systems. Access to our online systems will be provided. Team Leaders will all have CTC security clearance, and for fragile states, this will be increased to SC clearance. Each CPE team will be made up of a combined skill set covering governance, economics, social and institutional development and human resource management and the number of team members will be appropriate to the country programme. There is not one model that will work for each country/ region being evaluated, so flexibility in team composition is essential. The team members for each country evaluation will need expertise in evaluation methodology and familiarity with development issues in the CPE countries. They should also have up to date knowledge of DFID policies and systems. Relevant experience in cross-cutting issues like gender mainstreaming, HIV and AIDS and the environment. The team should normally include a strong national/regional component. The consultancy team will have responsibility for: - maintaining ethical standards in implementing the evaluation - the timely production of evidence-based conclusions, lessons and recommendations to demanding quality standards - managing logistics in country, with support from the DFID country office, to the extent mutually agreed in the respective Inception Visit. ## Reporting And Dissemination The consultants will report to the Country Programme Evaluation Team Leader or the Deputy Programme Manager in DFID Evaluation Department. Reports will be published and distributed, electronically and in hard copy, to a wide ranging internal and external audience. The consultants should be prepared to present their findings to DFID staff and others as appropriate. Specific disseminations arrangements will be determined on completion of each country report and synthesis. Evaluation Department March 2008 ## Annex 2. Persons Consulted | Type of Organisation | Numbers consulted | Roles | |-------------------------|----------------------|----------| ## United Kingdom (Uk) | Adam Smith International. | Five | Including Directors. | |---------------------------------|---------------------------------|---------------------------------| | Afghanaid | One | Chairman | | Asian Development Bank | One | Principle Governance Specialist | | Two | Including advisor and programme | | | manager. | | | | British Agencies | | | | Afghanistan Group | | | | (BAAG) | | | | Cabinet Office | Two | Afghanistan advisors. | | Afghanaid | Three | Including Directors.. | | Consultants | Three | | | DFID (Department for | | | | International | | | | Development) | | | | Eighteen | Including Permanent Secretary, | | | Director, UN, Conflict and | | | | Humanitarian Division, Head of | | | | Western Asia Department, | | | | Internal Audit and former DFID- | | | | Afghanistan personnel | | | | Stabilisation Unit | Three | Including Head of Stabilisation | | Unit and advisors | | | | FCO (Foreign and | | | | Commonwealth Office) | | | | Five | Including Afghanistan Strategy | | | Unit and Afghan Drugs Inter- | | | | Departmental Unit (ADIDU) | | | | personnel. | | | | Media Support | One | Managing Director. | | MOD (Ministry of | | | | Defence) | | | | Two | Directorate of Joint | | | Commitments (DJC) and former | | | | Head, Helmand Task Force. | | | | One | Commandant General. | Royal Navy, Fleet HQ | | (Head Quarters) | | | | One | Senior Lecturer. | SOAS (School of Oriental | | and African studies) | | | | Womankind Worldwide | One | Programme Manager. | Afghanistan One Chairperson Afghan Human Rights Commission One Director. Agency Coordinating Body for Afghan Relief (ACBAR) Afghanistan Development Association (ADA) Two Including Deputy Managing Director Adam Smith International Five Including country manager and project personnel. One Director AIHRC (Afghan Independent Human Rights Commission) Aga Khan Foundation One Chief Executive Office, Afghanistan. Asia Foundation Two Including Country Representative One Director Inkishafee Tarbiawee Markaz (AITM) Three Including director and researcher Afghanistan Research and Evaluation Unit (AREU) British Embassy Six Including the Ambassador and 1st Secretaries. Canadian Embassy One 1st Secretary One Country Director. CARE (Christian Action Research and Education) One Kabul Representative Catholic Relief Services (CRS) Civil Service Commission One Senior Adviser Fourteen Including Head of Office, advisors and programme staff. Department for International Development (DFID) Stabilisation Unit Three | European Community | One | Programme Manager. | |------------------------------------|---------------------------------|-------------------------| | Two | 1 | | | st | | | | Secretary and Head of | | | | Counter Narcotics (CN) team. | | | | Foreign and | | | | Commonwealth Office | | | | (FCO) | | | | Foreign and | | | | Commonwealth Office | | | | (FCO), Helmand | | | | Three | Including Provincial | | | Reconstruction Team (PRT) and | | | | Afghan Drugs Inter- | | | | Departmental Unit (ADIDU) | | | | pesonnel | | | | German Embassy | One | 1 | | st | | | | Secretary. | | | | One | Mayor | Government of | | Afghanistan, Helmand | | | | GRM International | Two | Advisors | | One | Director | Helping Afghan Farmers | | Organisation (HAFO) | | | | IMF (International | | | | Monetary Fund) | | | | Four | Including Senior economists and | | | Kabul resident representative | | | | Japan Embassy | One | 1 | | st | | | | Secretary | | | | Kabul University | Two | Including Foreign | | Relations/Cultural Affairs | | | | One | Director General Alternative | | | Livelihoods | | | | Ministry of Agriculture, | | | | Irrigation and Livestock | | | | (MAIL) | | | | Media Support | One | Deputy Project Manager | | Mercy Corps. | Two | Including Programme | | Co-ordinator and sector specialist | | | | Ministry of Education | One | Minister | | Ministry of Finance | One | Project Manager | | One | Managing Director | Microfinance Investment | | and Support Facility | | | | Afghanistan (MIFSA) | | | | (MOD) Ministry of | | | | Defence | | | | Two | Including Deputy Commander, | | | Task Force Helmland | | | | Three | Including Deputy Minister and | |-----------------------------|----------------------------------| | programme personnel. | | | Ministry of Rural | | | Rehabilitation and | | | Development (MRRD) | | | One | Director. | | Afghanistan (MSPA) | | | OXFAM | One | | One | Deputy Director General | | Office of Administrative | | | Affairs, Government of | | | Afghanistan | | | Office of the President | Two | | of Staff | | | Two | Sector advisors. | | Team (PRT) | | | Two | Including finance and programme | | director | | | Serving Emergency Relief | | | and Vocational Enterprise | | | (SERVE) | | | Tribal Liaision Office | Two | | One | Country Director | | Afghanistan | | | Two | Including Deputy Special | | Representative. | | | United Nations Assistance | | | Mission in Afghanistan | | | (UNAMA) | | | One | Consultant. | | and Crime (UNDOC) | | | One | Senior Programme Manager. | | Habitat | | | Two | Gender specialists | | United Nations | | | Development Programme | | | (UNDP) | | | United Nations | | | (UNIFEM) | | | Six | Including Officer-in-charge and | | Deputy Director | | | World Bank | Seven | | ARTF Coordinator and sector | | | specialists. | | | 16 Air Assault | One | | (PRT) Officer. | | ## Annex 3. List Of Reference Documents The evaluation team had access to DFID and FCO internal project documents, reviews, papers and correspondence too numerous to list here. Existing key DFID policy documents of relevance to Afghanistan were also referred to. There were also a large number of confidential documents made available to the team leader. The following list of documents is in addition to the huge DFID and FCO literature the team consulted. ## General Afghanistan Independent Human Rights Commission (2007), Economic and Social Rights in Afghanistan II, August 2007. Astri Suhrke (2008), *The Democratisation of a Dependent State: The Case of Afghanistan*, FRIDE, http://www.fride.org/publication/340/the-democratisation-of-a-dependentstate-the-case-of-afghanistan. Astri Suhrke (2006), *When More is Less: Aiding Statebuilding in Afghanistan,* September 2006: FRIDE (ibid). British Overseas Agencies Group (2006), Afghanistan Briefing, (BOAG): September 2006. Cammack, D., McLeod, D. et al (2006), Donors and the 'Fragile States' Agenda: A Survey of Current Thinking and Practice, ODI: March 2006, UK. Center for Strategic and International Studies (2007), Breaking Point - Measuring Progress in Afghanistan, Washington DC, February 23, 2007. Chr. Michelsen Institude et al (2005), Humanitarian and Reconstruction Assistance to Afghanistan 2001-2005: From Denmark, Ireland, the Netherlands, Sweden and the United Kingdom, DANIDA: October 2005. Courtney, M. et al (2005) *In the balance: measuring progress in Afghanistan*, CSIS: July 2005. Danida (2006), *Humanitarian and Reconstruction Assistance to Afghanistan*, 2001-05, from Denmark, Ireland, The Netherlands. Sweden and the United Kingdom: Ministry of Foreign Affairs of Denmark. Danida. European Network of NGOs in Afghanistan (ENNA) and British and Irish Agencies in Afghanistan (BAAG) (2006), Position on Provincial Reconstruction Teams 2006, BAAG. Foresti, M., Booth, D. and O'Neil, T. (2006) Framework Paper, Aid Effectiveness and Human Rights: Strengthening the Implementation of the Paris Declaration, ODI: September 2006. German, T., Randel, J., Tasneem, M., and Baker, L (2005) 'Aid to Afghanistan: building on the momentum?' Development Initiatives briefing Available at: http://www.globalhumanitarianassistance.org/afbull05final.pdf. Government of Afghanistan (2006) Afghan National Development Strategy (ANDS): An interim strategy for security, governance, economic growth and poverty reduction, GOA: January 2006. Government of Afghanistan (2006), The Afghanistan Compact, The London Conference on Afghanistan, 1 February 2006. Grunewald, F., Pascal, P. et al (2006), Linking Relief Rehabilitation and Development in Afghanistan, Groupe URD (Kabul): April 2006. International Development Committee (2003), Afghanistan: the transition from humanitarian relief to reconstruction and development assistance, First report of session 2002­ 03, House of Commons, London, 23 January 2003. International Development Committee (2008), Reconstructing Afghanistan, Fourth Report of Session 2007-08, House of Commons, London, 14 February 2008. Jonathan Goodhand & Mark Sedra (2006), Afghanistan Peace Conditionalities Study, Netherlands Institute of International Relations, June 2006. Karp, C. (2006) 'Leading by example: Australia's Reconstruction Task Force and the NGO Civil-Military Relationship in Afghanistan', Security Challenges, 2 No 3: p.1-8. M Suleman & D Copnall (2006), *Independent Review of GCPP Afghanistan*, CA-SDF, April 2006. Matt Waldman (2008), *Falling Short: Aid Effectiveness in Afghanistan*, ACBAR Advocacy Series: March 2008. UNDP (2006) Fact Sheet Counter Narcotics Trust fund (CNTF), UNDP: January 2006. United Nations (2007), Report of the UN Secretary General on Afghanistan: 27 September 2007. United Nations (2008), Report of the UN Secretary General on Afghanistan: 6 March 2008. World Bank (2006), Interim Strategy Note for the Islamic Republic of Afghanistan for the Period FY 07-FY 08, Washington, 2006. ## State-Building Altai Consulting (2004), Assessment of NSP Facilitating Partners: Common Final Report (including appendices on Lessons Learned and Key Recommendations), Kabul, August 2004. Asta Olesen & Asger Christensen (2007), Afghanistan - Assessment of the scope for strengthening the role of NSP Community Development Councils in local governance. Report for the World Bank TA on Public Administration Reform, June 2007. Chris Berry & Adaeze Igboemeka (2004), Service Provision in Difficult Environments: Issues arising from DFID support to health sector interventions in Burma, Afghanistan, Nepal, DFID (unpublished), 2004. Ghani, A. and Lockhart, C. (2006) *Rethinking Nation-Building*, The Washington Post: 1 January 2006. Hamish Nixon (2007), Aiding the State? International Assistance and the Statebuilding Paradox in Afghanistan. AREU Briefing Papers, April 2007. Inger Boesen (2004), From Subjects to Citizens: Local Participation in the National Solidarity Program, Afghanistan Research & Evaluation Unit (AREU) Working Papers, Kabul, August 2004. Jonathan Goodhand & Paul Bergne (2004), Evaluation of the Conflict Prevention Pools, Afghanistan, DFID Evaluation Report, EV 647, March 2004. Post-War Reconstruction & Development Unit (2006), Mid-term Evaluation of the National Solidarity Program, University of York, May 2006. US Department of State and US Department of Defence (2006), Office of Inspector General: *'Inter-agency Assessment of Afghanistan Police Training and Readiness Program'*: November 2006. World Bank (2005), Afghanistan Poverty, Vulnerability and Social Protection: An Initial Assessment, WB Report No. 29694-AF, March 7, 2005). Yama Torabi (2007), *Assessing the NSP: The Role of Accountability in Reconstruction*, Integrity Watch for Afghanistan, 2007 (www.tiri.org). ## Livelihoods British and Irish Agencies Afghanistan Group (2007), Briefing Notes: NGO concerns on the immediate and long term impact of the existing aid policies on front-line livelihoods programmes and essential services in Afghanistan, 27th February 2007. Chipeta, S. (2006), 'Concepts for Community Based Agricultural Service Systems in Afghanistan', Support to Strategic Planning for Sustainable Rural Livelihoods - Afghanistan, Danish Agricultural Advisory Service: January 2006. Jonathan Goodhand, NGOs and Afghanistan: new challenges, old dilemmas. Letter from British and Irish Agencies Afghanistan Group to the International Development Committee: 23 April 2008: Inquiry into Afghanistan. Mansfield, D. and Pain, A. (2005) *Alternative Livelihoods: Substance or Slogan*, AREU: October 2005. World Bank and DFID (2008), Afghanistan: Economic Incentives and Development Initiatives to Reduce Opium Production, February 2008. ## Economic Management Government of Afghanistan [Afghanistan Ministry of Finance] (2004) Financial Report: 4th Quarter 1380 - 2nd Quarter 1383 [21 January 2002 - 20 September 2004], GOA: October 2004. ## Annex 3 - List Of Reference Documents Government of Afghanistan [Afghanistan Ministry of Finance] (2006) Summary of International Assistance to Afghanistan, GOA: November 2006. Ruth Lister (2006), Moving Forward? Assessing Public Administration Reform in Afghanistan, Afghanistan Research and Evaluation Unit: September 2006. Scanteam (2005), *Assessment, Afghanistan Reconstruction Trust Fund (ARTF)*, Final Report: Oslo: March 2005. World Bank (2006) Managing public finances for development (Ch. 8 Delivering Services to the Afghan people), World Bank: February 2006. ## Annex 4. Afghanistan Country Programme Evaluation Matrix Sector:_____________________________ | EVALUATION | KEY QUESTIONS | |--------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------| | CRITERIA | documents to be identified in inception | | phase) | | | (Chapter 1: Introduction and Methods) | | | Context (to form Chapter 2 of report: Context: 2002 - 2007) | | | Political and post-conflict situation. Key events over period including factors beyond control of development partners, MDG | | | progress (and variation by gender, rural/ urban, ethnic group etc.); progress with peace-building and capable, accountable and | | | responsive state-building. Importance of aid to the country and no. of donors active in area. Key agreements / strategies / | | | reviews that influenced DFID's work. | | | Relevance (to form Chapter 3 of report: To what extent was DFID's strategic approach relevant in a fragile states context | | | Overall strategy | | | 1. Throughout the evaluation period and as the context evolved, did DFID have clear and focussed | | | Reference should be made to reputable | | | and areas/sectors | | | country/ sector strategies that explained the rationale for interventions supported? What were the key | | | data and analysis from other agencies, | | | selected for | | | underlying assumptions of the programme from 2002, and did these change over time? (eg options | | | academics, etc. | | | intervention | | | considered, analysis done, choices made and why etc.). | | | 2. How far were strategies based on a realistic analysis of the country situation, including political | | | economy/conflict analysis? What analysis did the DFID Office undertake, or draw on in developing its | | | strategies and what tools/frameworks did it use? Was it appropriate/sufficient? Did it consider the links | | | between development and conflict? Did it inform strategy? | | | 3. Over the period, how far were strategies aligned with development needs and policy priorities of the | | | country, (eg aligned with the the National Development Framework (NDF, April 2002), Securing | | | Afghanistan's Future (SAF, March 2004), and Interim Afghanistan National Development Strategy (I- | | | ANDS, December 2005)? Related to off-track MDGs? In line with peace-building strategy/needs etc.) ? | | | 4. How far were strategies aligned with or determined by broader HMG objectives? How were the links | | | between political, security and development objectives addressed? | | | 5. To what extent were strategies in line with corporate priorities? (e.g Fragile states policy (2005), | | | Conditionality paper (2005), conflict guidelines, cross-Whitehall working and relevant sector strategies). | | | To what extent does the consensus | | | established around the Bonn (2002) | | | and London (2006) agreements - that | | | ISAF was essentially a peace | | | enforcement operation, and that PRTs | | | would help extend the influence of the | | | central government - still hold; and | | | what does this mean for the DFID | | | programme? | | For example, when key decisions were being made in 2005/06 (over Helmand, and the comprehensive UK approach) was there any disconnect between policy (White Paper, etc) and these decisions? 6. Were strategies in line with a focus on state-building and delivering security and justice for the poor - strengthening core functions of the state (e.g. security and justice, revenue mobilisation) and improving accountability and legitimacy? What are the key papers that would allow consultants to identify appropriate state-building activities and so address question 6? 7. Were changes to strategies appropriate given the context or were there too many/ too few adaptations? Risk Management 8. How systematically did DFID assess the external risks (ie political governance, conflict, economic and fiduciary) and the internal threats to the country strategy? Were regional and international factors assessed? Did DFID consider risk of potentially negative impacts of development assistance on the conflict situation? Were measures taken to minimise these e.g. through tools such as Do No Harm, Peace and Conflict Impact Assessment etc. 9. How did DFID address the inherent contradiction between a short-term outlook and approach commensurate with military actions on the ground (particularly in hazardous areas such as Helmand) and a longer term developmental approach? How did DFID adapt itself to a 'stabilisation' agenda? And is there a proven relationship or dependence between stabilisation and longer-term development? 10. How comprehensive were plans to minimise the identified risks? What tools were used - e.g. scenario and contingency planning Portfolio profile 11. What interventions did DFID support over the evaluation period? Was there an appropriate Descriptive summaries of the balance in the size and scope of the chosen portfolio? programme should be in a box. DFID's choice of aid instruments 12. What mix of aid instruments was intended and how did this change over the evaluation period? Was there a sufficient balance between use of long term and shorter term instruments? And between pooled funding, multi-lateral and bi-lateral funding? 13. To what extent did choices about aid instruments reflect the political economy and governance / conflict context of the country (e.g. analysis of incentives and disincentives provided by aid and instruments used vis a vis conflict reduction and state building))and DFID policy? Was there an appropriate balance between support through government and non-governmental channels? 14. Was funding shifted between instruments, or delayed / suspended? Was this in line with the DPA and other broader HMG policies? DFID's partnership working 15. How did DFID approach working with: a) Government (central, provincial, local), b) civil society, c) multi-lateral organisations (WB, UN, EU), d) other bilateral donors? Were there explicit strategies? What was the basis of any influencing agenda? Was the balance among chosen partners appropriate? 16. How did DFID work with OGDs - FCO, MoD, Cabinet Office. How and when did a joint HMG strategy emerge? Was there pooled funding / staff / systems? Was security sector work integrated with OGDs? 17. To what extent did DFID seek to strengthen harmonisation across the donor community? (was there joint analysis, pooled funding, joint reporting etc?) 18. How well did DFID consult with and communicate its aims and objectives to development partners? | DFID's approach to cross- | 19. Did DFID have a strategy for mainstreaming cross-cutting issues such as conflict, gender, social | |--------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------| | cutting themes | exclusion, human rights, HIV/AIDS and environmental protection? (and was this consistent with | | corporate policy) on these issues?). Was counter-narcotics treated as a cross-cutting issues, and | | | how? | | | Level and allocation of | | | resources | | | 20. Were strategies appropriate to the level of resources anticipated? | | | 21. How far did planned spending and use of staff time reflect strategic objectives? Was there an | | | appropriate balance between staffing in London and Kabul? | | | 22. Was geographic coverage too narrow / wide for resources available? | | | 23. Were other donor resources and plans in the country taken into account to avoid over / under - | | | aiding and aid volatility? | | | A brief outline of the scope/scale | | | of other donor programmes can | | | be used to contrast with the DFID | | | programme. | | | Results focus | 24. How far were DFID's planned interventions sufficiently results-focused and subject to monitoring? | | (e.g were there results frameworks? Was there a sufficient balance between quantitative and | | | qualitative indicators to fully understand impact?) | | | PRISM documents | | | 25. How far were the results of reviews used to reconsider design/ direction of work,, resources | | | (financial and human) and staff allocation priorities? | | | II. Effectiveness and III. Efficiency (Chapter 4: How successful was DFID in terms of engagement in development and delivering | | | results in a time of conflict?) | | | Delivering on strategy | 26. How far were objectives set out in strategies achieved in practice (CAP performance objectives | | and other strategic outcomes)? What explains any areas of divergence? | | | 27. How effectively did the country office manage the strategic risks that emerged? To what extent did | | | effective risk analysis assist DFID's engagement through the post-conflict transition? | | | Results | 28. How far were the objectives and performance indicators for individual DFID interventions | | Draw on PCR, AR docs, and | | | achieved? (drawing on data from project reviews and PRISM scores) | | | 29. How did individual DFID programmes function during the different phases of conflict (immediate | | | post-conflict/humanitarian, post-conflict transition, new insurgency etc.)? What explains key | | | successes and failures with regard to programme objectives? What was the role of govt and non | | | comment on validity of scores (if | | | able). | | | govt. actors? | | | 30. Were the choices regarding discontinuing programmes (e.g. in livelihoods) appropriate, given the | | | wider context? | | | Efficiency | 31. Was DFID's actual disbursement in line with expectations and plans? Were there any significant | | changes or delays? | | | 32. How was staff time spent? (influencing/ policy work, project/ programme work, field work, | | | Look at staff timelines, skills and | | | issues of continuity. | | | corporate reporting/ activities, liaising with OGDs and other donors) | | | 33. Was the skill mix and continuity of staff appropriate to the country context and strategy? | | | Aid effectiveness | 34. How effective was the mix of aid instruments in achieving objectives? Were the different | | instruments used in a complementary way? | | | Not to be confused with the | | | 'relevance' section (above). This | | | 35. How effective has DFID been in pursuing its development agenda (including peace building) with | | | partners including other parts of the UK Government, the partner country Government, Civil | | | Society, NGOs? | | | points to evidence on | | | effectiveness of the choices | | 36. Has DFID operated in accordance with the emerging principles of aid effectiveness in fragile states? [And if not, why not? Have there been the tensions? ] 37. How well has DFID communicated its results / lessons/ good practice? 38. What methods has DFID used to effectively communicate its programme in the media to an Afghan audience? actually made. DFID's delivery on crosscutting themes 39. How well were issues of conflict, gender, social exclusion, human rights, HIV/AIDS and environmental protection actually integrated across the programme? And the counter-narcotics agenda? 40. Were results disaggregated by gender, social group etc. and what does the data show? 41. To what extent was DFID's peace-building and state-building work undertaken discretely and to what extent through other aspects of the programme? Impact and Sustainability Chapter 5: What impacts has DFID Afghanistan helped to achieve? Outcomes and sustainability 42. What is the evidence to support the view that DFID helped contribute to the peace building process and improve the security situation in the country? 43. To what extent has the policy and governance environment (eg accountability, action on corruption) been strengthened? Is there evidence to show that TA support is sustainable and renders results? 44. What is the evidence to show that DFID has helped contribute to specific development outcomes and PRS achievements? (PSA/ DDP/ direct project/ programme impacts and 'indirect' benefits around policy dialogue) 45. Are the development changes or reforms supported by DFID's country programme likely to be sustained / difficult to reverse? Have parallel systems been set up to deliver projects, and if so is there a plan to integrate them into government systems? To what extent has local capacity been built? 46. Has DFID added value through gains in aid effectiveness? For example, contributing analysis/ tools/ support on harmonisation? What lessons can DFID draw from the evaluation for informing future country, regional or corporate planning and operations? ## Chapter 6: Lessons And Recommendations Strengths and weaknesses of DFID 47. What are the key strengths demonstrated by the DFID office? 48. What are the key weaknesses demonstrated by DFID? Lessons 49. What lessons (from positive and negative findings) can be drawn for DFID's future work in the country? 50. What lessons can be drawn more widely for DFID and its work in other post-conflict and fragile situations? ## Annex 5.Timeline Of Key Events | Year | Political event | |-----------------------------------------------------|---------------------------| | British Embassy opens 22 Dec 2001. | | | Emergency phase still dominant. | | | 2002 | April 2002 | | Publication of National Development | | | Framework. | | | January 2002 | | | Tokyo conference DFID pledges | | | £200m over 5 years (02/03 - | | | 07/08). | | | January 2002 | | | International donors convene International | | | Conference on Reconstruction Assistance to | | | Afghanistan in Tokyo. | | | June 2002 | | | The Emergency Loya Jirga-Hamid Karzai was | | | elected as the President of the ATA. | | | October 2002 | | | A Constitutional Commission of 35 members | | | appointed to draft a constitution. | | | December 2002 | | | First Provincial Reconstruction Team (PRT) | | | established. | | | Transitional CAP. | | | Funding of NSP. | | | 2003 | Spring 2003 | | Insurgents commence orchestrated campaign of | | | terrorist attacks on targets associated with state- | | | building and reconstruction processes. | | | June 2003 | | | First suicide attack in Kabul. | | | June 2003 | | | UK leads its first PRT in Mazar-e- | | | Sharif. | | | December 2003 | | | Constitutional Loya Jirga delegates -- 500 Afghan | | | civic leaders -- met in Kabul to debate draft | | | constitution. | | | December 2003 | | | Ring Road stage one, linking Kabul to Kandahar | | | completed, a major rebuilding project sponsored | | | by the U.S., U.K. and Saudi Arabia. | | | 2004 | March 31 -- April 1, 2004 | | International Conference on Afghan | | | Reconstruction in Berlin. | | | Berlin Conference, DFID increased its | | | (Tokyo) pledge to at least £500m in | | | the same 5 year period (02/03 - | | | 07/08). | | | DFID programme management | | | devolved to Kabul. | | | October 2004 | | | Afghan Presidential election. More than 8.1 | | | million Afghans participated. | | | Alternative livelihoods strategy | | | (Badakshan - including cash-for-work, | | | Hezarejat). | | | 3-December 2004 | | | Inauguration of Hamid Karzai as democratically- | | | elected President of Afghanistan. | | | Funding of MISFA. | | | Evaluation of GCPP. | | | "Securing Afghanistan's Future" launched | | | Prime Minister Afghanistan Drug Action Plan | | | 2004-06. | | DFID Interim Strategy - 3 pillars (state building/ livelihoods/ economic management). 2005 May 2005 U.S. and Afghanistan formalized Strategic Partnership, reaffirming U.S. long-term commitment to Afghanistan's reconstruction and stabilization. September 2005 National Assembly and Provincial Council elections. More than 6.2 million Afghans vote. December 2005 National Assembly inaugurated in Kabul. Shift of emphasis towards central government budget support UK opens/leads Helmand PRT. 2006 January 2006 International Conference on Afghanistan in London. Donors commit themselves to support the reconstruction of Afghanistan for a further five years on the basis of the Afghanistan Compact. Publication of Interim Afghanistan National Development Strategy. Summer 2006 ISAF scheduled to expand mission in southern Afghanistan, and increase troop presence. 2007 August 2007 Opium production soared to a record high. 2008 March 2008 Launch of ANDS. June 2008 Donors Conference 2009 March 2009 HIPC deadline ## Annex 6.Table Showing Net Disbursements Table showing the net disbursements for ODA from the top 20 donors to Afghanistan 2002–2006 (USD, millions) Year 2002 2003 2004 2005 2006 2007 Total 2002–2007 % of % of % of % of % of % of % of Country Amount total Amount total Amount total Amount total Amount total Amount total Amount total United 367.61 485.79 778.29 1318.3 1403.71 1514.28 1 States 28% 31% 36% 48% 47% 38% 5,868 40% 2 EC 11% 13% 212 10% 9% 220.9 8% 1,349 9% 143.72 208.03 256.62 7% 307.46 United Kingdom 224.01 219.92 246.49 268.71 3 130.8 10% 98.61 6% 10% 8% 8% 7% 1,189 8% 4 31.7 2% 8% 8% 71.05 3% 4% 3% 618 4% Japan 134.42 172.52 107.42 101.01 5 92.57 7% 82.1 75.13 3% 99.23 4% 4% 5% 684 5% Germany 5% 117.99 217.15 Netherlan 6 ds 88.28 7% 77.37 5% 90.31 4% 79.09 3% 87.34 3% 88.82 2% 511 3% 7 35.81 3% 73.13 5% 56.24 3% 89.47 3% 5% 9% 740 5% Canada 140.27 345.39 8 60.86 5% 68.78 4% 67.73 3% 59.95 2% 69.68 2% 94.42 2% 421 3% Norway 9 27.52 2% 41.88 3% 55.68 3% 44.22 2% 46.42 2% 56.15 1% 272 2% Sweden 10 28.34 2% 38.16 2% 37.31 2% 27.39 1% 32.5 62.04 2% 226 2% Italy 1% Other Donors * 8% 8% 12% 172.6 13% 188.3 14% 9% 1,077 7% 106.26 109.76 149.66 350.32 All Donors, Total 1300.49 100% 1590.7 100% 2171.13 100% 2752.09 100% 2999.76 100% 3951.08 14,765 100% 86% Source: Data extracted on 30/05/2008 from OECD Stat. * Includes the next top ten donors: Turkey, Denmark, Switzerland, Australia, Spain, Finland, France, Korea, Greece & Austria. ## Annex 7. On The State Building Portfolio Dfid Afghanistan State Building Portfolio - Major Projects, 2002-2008 Within the state-building portfolio, early projects included support for the constitutional process, followed by support to the presidential, parliamentary and provincial elections in 2004-5. The elections projects supported planning and implementation, voter registration, civic education and election monitoring activities122. DFID contributed £5m to the UK Provincial Reconstruction Teams (PRT) from August 2003, under the Provincial Stabilisation Programme. Its aim was to support the military stabilisation effort, and DFID's contribution was to deploy several Development Advisers (DAs) in a number of PRTs123. The focus of the programme changed significantly in 2006 following the shift in UK priorities to Helmand. DFID's support for Public Administration Reform (PAR) was initiated in October 2003 through the Second Emergency Public Administration Programme (SEPAP), to which DFID committed £1.67m. SEPAP aims to "support the design and implementation of priority reforms and restructuring (PRR) of the Afghan civil service". Its goal is to achieve a more effective and efficient Government that can perform basic functions (budgeting, policy formulation and basic service delivery). DFID's support for SEPAP has continued throughout the evaluation period, and the programme has evolved as the PAR agenda has become more holistic to include pay and grade reform, capacity-building and sub-national governance. DFID provided a further £5 million of support to PRR with a specific focus on the Centre of Government institutions from December 2005, including the Office of Administrative Affairs and the Chief of Staff to the President. The project (SCoG) aims to "strengthen institutions at the CoG so they are more agile, transparent and effective in their support to the Office of the President as it strives to achieve its policy objectives". It includes support for rehabilitation of office facilities, provision of equipment including IT, and reform of administrative, policy and decision-making processes124. The National Solidarity Programme (NSP) with its focus on community empowerment has important relevance to the demand side of local governance. DFID gave early, substantial support to the programme, initially committing £13m, but ultimately totalling £56 million by early 2008. Alongside its primary focus on rural reconstruction, NSP had an important local governance dimension from the outset. Its primary benefit was to be "the empowerment of local communities through the establishment of village level consultative decision making and representative local leadership." NSP aimed to channel resources through block grants to rural communities for investments in reconstruction or development activities planned and managed by the communities themselves. Decisions were to be made through Community Development Councils (CDCs) elected through secret ballot, forming the basis of interaction between communities and local government125. Another national priority program, the Afghanistan Stabilisation Programme, was supported by DFID from 2004. Its purpose was to "establish basic security and good governance in the district and provinces of Afghanistan, through well-sequenced and co-ordinated development interventions focusing on security, governance and reconstruction". The Governance and Reconstruction component included training, establishment of a Provincial Stabilisation Fund, administrative reform, district infrastructure, and establishment of a programme management unit. DFID made a single payment of £20m directly to the Government in support of this component of the programme in March 2004. The Strengthening Counter Narcotics in Afghanistan Project (SCNIAP) started in August 2005, and aims to strengthen the government institutions responsible for counter narcotics at central and provincial levels. DFID committed £12.7m, and the programme was delivered as part of the UK's broader effort on counter-narcotics. Oversight was transferred to the Embassy in Kabul in 2007. The next phase of DFIDA's state-building programme aims to support the ANDS in governance, with a focus on capability, accountability and responsiveness, reducing conflict, and supporting justice sector reform126. Recent programme commitments that have been made include: (i) £4.5m to the Management Capacity Programme, to help recruit additional qualified Afghan staff to line management positions in ministries considered of priority to service delivery and improved budget execution; (ii) £3m to the National Justice Programme to help achieve progress in reform of the justice sector, in order to consolidate public trust in the Government, by promoting the rule of law, and safety and personal security for all Afghans127. (iii) £2.4m for work on Strengthening Municipal and Community Development in Helmand, supporting UN Habitat to achieve infrastructure improvements in up to four districts underpinned by community participation (urban CDCs) and municipality-led planning128. (iv) £1.7m to improve the communication capability of the Office of the Presidential Spokesperson (OPS), on the basis that better use of communications and media is an essential aspect of the Government of Afghanistan's strategy for countering the Taliban insurgency129. (v) £1.3m to support the Independent Directorate of Local Governance (IDLG). The project's purpose is that the "Government of Afghanistan is able to bring stability to key provinces and reach consensus on sub-national policy". It includes setting up an IDLG provincial advisory team in Helmand to contribute to provincial stabilisation. A new conflict transformation programme to "ensure that district level political settlements to violent insurgency are negotiated and sustained between the Government of Afghanistan and tribal society in southern Afghanistan" is currently under design. ## Dfid Statement Of Purpose DFID, the Department for International Development: leading the British Government's fight against world poverty. One in six people in the world today, around 1 billion people, live in poverty on less than one dollar a day. In an increasingly interdependent world, many problems - like conflict, crime, pollution and diseases such as HIV and AIDS - are caused or made worse by poverty. DFID supports long­term programmes to help tackle the underlying causes of poverty. DFID also responds to emergencies, both natural and man­made. DFID's work forms part of a global promise to: - halve the number of people living in extreme poverty and hunger - ensure that all children receive primary education - promote sexual equality and give women a stronger voice - reduce child death rates - improve the health of mothers - combat HIV and AIDS, malaria and other diseases - make sure the environment is protected - build a global partnership for those working in development. T ogether, these form the United Nations' eight 'Millennium Development Goals', with a 2015 deadline. Each of these Goals has its own, measurable, targets. DFID works in partnership with governments, civil society, the private sector and others. It also works with multilateral institutions, including the World Bank, United Nations agencies and the European Commission. DFID works directly in over 150 countries worldwide, with a budget of some £5.3 billion in 2006/07. Its headquarters are in London and East Kilbride, near Glasgow. LONDON GLASGOW 1 Palace Street Abercrombie House London Eaglesham Road SW1E 5HE East Kilbride UK Glasgow G75 8EA UK E­mail: enquiry@dfid.gov.uk Public Enquiry Point: 0845 300 4100 If calling from abroad: +44 1355 84 3132 ISBN: 1 86192 995 1
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## ## Neighbourhood Planning & Local Planning Service Redesign & Capacity Building - Dclg Pilot Programme For Local Authorities Redesigning Data Management Summary Paper Introduction The Local Authorities in the Exeter Housing Market Area (the HMA) have a strong record of working together and with other partners across administrative boundaries to plan for, promote, and deliver growth in an innovative way. The Local Authorities in what is termed the 'Greater Exeter area' are: - East Devon District Council; - Exeter City Council; - Mid Devon District Council; - Teignbridge District Council; and - Devon County Council. Alongside the involvement of the Exeter and East Devon Growth Point, the joint working of the Local Authorities has resulted in the development of the Cranbrook New Community to the east of Exeter, as well as large scale employment sites, all supported by significant transport, education and energy infrastructure. This collaborative approach is set to develop further in the context of the devolution agenda which is emerging in the Devon area1. This will seek to establish a new, more formal joinedup approach to setting long term visions and development strategy across the HMA and travel to work area coupled with innovative mechanisms for development and infrastructure delivery. The Authorities recognise that redefining and redesigning the way in which the Local Authorities work together on local plan making will be a vital part of ensuring that collaborative work continues and evolves. As such, the Local Authorities are coming together to work on a joint strategic plan for the area - the Greater Exeter Strategic Plan - a project to which the Partner Authorities have recently committed. The plan will provide a strategic planning framework following appropriate functional geographies, allowing the Authorities to operate more efficiently. It will also be important in ensuring that the Partners comply with the 'duty to cooperate' placed on the local authorities through the Localism Act 2011. The Partner Authorities' bid to DCLG included a request for funding to help redesign data management - to analyse, consolidate and achieve consistency across data sets. This work is helping to facilitate the preparation of the Greater Exeter Strategic Plan. The Partner Authorities are continuing to work on data management to support the Strategic Plan. Work package A joint bid to the Neighbourhood Planning & Local Planning Service Redesign & Capacity Building fund was submitted by the Partner Authorities. Total funding of £60,000 was awarded in February 2016 covering three elements to support accelerated strategic planning. The elements were: - Transportation study work: £25,000 To develop the transportation evidence base to support joined-up plan-making and help develop a long term transportation strategy to support future growth. - Environmental study work: £15,000 To develop the environmental evidence base to support strategic plan-making and ensure the development of an appropriate strategy for accommodating future growth and environmental aspirations. - Redesigning data management: £20,000. To analyse, consolidate and achieve consistency across existing data sets. This paper summarises the data management element of the work. The outputs of the environmental and transport studies are considered separately. Current data management Data for the Partners is currently held separately on independent systems at physically separate campuses. The data is currently managed by three separate IT providers - in two cases these are discreet organisations: - 'Strata Solutions' supporting Exeter City Council and Teignbridge and East Devon District Councils; - 'Scomis' supporting Devon County Council; and - Mid Devon District Council's own 'in-house' IT service. The way that data is currently managed across the five Local Authorities has therefore posed significant challenges to joint planning activities that have needed to be reconciled and overcome. Approach to managing data differently The Partners have reviewed their current data management where this relates to planning policy development. This has included: - Data storage and file sharing; - Geographic Information Systems (GIS mapping); and - Website and public facing data. Data storage and file sharing The Partner Authorities have identified potential approaches to how documents can be stored most efficiently to allow shared access and appropriate document version control. Alternative options considered have included: - A single lead authority to hold and disseminate files. This places an additional administrative burden on that authority. Data sharing is predominantly by email, which is cumbersome; and - Each Local Authority being responsible for holding its own data. This risks inconsistencies in data sets and challenges of version control. Given the limitations of the options above, officers are now pursuing the use of the cloudbased Microsoft product 'Sharepoint' for the storing and exchange of data by the Partner Authorities. The system is currently being established and it is expected this will be rolled out to officers in the autumn 2016. GIS mapping Thematic workstreams for the Greater Exeter Strategic Plan have identified an early need for GIS support for the capture, storage and sharing of spatial data. This has culminated in an audit of spatial data needed (for example, designated heritage assets, landscape character areas) and the nomination of lead officers across the five councils for each of the identified data sets. A series of potential approaches have been considered through discussions with planning officers and IT representatives from the Partners: - Each Partner Authority to hold spatial data for its administrative area. This risks inconsistencies in data sets and a lack of complete plan area coverage on a single GIS; - A single lead Authority to hold GIS data with access provided through a web browser; and - A cloud-based based GIS . Each Partner Authority would be able to access and share information. This could prove cost prohibitive to purchase and would incur ongoing service charges. The most practicable way forward will be for a single lead authority to provide complete plan area coverage for a GIS. Devon County Council is able to take this role because it can build on existing GIS covering the whole of the plan area through an online system. This approach will involve significant frontloading of data management to bring different datasets together, make them consistent in their format, symbology and meta data and transfer the data to a single system. The capture of new data will need to be co-ordinated and have quality controls. Significant resource will be required to undertake the frontloading of the GIS data management. Existing IT support across the Partner Authorities is likely to be able to support some of this work, however additional short term capacity improvements will be required to expedite this work. There will be a cost implication for the Partner Authorities in the autumn 2016, and this is being met by the DCLG funding. Website and public-facing data The Partner Authorities have identified the need for a specific website to provide for public facing work, including providing information about the Strategic Plan and facilitating future public engagement involving consultation exercises with web response forms. Alternative options considered have included: - Each Partner Authority having its own dedicated webpage for the Strategic Plan. This has a potential risk of inconsistent information being provided and would be an inefficient approach as it would require the maintenance of numerous webpages; - A single lead authority hosting the website. This places an additional administrative burden on that authority and risks politicising the preparation of the Strategic Plan where its content may impact on adjoining authority areas; and - A free-standing independent website. This would be neutral and can include independent branding that is bespoke and specific to the preparation of the Strategic Plan. It would provide a single public facing place on the internet thereby avoiding duplicating webpages on Partner Authority's websites and risk of multiple and potentially inconsistent information being provided. The Partner Authorities consider the free-standing independent website to be the most practicable and advantageous way forward. Devon County Council will develop the website working with media / communications teams from the other Partner Authorities. The cost incurred will be met from DCLG's grant award. Lessons learnt Work for the redesign of data management is currently ongoing. However, the Partner Authorities have learnt a number of lessons from the progress made. Project management Several planning officers, with support, have worked together to move the project forward. However, limited capacity to do so in light of other work commitments and the practicalities of bringing together IT specialists from across the Partner Authorities has meant this work has taken some time. Project management from a dedicated 'lead officer' is important to take responsibility for, and co-ordinate, the data management work across the area. Business justification There is a need to identify a clearly defined business justification for the redesign of data management to help align the work priorities of each Partner Authority's IT service provider and to confirm the timely delivery of the project. Given the size of the Partner organisations and the competing needs, the length of time required to execute such a project should not be underestimated. Communication There is a need to communicate the aim of redesigning data management effectively to each IT service provider from each Local Authority. Key to this is identifying the appropriate contact officers and ensuring regular communication. IT officers are not 'planners' and therefore a need exists to communicate the relevance of the plan work to them so that they can understand how they can contribute towards this. Planners also need to better understand IT capabilities and limitations and what can feasibly be achieved. Timeframe The review of data management has so far taken a number of months, with good progress, however the time required to secure agreement from each Local Authority is significant. The length of time that such a project takes to deliver should not, therefore, be underestimated. Innovative thinking The project has three main components. Bringing these together in a timely manner to meet the IT needs of the Partner Authorities poses significant challenges which have required careful timetabling and planning. Limited available budget and resources have helped to focus attention on finding practical and achievable solutions. Procuring a new external IT service provider specifically for the purpose of the Strategic Plan is not an option and therefore the Partner Authorities have brought together specialists from each of their IT providers to think and work collaboratively on the project. The lead responsibility for each of the three IT components has effectively been passed to the IT provider associated with the Authority that is best placed to deliver. Identifying 'quick wins' has helped to build and maintain momentum in the project - the use of existing available and affordable commercial products such as 'Sharepoint' to provide a cloud-based data storage / sharing have put in place early IT capabilities to help the Partner Authorities prepare the Strategic Plan. Sharing of learning Officers from the Local Authorities will share the learning which has resulted from this work through relevant networks via the Department for Communities and Local Government, to Planning Advisory Service, Royal Town Planning Institute and the Town and Country Planning Association. At a more local level, there are specific examples of emerging cross-boundary plan-making taking place in the Plymouth and northern Devon areas where lessons here could be applied. Discussions could be initiated in the context of the existing Devon Duty to Cooperate Protocol2 and through the Devon Planning Officers Group which meets quarterly. ## Further Information . Contact Information Lead officer: George Marshall, Devon County Council Principal Planning Officer: Policy and Infrastructure Development George.marshall@devon.gov.uk 01392 383000 Further contact: Tristan Peat, Teignbridge District Council Principal Planning Officer: Spatial Planning and Delivery Tristan.peat@teignbridge.gov.uk 01626 215710
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## # Operational Selection Policy Osp45 English Partnerships 1999 - 2006 ## Contents Authority Scope Executive summary Background information Appraisal suggestions of record types Key committees Policy work Operational work Electronic formats Publications Implementation of the policy 1 Authority 1.1 The National Archives' Acquisition Policy statement announced the Archives' intention of developing, in consultation with departments, Operational Selection Policies across government. These Policies would apply the collection themes described in the policy to the records of individual departments and agencies. 1.2 Operational Selection Policies are intended to be working tools for those involved in the selection of public records. This policy may, therefore, be reviewed and revised in the light of comments received from the users of the records or from archive professionals, the department's experience of using the policy, or as a result of newly discovered information. There is no formal cycle of review and revision exercise will be determined according to the nature of the comments received. 1.3 This policy is a presentation version of an appraisal report. Appraisal reports have been developed to implement The National Archives' Appraisal Policy, published in August 2004. They are designed to provide structured information about the responsibilities, work and records of an organisation so that appraisers can identify records of potential historical value. They provide a transparent record of decisions on the selection of records in whatever format for permanent preservation. Selection decisions are based on the requirement both to document the work of the organization and to provide information about specific topics of potential long-term research interest. 1.4 If you have any comments upon this policy, please e-mail recordsmanagement@nationalarchives.gov.uk or write to: Acquisition and Disposition Policy Manager Records Management Department The National Archives Kew Richmond Surrey TW9 4DU ## 2 Scope 2.1 This report constitutes an agreement reached between The National Archives and English Partnerships on the future selection of their records. 2.2 This policy relates to the records produced by English Partnerships from its establishment in 1999 to the present day. It covers both paper and electronic records created during this period and will continue to be valid until summer 2008, when English Partnerships is due to be incorporated into a new agency, Communities England (see 2.4). 2.3 This policy does not cover the records of English Partnerships' constituent bodies, The Commission for the New Towns (CNT) and the Urban Regeneration Agency (URA), prior to 1999; these are currently being reviewed. The records of the CNT are public records; the records of the URA are not public records, but under a memorandum of understanding between the URA and The National Archives (TNA) are treated as such for the purpose of review and selection for permanent preservation at The National Archives and places of deposit. 2.4 In April 2006, English Partnerships' parent body, Communities and Local Government (CLG), announced a review of government housing and regeneration initiatives. On 17 January 2007, the review team announced that English Partnerships would be wound up and a new agency, Communities England, would be formed by bringing together English Partnerships, The Housing Corporation, and the Communities functions of Communities and Local Government. Executive Summary English Partnerships' records have historical value for two main reasons. Firstly, English Partnerships handles significant sums of public funds. During the period covered by this report, English Partnerships' annual income varied between 2 and 6 hundred million pounds. It is therefore important that The National Archives captures documentation on how these resources are disbursed. Secondly, English Partnerships has a national impact on urban planning and housing delivery, with responsibility for regenerating decaying urban areas and provision of keyworker housing. It also has a directing role in the planning and development of large new residential communities such as Thames Gateway. The National Archives will therefore seek to record these significant changes to Britain's cities and towns. These records will be of interest to social and economic historians, those interested in Britain's architectural heritage, and local historians. They comply with The National Archives' Acquisition Policy under the following criteria: 2.1.5 Formulation and delivery of social policies 2.2.2 Impact of the state on the physical environment Records for this period will be selected to reflect English Partnerships' main functions of identification and delivery of land for residential use, provision of keyworker and affordable housing, regeneration of urban areas and brownfield sites. Policy decisions are recorded across English Partnerships' files and electronic systems. At the highest level they will be contained in the papers of the Non- Executive Board and the Executive Management Board. The Decisions Database (which holds all agenda, papers, minutes and action points from English Partnerships committees) will provide a record of actions decided in the committee structure. At an operational level, English Partnerships functions through a series of national programmes across five geographical regions, which are split into 15 areas. Each national programme has its own file series. These, in conjunction with records of key committees and high-level policy files (and case files contained within them) will ensure that policy decisions, particularly relating to disbursement of funds, are captured. National strategies are driven by Communities and Local Government, but are formulated and implemented by English Partnerships. High-level records will be selected from the parent department, but formulation of the strategies will be recorded in the English Partnerships programme files. English Partnerships publications are published both in hard copy and on its website, with annual reports and accounts being published since 1999. The National Archives took an initial snapshot of the English Partnerships website in July 2004 and there have been 4 irregular gathers since. A number of publications from this period have been appraised and a selection has been made. From March 2006, selection decisions will be in line with OSP36 on Publications. The majority of CNT records prior to the merger with the URA had a local focus and therefore those not of a nationwide corporate value have been deposited with local record offices and specialist archives. English Partnerships work is conducted on wider regional areas making local deposits impractical. Therefore, The National Archives will be selecting a larger proportion of English Partnerships records than has been usual in the past. ## 1 Background Information 1.1 Name Of Agency / Ndpb - English Partnerships 1.2 What Type Of Agency Is The Organisation? Executive Agency Non-Departmental Public Body Trading Fund Research Councils Next Steps Agency Non- Ministerial bodies Libraries, Museums, Galleries Executive NDPB. Consists of two - Commission for the New Towns (CNT) and the Urban Regeneration Agency (URA) 1.3 What is the annual budget of the organisation? English Partnerships is treated as a business as well as a public body, but it is not a trading fund, and profit making is not a primary objective. The expectation is that money raised from property sales be utilised in achieving English Partnerships' aims. The accounts for CNT and the URA do not show budgets, only incomes, which are as follows: CNT 249,628,000 (disposal of property assets, rents, other operating income), URA 358,121,000 (release of grant in aid, clawback of grants and contributions, rents/maintenance charges, contributions from partners, disposal of development assets, other operating income). [Incomes are taken from annual report for 2006]. 1.4 What is the total number of employees? CNT 185, URA 352 [figures taken from 2006 annual report - all new employees are appointed to URA contracts] 1.5 Hybrid Records - records are created electronically, but until an official electronic records policy is finalised, corporate policy remains print to paper. Whilst officially this creates paper records, it effectively creates only hybrid records. Although documents are created and stored on shared drives, those considered to have corporate value are filed on paper files, whilst related documents may remain on electronic systems only. There are no mechanisms in place to monitor whether records are being printed to paper or that related records are being maintained. English Partnerships has a Decisions Database that records all agenda, minutes, papers and decisions of committees. Executive Management Board papers are already included in the Decisions Database; it is hoped that a solution can be found for Board papers to be entered as well, but this is subject to issues of allowing non- English Partnerships staff (see 1.8 for Board constitution) to access the database. Once a committee starts inputting to the database, the paper set of records are discontinued and the electronic record becomes the master, but this is being rolled out gradually across all the organisation's committees. A survey of committees has been undertaken to ascertain when each secretariat began using the database, and the results are noted in Section 4.1, Table 1 below. For some committees, plans are not scanned into the database and continue to be held in hard copy. 1.6 Background, functions and activities - English Partnerships is the trading name of the organisation created in May 1999 by the merger of The Commission for the New Towns and the Urban Regeneration Agency. It is a single operational entity but the two constituent organisations exist as separate legal bodies. Statutory background The Commission for the New Towns was set up under Part II of the New Towns Act 1959 and was launched in October 1961. It operates under the provisions of Part II of the New Towns Act 1981 as amended by the New Towns and Urban Development Corporations Act 1985, the Urban Development Corporations in England (Transfer of Property, Rights and Liabilities) (Commission for the New Towns) Order 1998, and the orders dissolving the Housing Action Trusts for North Hull, Waltham Forest, Castle Vale, Tower Hamlets and Liverpool, for which CNT is the residual body for records. The Urban Regeneration Agency was established under Part III of the Leasehold Reform, Housing and Urban Development Act 1993. It came into existence following Parliamentary approval of the Leasehold Reform, Housing and Urban Development Act 1993. The agency became fully operational on 1 April 1994 when it took over Derelict Land Grant and City Grant and English Estates under the provisions of the Leasehold Reform, Housing and Urban Development Act 1993 (Commencement No 4) Order 1994 Statutory remit The Commission's statutory purpose is: - To take over, and, with a view to its eventual disposal, manage and turn to account the property of the New Towns and Urban Development Corporations and Housing Action Trusts transferred to it - To dispose of the property when it is most expedient to do so The aim of the URA is to regenerate land in England that is: - Vacant or unused - In an urban area and is under-used - Contaminated, derelict, neglected or unsightly It also has a role in ensuring the stabilisation and development of land that has collapsed or is likely to collapse as the result of mining that is no longer operational (other than coal mining, which is a separate English Partnerships programme). The two agencies were merged on 10th May 1999 to form English Partnerships, with Board members appointed to the boards of CNT and URA at the same time. English Partnerships' original role was to focus on national and cross-regional co-ordination within the Government's overall regeneration agenda. There were four main areas of business: developing assets, creating partnerships, improving the environment and finding new sources of funding. The regular 5-year review of the agency by ODPM was brought forward to 2003, resulting in a shift in focus towards the following: - Identify and deliver land for housing and sustainable urban development - Regenerate areas badly affected by abandonment and decay - Help co-ordinate delivery of key worker and affordable housing - Develop its role as an agency for best practice regeneration and development of brownfield land through its National Brownfield Strategy and National Coalfields Programme - To ensure that surplus public sector land is used to support wider government initiatives (English Partnerships administers the Register of Surplus Public Sector Land, available to 180 government bodies) - In 2006 English Partnerships was also given responsibility for housing expansion in the South East by the Deputy Prime Minister. Thames Gateway has been designated one of English Partnerships' regional areas, and in conjunction with Regional Development Agencies, the Greater London Authority, and the Housing Corporation, the agency will identify sites and contribute to their redevelopment ## 1.7 Name Of The Parent Or Sponsoring Department - Communities And Local Government (Clg) 1.8 Relationship with parent department - Agency status: the Minister for CLG answers to Parliament for English Partnerships. The framework agreement between department and agency is known as the Management Statement, which sets out the framework within which English Partnerships operates, including rules and guidelines relevant to the exercise of English Partnerships' functions, duties and powers, the conditions under which any public funds are paid to English Partnerships and how EP is held to account for its performance. The Minister for CLG appoints a Management Board, which has full control over internal affairs. Membership of the Board consists of local authority, Regional Development Agency, Housing Corporation and private sector representatives. 1.9 Relationship with other agencies / NDPBs The Housing Corporation, a government agency with a remit to fund affordable housing and to regulate housing associations in Britain. - English Partnerships has formed a joint initiative with the corporation, The Housing Partnership, to supply affordable homes in London and South-East England (this latter project currently extends only to expansion of Milton Keynes). The Chief Executives of English Partnerships and the Housing Corporation are members of each other's Boards. - Housing Action Trusts (HATs) were six projects nationwide that aimed to regenerate urban housing estates. These were short-term projects, five of which have now been wound up, with the last, Stonebridge in North West London, due to close in July 2007. The Housing Corporation has responsibility for Community Based Housing Associations (CBHA). HAT tenants have the option to transfer to the CBHA when the HAT closes, as an alternative to the local authority. English Partnerships is the residuary body for the records of the Housing Action Trusts. - The Housing Corporation is not a Public Record body and has responsibility for its own records, but in 2008 it will become part of the new regeneration and housing agency, Communities England, and its records will become public records from that time. Defence Estates has a formalised relationship with English Partnerships through a joint working agreement that sets out the operational mechanisms for how the agencies will work together to dispose of surplus MoD property to maximum commercial benefit. English Partnerships' input can range from site purchase through to collaborating on design and masterplanning in advance of the sites being put on the open market for sale. CABE (Commission for Architecture and the Built Environment) is the government's advisor on architecture, urban design and public space. This impacts on English Partnerships' remit and CABE is listed on the English Partnerships website as an external partner. Regional Development Agencies are responsible for overall economic development and regeneration. They are regional partners in the national English Partnerships framework, working to ensure that industry and business opportunities are made available to support new communities. The Forestry Commission have a memorandum of understanding, setting out how they will deliver shared regeneration objectives in support of RDA strategies and the England Forestry Strategy 2 Material transferred to The National Archives in the past As English Partnerships was not formed until 1999 and the URA is not a public records body, records selected and transferred so far are almost entirely those of the Commission for the New Towns. FJ 1 - Minutes and papers of the Board FJ 2 - New Towns Association registered files. The New Towns Association was set up in the late 1960's in response to suggestions from the Ministry of Housing and Local Government. It was set up as a permanent organisation to collect, evaluate, identify and appraise emerging problems, to provide secretariat services for the various committees (of chairmen, general managers, financial officers etc). Its key role was to facilitate consultation and provide a "clearing house" for central responses to government and others. The New Towns Association was wound up in 1992. FJ 3 - Commission for the New Towns and Urban Regeneration Agency annual reports FJ 4 - Commission for the New Towns and English Partnerships files (registered and unregistered - no English Partnerships files have yet been appraised) FJ 5 - Commission for the New Towns seals registers (all selected - no longer accruing) FJ 6 - Commission for the New Towns and English Partnerships library material (some selected from both organisations) FJ 7 - English Sites database - English Partnerships website 'advertising' government land available for sale for development (NDAD) ## 3 Does The Agency Have A Statutory Duty To Preserve Permanently Some Of Its Records? If So Give Details No. 4 Appraisal suggestions of record types 4.1 Committee structure within the agency or parent department, relevant committees directing the work of the organisation but independent of the agency and its parent department. Committee papers within English Partnerships are gradually being created in electronic form in a Decisions Database. English Partnerships has no EDRM and this Lotus Notes database is currently available on English Partnerships' intranet. It has been in operation (excluding pilot period) since December 2005 and an archive component has now been added. The current expectation is that a snapshot of the database will be selected for The National Digital Archive of Datasets (NDAD) when it has been in use for five years, with an annual review thereafter to ascertain the need for further updates. See Section 1.5 for more details There may be commercial in confidence sensitivities in committees of all levels. Many of these will only be sensitive for a relatively short time, but this will be examined more closely in the period prior to transfer. ## Table 1(A): Key Committees - Current At Date Of Publication Name of committee Terms of reference Appraisal hypothesis Non-Executive Board To consider strategic issues and approve projects: set strategic aims, objectives and policies, ensure sufficient financial and human resource, review management performance, set values and standards, ensure effective communication of English Partnerships' strategic objectives and obligations to stakeholder; for projects costing in excess of £10 million: to approve investment, to consider proposals for the acquisition of land and property, to approve the disposal of assets, to exercise CNT's planning powers in administration of the 1981 New Towns Act, to consider novel, contentious or repercussive issues which would other wise be within the delegations of the Chief Executive or Directors, prior to their recommendation to CLG where necessary; to review individual development and disposal strategies. Select (papers for CNT 1961- 1998 already transferred to The National Archives, 1999 onwards held by English Partnerships secretariat; URA papers 1994 to present: master set is held by Regional Director, Southern Region for operational purposes) Milton Keynes Partnership Committee A sub-committee of the main English Partnerships Board, Milton Keynes Partnership Committee (MKPC) has delegation from the Board to approve the strategy for, and expenditure on English Partnerships' current strategic projects in MK. The MKPC comprises an independent Chairman, representatives from English Partnerships, Milton Keynes Council and the Local Strategic Partnership together with an Independent Member. Minutes submitted to main English Partnerships Board and are in the public domain. Check of quality of information Date from which Decisions Database is considered the master record (if included) Highest level of strategic decision making for English Partnerships, meeting once every two months. Also incorporates Board Projects Committee, which meets bimonthly to discuss projects matters only. January 2006 (incomplete records held since December 2003). Board Projects was established in December 2005 - all its records are held on the Decisions Database. Executive Management Board (EMB) No up to date terms of reference. However, the first meeting states 'The underlying principle of the EMB required all members to assume collective responsibility for the business of the Agency. Each member would be responsible for a separate major part of the business reporting directly to the Chief Executive. The Chief Executive would be brought into all key discussions at the appropriate stage. All papers for consideration by the Board of English Partnerships must first be considered by the EMB. The format of the meetings should allow for a broad discussion on key policy issues affecting the Agency.' 1st joint I/URA meeting was held April 6 1999 in preparation for the merger on April 27 (English Partnerships was launched on May 10). Select High level decisions including delegation of responsibilities and some cases of allocation of funds/discussion of English Partnerships investment Jan 2006 | Audit Committee | To review the annual financial statements | |------------------------------------------------|----------------------------------------------| | and the reports of the external auditors, to | | | advise on account and disclosure | | | amendments and action in respect of the | | | annual management letter, and to make | | | recommendations to the Board; to review | | | the effectiveness of English Partnerships' | | | internal control arrangements established to | | | ensure that the aims, objectives and key | | | performance targets of the organisation are | | | achieved in the most economic and | | | effective manner; to review the annual | | | statement on internal control prior to | | | endorsement by the Board and in particular | | | to review (a) the procedures for identifying | | | business risks and controlling their potential | | | impact, the policies for preventing and | | | detecting fraud, the policies for ensuring | | | compliance with relevant regulatory and | | | legal requirements, the operational | | | effectiveness of the policies and | | | procedures; to ensure that the internal audit | | | function is appropriately resourced and | | | meets, or exceeds, the standards specified | | | in Government Internal Audit Standards | | | Select | This is a Board committee | | (previously the Audit Sub- | | | Committee of the Board, URA | | | 25/11/2002 | | | and pre 1/7/99 I Finance and | | | Audit Committee), which have | | | traditionally been selected in | | | the past. Its primary function is | | | 'to assist the Board in | | | discharging its duty to ensure | | | that financial statements comply | | | with any statutory and | | | administrative requirements and | | | for ensuring the highest | | | standards of propriety and | | | accountability for the use of | | | public funds'. | | Remuneration Committee To approve the terms and conditions of employment of the Chief Executive (subject to CLG approval); to consider and approve objectives for the Chief Executive on an annual basis; to consider and approve the bonus arrangements for the Chief Executive on an annual basis; to consider and advise the Main Board upon broader staffing issues; to monitor the agency's manpower requirements against the organisational structure and revenue budget agreed by the Board; to review terms and conditions of service and to determine any issues in relation to terms and conditions, overall pay levels and performance awards that are referred to the Committee by the Executive; to ensure that there are clear legal and administrative arrangements covering the provision of the Agency's pensions schemes in respect of benefits and contributions, the administration of the schemes and the management of the pension funds Select The files reflect the committee decisions made. Not included Projects Executive Committee To consider investments in projects which exceed the delegated authority of individual directors and make recommendations to the Chief Executive for approval under his/her delegation or for submission to Project Planning and Property Committee/Board as appropriate; ensure a co-ordinated and consistent approach to English Partnerships investments; to review all requests to use the Agency's Compulsory Purchase Order powers and make recommendations to the Chief Executive prior to discussion with the Project Planning and Property Committee; to monitor the progress of major projects and investments to ensure that they are being delivered in accordance with the relevant approvals; to consider projects and investments which are not achieving the forecast timescale, cost programme or outputs with a view to recommending a remedial course of action; any other business referred to the Committee by the Chief Executive Select This committee covers similar business to the Commercial Committee, but is at a management board level. It considers wider planning and funding issues, such as impact of legislation, sustainability standards (i.e. renewable energy use in new developments), and environmental issues. The committee also approves funding applications that are above certain management delegation levels. July 2004 Operations Committee To balance resources against the needs of the programme and administration budget and to consider any issues under Resource Accounting; to determine and agree the administration budget; to monitor the overall expenditure and receipts against budgets and predetermined limits; to monitor competitive tendering arrangements; to monitor and approve manpower and training requirements; to determine and review terms and conditions of service; to agree the IT strategy and determine its resource requirements; to consider issues relating to premises and facilities; to consider health and safety matters; to monitor English Partnerships support to Regional Development Agencies and approve any arrangements under SLAs; to make necessary recommendations to EMB Select This committee is attended by senior operational management. Key findings and observations are reported to other higher-level committees, where the reports are noted and minuted. Senior Management Team/Regional Management Team Meetings Meets monthly or twice monthly (varies from region to region) to consider and approve projects within the Regional Directors financial delegations or to forward on to Projects Executive. Not included ## Table 1(B): Key Committees - Historic Acquisition and Disposal Committee To consider proposals for the acquisition of land, beyond the level of delegation to the Chief Executive and Directors as determined by the Board, and to approve or reject such proposals as appropriate; to consider proposals for the disposal of land, beyond the level of delegation to the Chief Executive and Director as determined by the Board, and to approve or reject such proposals as appropriate; to consider any strategic or policy issues arising from acquisition and disposal proposals and if appropriate to refer these to the main Board; to consider acquisition and disposal strategies as they may relate to compact geographical areas or nationwide related sites (e.g. portfolios) and to advise and make recommendations to the main Board as the Committee consider it appropriate to do so Select This is the committee within the structure of the new merged organisation that replaced CNT's Property Committee. Minutes from the Acquisition and Disposal Committee did not automatically go to the Board as Property Committee minutes had done in the past. Central Region Executive Committee (EMB) Principal terms of reference are 'consideration of items requiring Board or delegated approval and other items of regional concern, and the debrief of corporate and Board information.' Destroy There was an intention to review the terms of reference after three months of operation; however, the committee continued under the original reference terms. Files for this CNT committee run only from 1998, although the first paper reports on changes to the existing committee. The files reflect the committee decisions made at that time, which relate mainly to operational lowvalue transactions and procurements. Not included Commercial Committee and Partnership Investment Programme Sub- Committee Commercial Committee: to consider and approve/recommend projects forming part of the (a) RDA Partnership Investment Programme (b) the Coalfields Programme (c) the Unstable Land Programme and English Environment Fund, and to take reports on progress of the programmes; to consider and approve/recommend proposals for disengagement from CNT/UDC liabilities, and to take reports on progress of the disengagement programme; to receive full quarterly reports on progress of the RDA PIP, Coalfields, Unstable Land, Disengagement and Derelict Land Grants after value recovery programmes; to consider operational issues relevant to the Commercial Director; to consider all proposals for new initiatives within the Commercial Directorate Select The Unstable Land Programme was subsequently renamed the Land Stabilisation Programme. This committee decides where investment will be made. Its meetings are divided into: English Partnerships investment programme, land stabilisation programme, Coalfields, disengagement, progress against business/corporate plan, and items needing DETR/ODPM approval. It covers both policy direction and case papers on individual sites. Brief minutes go to the Executive Projects Committee. Please note that the subcommittee minutes consist of brief action points and are passed to the main committee. These minutes are filed with the Commercial Committee papers. Not included RDA PIP Subcommittee: to consider and approve RDA Partnership Investment Projects of up to £3m. This will include taking note of reports from the Divisional Director (PIP) on delegated decisions and other matters; to consider and make recommendations to Property, Planning and Projects Committee (PPP) on RDA PIP projects of more than £3m; to consider and approve increases of up to £1m in RDA PIP projects and make recommendations to the Commercial Committee; to consider all novel and contentious RDA PIP projects and make recommendations to the Commercial Committee; to receive reports from the Divisional Director (PIP) on projects approved and increases approved under his delegations; to receive reports on the progress of RDA PIP projects and to make reports to the Commercial Committee and PPP; to keep under review the working arrangements between English Partnerships and the RDA's and to monitor evolving State Aid issues; to consider and approve DLG after value settlements proposed by the Divisional Director PIP above his delegation Development Committee To approve competitive disposals above individual directors' delegations but below £3m; to recommend competitive disposals above £3m for approval; to approve negotiated disposals above individual directors' delegations but below £1m; to recommend negotiated disposals above £1m for approval; to recommend non-ring-fenced PIP and land reclamation projects above individual directors' delegations for approval; to approve land acquisitions and direct development projects up to £1m; to recommend land acquisitions and direct development projects above £1m for approval; to approve planning applications where there are no sustainable objections; to recommend for approval planning applications where sustainable objections have been made; to approve expenditure on site investigations and feasibility studies above individual directors' delegations but below £1m; to recommend expenditure on site investigation/feasibility studies above £1m; to consider all requests to increase investment above present approval levels; to consider all novel and contentious projects; to monitor the progress of sales, purchases, projects previously approved by the committee Select Delegated authorities allow this committee to approve a significant level of spending on individual projects. It creates a limited number of case papers showing the current and projected value of land/sites, with the estimated amount of spend by English Partnerships. Those papers that cannot be approved by the Development Committee are submitted to the Executive Projects Committee or the Property Planning and Projects Committee. Not included Finance and Administration Committee To balance the Agency's resources against the needs of the development programme and operations budget; to manage the Agency's single running cost control and administration budgets; to consider operational issues of the Agency and any specific issues raised by other EMB Members; to determine and agree the administration budget for the Agency; to monitor the overall expenditure and receipts of the Agency against budgets and predetermined limits; to monitor the Agency's Select This committee was short-lived and covered a major restructuring of the Finance and Administration Directorate in English Partnerships, bringing together the equivalent bodies in CNT and English Partnerships. Not included competitive tendering arrangements; to monitor and approve the Agency's manpower requirements; to determine and review terms and conditions of service including overall pay levels and performance awards; to agree the Agency's information technology strategy and determine its resource requirements; to consider issues relating to the Agency's facilities; health and safety matters; to report key issues to EMB Greenwich Peninsula Project Board To approve the development, procurement and disposal strategies for the regeneration of the Greenwich Peninsula; to approve the cash flow projections for the regeneration of the Greenwich Peninsula; to monitor performance against the agreed strategies and cash flow projections; to approve manpower plans and staff appointments for the Greenwich implementation team; to approve/recommend expenditure in excess of the Development and Technical Directors' delegations. Matters relating to the Greenwich Peninsula are currently considered by Projects Executive and Board Projects when required. Select The files reflect the committee decisions made. Planning and Risk Management Group To identify the key opportunities for continuous improvements to English Partnerships' core management processes and capabilities requiring cross-cutting, multifunctional solutions; to identify further opportunities to extend the integration of risk assessment and management to all core business processes and activities; to develop proposals to implement the required changes to processes, practices and procedures, for consultation with the wider business and, where appropriate, approval by Executive Management Board or Projects Executive Select Committee supports business planning, performance management, risk management and project and programme management within English Partnerships and to examine risks in processes that are not the discrete responsibility of any specific function. Projects and Disposals Committee To accept projects for appraisal; to provide advice on the approach to be adopted on emerging property, projects and disposal issues; to consider and approve/recommend to Executive Management Board (EMB) implementation of projects, terms of acquisitions and terms of disposal; to consider and approve the letting of project investment contracts, including those relating to engineering/construction projects; to consider and approve/recommend to EMB increases in existing financial authorities; to monitor progress of approved Select Papers submitted to the committee include outline of project, background, recommendations, planning and appraisal details, exit strategies and value for money considerations. Not included July 2004 (disbanded Feb 2007) Not included disposals/acquisitions/projects against the agreed financial and output targets; to consider and approve/recommend to EMB development policy or planning policy papers; to consider policy and strategy issues regarding projects, disposals and property interests and report to EMB. This was superseded by Projects Executive in 2003. Property Planning and Projects Committee To consider proposals for the acquisition and disposal of non-operational properties and land; to consider acquisition and disposal strategies as they relate to defined geographical areas or nationwide related sites and make recommendations; to consider and advise on novel or contentious property management issues; to exercise CNT planning powers in the administration of the 1981 New Towns Act; to consider and advise on proposed planning strategies designed to enhance the value of marketablility of assets for disposal or to bring to fruition regeneration initiatives; to consider proposed regeneration projects, beyond the delegation level of the Chief Executive and Directors as determined by the Board, and to approve, reject or defer such proposed projects. This was superseded by the Projects Committee and subsequently by Board Projects in December 2005. Select Papers discuss acquisition and disposal of property, allocation of funds to specific projects and programmes. Relates mainly to CNT's remit to disengage from the New Towns by disposing of remaining assets. Urban Affairs Committee This is not an English Partnerships committee and is a sub-committee of the Transport, Local Government and the Regions Committee Parliamentary Select Committee Destroy Files consist of correspondence between the sub-committee and English Partnerships. This, along with the evidence submitted by English Partnerships should be held on Parliamentary files. Not included ## 4.2 Areas Of Policy Work Undertaken In The Agency Table 2: Policy Work In The Agency | Type of policy | Yes | |-----------------------------------------------------------------|----------------------------------------------------------------| | / No | | | Notes | | | All primary legislative policy is | | | made in parent department | | | Yes | CLG and its predecessors make all legislation relating to the | | functions of CNT and English Partnerships | | | | | | Agency plays major consultative | | | role in the development of | | | primary legislation directly | | | associated with its role. | | | Yes | English Partnerships has a consultative role in legislation on | | housing development in the South East and regeneration | | | issues, and gives feedback on any bills affecting its interests | | | and functions | | | | | | Agency represents the parent | | | department/ UK govt at | | | international conferences/ on | | | European or International bodies | | | No | Attend international bodies and meetings (usually marketing | | opportunities) but not as representative of CLG | | | | | | Agency develops secondary | | | legislation | | | No | Statutory orders come from CLG - English Partnerships input | | but do not drive | | | Agency issues advice and | | | guidance | | | Yes | Urban Regeneration Agency issues best practice guidance | | on construction. Variety of standards and best practice | | | guides issued by English Partnerships. There is a blurring | | | between best practice, research, monitoring, standards and | | | guidance, with all five being published on the English | | | Partnerships website under the heading 'Best Practice'. Also | | | included in this section are purely informative documents | | | such as the Housing Statistics Briefings. | | | Agency develops nation-wide | | | strategy documents (below | | | White Paper status but above | | | operational level) | | | No | English Partnerships has nationwide strategies although | | these are driven by CLG. There does not appear to be a | | | committee that looks specifically at nationwide issues, but the | | | Commercial Committee and Executive Projects Committee | | | looks at wider planning issues and investment in national | | | projects such as the Coalfields programme | | Papers relating to legislation to be selected from CLG Select departmental input into primary legislation and into secondary legislation according to importance Main international meetings are the International New Towns Association (INTA). These have not been selected Select input according to importance of the legislation Guidance is available on English Partnerships website which is already captured twice yearly by ZWEB. Most guidance has only been published since 2004/5 in line with English Partnerships' publication scheme; only CL:AIRE (Contaminated Land: Applications in Real Environments) predates this. Some library material for this project has already been selected for The National Archives but policy files may also need identifying. These two committees will be selected; along with Board papers and relevant CLG policy files, English Partnerships' national strategies will be sufficiently reflected in The National Archives holdings. ## 4.3 Operational Work Undertaken By The Agency Table 3: Operational Work Of The Agency And Records Created | Operational activity | Detail of activity | Type of | |-----------------------------------|-----------------------|-----------------| | record | | | | created | | | | Is the work | | | | captured | | | | through a | | | | database? | | | | Is the work | | | | captured | | | | through | | | | publications | | | | (see 4.5 below) | | | | Do appeals go | | | | elsewhere | | | | (Parent dept, | | | | independent | | | | panel? | | | | Are key results | | | | captured in the | | | | Annual Report? | | | | Appraisal | | | | hypothesi | | | | s | | | | Monitoring | | | | | | | | English | | | | Partnerships | | | | monitors best | | | | practice in utility | | | | procurement in | | | | the construction | | | | industry following | | | | critical report in | | | | 2004 | | | | | | | | Web pages | No | Yes - all | | available on Best | | | | Practice section | | | | of English | | | | Partnerships | | | | website | | | | N/A | No | Already | | selected | | | | through | | | | website | | | | Setting industry standards | Does not set | | | standards across | | | | industry but does | | | | set requirements | | | | for developer | | | | submissions | | | | Web pages | No | Yes - available | | on website since | | | | 2004. Prior to | | | | this, they were | | | | published | | | | internally and a | | | | small selection of | | | | these will be | | | | made. | | | | N/A | No | Select | | Providing training / skills | Training | | | exchanges with | | | | legal consultants; | | | | 1 year student | | | | placements in | | | | several | | | | departments | | | | increased greatly | | | | in 2006 under the | | | | auspices of the | | | | regeneration | | | | programme | | | | Personnel | | | | files, case | | | | files | | | | No | | | | Providing a service to another | | | | department/organisation, eg local | | | | IT services to | | | | RDA's. | | | | Files | | | | | | | | 25 | | | authorities, industry, car service, defence agencies? Partnership bodies as per individual agreements, records advice and storage services to Housing Action Trusts in advance of closure. Business appraisal for some RDA's e.g. checking tenders Making payments in response to applications Grants can be awarded to any application that falls within the English Partnerships remit e.g. grants made towards stabilisation of mines, towards social projects within regeneration areas etc Files, web pages No No No Select on merits; website will be collected twice yearly by ZWEB Providing guidance, information and support Large number of best practice and informational documents on website, mainly produced since 2004 in line with the FOI publication scheme. Examples include Additionality Guide, which Files, web pages No No No Select on merits; website will be collected twice yearly by THE NATIONAL ARCHIVES . Most guidance has been explains how to assess extra impact of a regeneration project beyond immediate environmental impact (eg job creation, crime reduction, improved access to educational facilities etc), and the Urban Design Compendium, which provides advice to developers on funding agencies and partners for provision of high quality urban design. Managing property (other than its own administrative sites) Property portfolios, both land and property on land until it is disposed of. Case files can be found in the papers of the Commercial Committee and in the files of the Asset Transfer Department, which includes the function of estates management Files (registered, unregistere d and case files) Assets Database - soon to be superseded Answering requests for information Not outside of produced since 2004 when English Partnership s' primary functions became fully concentrat ed on regeneratio n and provision of sustainable communitie s No Yes Select on merits | as a statutory function | FOI/DP/EIR's | |----------------------------------|-----------------| | Preventative or remedial work | Decontamination | | of land | | | (brownfield sites) | | | Case files, | | | policy files | | | Yes. | | | Information | | | relating to the | | | Coalfields | | | Programme in | | | particular are | | | entered onto | | | the National | | | Land Use | | | Database | | | Acquiring records as a statutory | | | function | | | English | | | Partnerships is | | | residual body for | | | 22 New Towns, | | | the Development | | | Corporations and | | | 6 Housing Action | | | Trusts (CNT), | | | and English | | | Industrial Estates | | | (URA) | | | Files | No | | keep | | | records | | | manageme | | | nt files, but | | | we may | | | want to | | | select files | | | relating to | | | outsourcing | | | as this is | | | the first | | | time a | | | governmen | | | t | | | department | | | has done it | | | to this | | | extent | | | Commissioning research | Yes, eg | | Stakeholder | | | Survey 2006, to | | | ascertain views | | | of stakeholders of | | | Reports | No | | published on | | | website and | | | should be | | | deposited with | | | | | | 28 | | | Yes. A summary | | | of progress is | | | made in the | | | annual report, but | | | files will need to | | | be selected if The | | | National Archives | | | is to document | | | this work. There | | | are four separate | | | publications on | | | the Brownfield | | | Sites Programme | | | which are all | | | capture on the | | | website | | | | | | merits | | | | | | through the | | | website | | way English Partnerships performs, Skills in Regeneration Research Study to identify core skills needed to promote and manage successful urban regeneration and development. the British Library under the Legal Deposit Act Undertaking research Yes, ATLAS (Advisory Team for Large Applications) carry out research for partners. Reports No Yes, reports are published on website and should be deposited with the British Library under the Legal Deposit Act No Selected through the website ## 4.4 Electronic Formats Datasets Name of database Purpose database serves in Agency Information contained of historical value English Sites database Advertises government land available for sale for redevelopment. Shows management of government funds by getting best value for land no longer needed. Decisions database Records all agenda, minutes, papers and action points of key English Partnerships committees Contains all policy and operational decisions at all levels. Currently excludes board because non-executive members cannot have access to database, but aim is to resolve this within the next year. Pilot began in Nov 2002 and records have been added to it since this date. National Land Use Database Database of vacant and derelict sites and other previously developed land and buildings with redevelopment potential Used jointly by the Local Government Management Board, DETR, Ordnance Survey and English Partnerships. Assets database Records all property assets held by English Partnerships. Currently being redesigned and upgraded. Existing information will be migrated onto the new system Property holdings are the source of English Partnerships' business. May be of archival value, but cannot look at system until new version is up and running. Structured Filing System Although there is no EDRMS at English Partnerships, there is a partially constructed SFS that will eventually consist of 57 themes, and into which electronic documents are already being filed. The hope is that the SFS will also form the structure in an EDRMS, but procurement of a system is not anticipated in the short term. Therefore, electronic records considered to be of corporate value are still printed off and put on a paper file. As a result of this, the SFS is not significantly populated at the present time. However, it is possible to make suggestions of which areas of the file plan support English Partnerships' core functions and are likely to be of interest to The National Archives. These are: - Strategic ventures, which will include the policy work on the Brownfield strategy. - Coalfields - Land stabilisation, which relates to stabilisation and redevelopment of land used for non-coal mining - Contaminated Land: Applications in Real Environments (CL:AIRE) - Millennium Communities - Urban Regeneration Companies - NHS Estates, which covers the purchase of property from the NHS, its redevelopment and resale - Liability transfers, which relates to English Partnerships' disengagement from various properties, including remaining CNT properties which, in line with the realignment of English Partnerships functions, are being transferred to local authorities or other - Projects, which will hold the records of individual projects within national programmes Image Library Corporate Image Library Archive (CILA). This contains images of English Partnerships sites once they have been redeveloped. Unlikely to be of interest to The National Archives but a suitable repository for it may be available. CILA is relatively new and will be appraised in 2010. A decision on disposition will be made then. Geographic Information Systems (GIS) 2 - GIS is used in Warrington and LIS (Land Information System) available; they are working tools and information comes from other organisations. It is an ongoing departmental function and is always changing. The GIS is currently being upgraded and a selection decision will be made once the new version is active. Website(s) snapshot of English Partnerships website should be taken every six months, although it has been irregular so far. English Partnerships also hosts residual websites for Housing Action Trusts for 12-18 months after the HAT is wound up, which are not available through the English Partnerships website. These are basic and do not have a high informational value. Selected HAT records are deposited locally; therefore no need to select websites. 4.5 Publications produced by the organisation ## Types of publications Preservation strategy Appraisal notes Place or form of publication Standards Website Preserved through website selected by The National Archives. No further selection than website needed Guidance/ codes of practice Website Preserved through website selected by The National Archives No further selection than website needed Selected for The National Archives until 2005 Annual reports HMSO to 1985, then published internally (for external circulation) Selected for British Library under Legal Deposit. Will not be selected for The National Archives from 2006 Preserved through website selected by The National Archives Select through website. Any not published online should be selected according to its subject matter. Research reports English Partnerships periodically commission research; the resulting reports are published on the website. Research carried out by English Partnerships for itself or third parties are also published online. Select examples only CNT newsletters selected for FJ 5; English Partnerships staff newsletters not yet appraised; website sufficient for Newsletters CNT newsletters (hard copy only); English Partnerships staff newsletters (hard copy only); 'Outlook' English Partnerships update newsletter published on website 3 times a year until 2005; variety of other newsletters newsletters relating to specific projects published online 4.6 **Scientific records** None 4.7 The Big Issues All English Partnerships strategic projects (e.g. Thames Gateway/SE expansion), Urban Development Programmes, Housing Estate Regeneration, Brownfield sites reclamation (e.g. Greenwich Peninsula), Coalfields programme, residuary body issues (e.g. Teesside UDC N.B. an NAO report was produced during period covered by this appraisal report), takeover of NHS/MOD sites (mainly disposed of to developers). 4.8 Internal administration records These will be selected in line with OSP38. It is expected that few internal administration records will be preserved, but documentation of organisational change, (e.g. any restructuring due to the alteration of English Partnerships' remit in 2004), staff directories, organisation charts, records of contentious staff issues will be selected. Records relating to the establishment of English Partnerships will largely precede the period covered by this policy; such records will be selected from ODPM records. 5 Additional Checks OSPs Dept of Environment OSP 1 - DoE was policy driver for CNT, but CNT barely mentioned in OSP. Committees OSP 35 - Committee papers selected in line with this Publications OSP 36 - publications selected in line with this Internal Administration OSP 38 - selection made in line with this Quality of committee minutes and papers CNT Executive Management Board is very active and as such will probably negate the need to select large numbers of other committee papers. Nature of documents included in any case files selected and the sort of information provided. Case files selected within committee papers - see Section 4, Table 1: Commercial Committee and Project Executive Committee. Location and provenance of records identified Doubt on part of DRO as to quality of record keeping at regional offices prior to records being deposited at the records centre. Relationship with paper records especially in any hybrid situation See Section 1.5. 6 Impact on records of parent department None anticipated. Records of policy and operational significance will be captured through English Partnerships' committee structure. Records affecting the establishment, remit and overall strategy will be selected from CLG. ## 7 Implications Of The Report For The Appraisal Of Agency'S Paper Records This Report Covers Records In Both Paper And Electronic Format. 8 Implementation Of The Policy At the time of writing (January 2007), a large team is preparing to review English Partnerships' records created prior to 1999. It is hoped that this review will be completed by the end of 2009 and records selected for permanent presentation will be deposited at The National Archives or places of deposit as appropriate. English Partnerships will also start review of both paper and electronic records in tandem on an annual review cycle from 2009, using this policy as guidance. This will ensure that transfer takes place when records in all formats reach 10 years old. Records will be made available to the public at this time, subject to the requirements of relevant information legislation.
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## Freedom of Information Act 2000 Request Please can you tell me how many people have been charged with offences under the Psychoactive Substances Act 2016 since its introduction in May? (If you are not able to give me the number of people charged, but can tell me the total number of charges instead, I would be happy to accept that as an alternative.) Can you also give me a break down of the charges ie possession with intent to supply, importation, offering to supply etc. Please can you also tell me how many of those were in prison at the time of the offence and give me the same break down of offences? Can you also tell me the sex and age of the person charged?' In response to your request, please see Attachment 1 which gives a table of data showing the number of offences brought by way of the Psychoactive Substances Act 2016 for the period May to September 2016 (a quarter in arrears as per Crown Prosecution Service (CPS) policy). Please refer to the caveats which apply and are appended to this table. There were 18 offences prosecuted in this period which are associated with 17 cases. I have undertaken a manual review of the 17 CPS case files in order to ascertain the more detailed information you have requested and this information appears in Attachment 2. Please note I have anonymised the ages of the persons involved to protect their personal data. Information Management Unit 020 3357 0899 FOI.Unit@cps.gsi.gov.uk
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BETTER ENVIRONMENT, BETTER HEALTH A GLA guide for London's Boroughs London Borough of Greenwich ## Copyright Greater London Authority November 2013 Published by Greater London Authority City Hall The Queen's Walk More London London SE1 2AA www.london.gov.uk enquiries 020 7983 4100 minicom 020 7983 4458 ISBN Photographs © Copies of this report are available from www.london.gov.uk ## Please Print And Circulate Widely Contents CONTENTS 1 FOREWORD 2 INTRODUCTION 3 GREEN SPACES 5 ACTIVE TRAVEL & TRANSPORT 8 SURFACE WATER FLOOD RISK 12 AIR QUALITY 15 HEALTHY FOOD 18 FUEL POVERTY 21 OVERHEATING 24 REFERENCES 28 FURTHER READING 31 PUBLIC HEALTH OUTCOMES FRAMEWORK 32 DATA APPENDIX 35 ACKNOWLEDGEMENTS 42 ## Foreword The Mayor's vision is for London to be the 'greatest city on earth' - this means making the city a great place for Londoners to live, relax, work and raise a family, whilst being attractive to investors. However there are significant inequalities in the health and quality of Londoners' lives. 2009-11 ONS figures show that average *healthy* life expectancy reduces by almost one year for every stop eastwards on the District Line between the boroughs of Richmond and Tower Hamlets - a difference of 18 years. The reasons for this are complex but the evidence points strongly to the important impact of the wider determinants of health. This inequality means some Londoners are unable to benefit from and contribute to the city's dynamism because of preventable health problems. The Mayor wants to ensure all Londoners have the chance to participate in what London has to offer. Furthermore, if we are to maintain and improve London's position as the attractive world city it is, we need to create a resilient city, able to deal with extreme weather events, and a city that offers a high quality of life with green spaces, a fantastic public realm and a pleasant, healthy environment. Local authorities have a unique role to play in achieving these goals, and with their new responsibilities for public health they have a new set of capabilities and levers for catalysing change. Better Environment, Better Health offers a bespoke guide to each of London's thirty three boroughs, describing the impact of seven wider environmental determinants of health on their specific populations and highlighting possible actions that could be taken to promote a better environment leading to better health and well-being, overall, for Londoners. For example we know that by encouraging walking and cycling we are not only helping to improve London's air quality but also cardiovascular health, whilst reducing levels of obesity. The guides demonstrate how such an approach can be taken on a range of issues, without necessarily adding to the financial burden on boroughs' already squeezed budgets, just by doing things differently. We hope you will find value in the guide and will use it to drive improvements locally to create strong environments which promote health and well-being, and are resilient. Finally, we would like to thank the project team for writing the guides and their drive in taking this project forward. Victoria Borwick Matthew Pencharz Deputy Mayor of London Senior Advisor for Environment and Mayoral Health Advisor and Energy ## Introduction What is likely to shape the health of our communities over the next twenty or thirty years? What will improve quality of life? What will help people live longer, particularly those most likely to die early? What will improve people's quality of life, reducing years lost to disability and poor mental and physical health? What will improve the health and wellbeing of children and young people? The United States Center for Disease Control and Prevention (CDC) has argued that in the 20th century public health measures added 25 years to the life of an average American.1 In its list of top ten interventions half are closely connected to the environment. The same list would be likely to apply to the UK and London. In the 21st century public health measures, including measures seeking to improve the environment, are likely to be as important in supporting good health as improvements in healthcare. We need to prepare, assess and plan for extreme weather events and their impacts not just to improve Londoners' health and wellbeing but to increase economic prosperity, for business and service continuity and to strengthen community resilience. In this guide we focus on seven environmental issues and their relationship to health: - Green spaces - Active travel & transport - Surface water flood risk - Air quality - Healthy food - Fuel poverty - Overheating For each of these we ask certain questions: - What is the issue and how do we measure it? - What is its impact on health? What is the evidence? - Who will experience the impact most? - What is the local borough picture? - What are the key actions to promote good health? We also provide links to the Public Health Outcomes Framework and suggested further reading. The aim of the bespoke borough guides is to maximise opportunities for improving health and wellbeing, as well as enhancing community resilience. They are aimed at professionals working in health, environment, regeneration, economic development or any aspect of shaping local places, as well as local people interested in improving the quality of life in their communities. Where issues are locally relevant we hope this document will help to start a conversation which enables them to be identified and addressed in borough Joint Strategic Needs Assessments (JSNA) and health and wellbeing strategies. These guides do not cover all of the wider environmental determinants of health. For example, they do not look at some aspects of housing (such as overcrowding), workplace health, wider resource use, access to services, water resource management or noise pollution. More broadly, issues of planning and environmental control tie many of these areas together. How we shape ongoing development and use of our town centres, neighbourhoods and business districts presents opportunities to maximise the health of users: residents, employees and visitors. Similarly, environmental consideration provides the scope to address potential risk to resilience, health and wellbeing as well as promoting good practice amongst, for example, businesses, landlords and facilities managers. ## Green Spaces Accessible green space has long been recognised as a wider environmental determinant of good health. Wide ranging research shows strong evidence that outdoor spaces have a beneficial impact on both physical and mental well-being2. When considering green space it is helpful to think about both access and **use:** availability being a necessary but insufficient indicator and determinant of use. A range of data are available on both access and use including the Natural England MENE survey (frequency, mode of access, reasons3); London.gov.data: 'Access to Public Open Space and Access to Nature by Ward'4; and Sport England: Active people Survey (physical activity rate)5. What is the impact on health? Accessible, safe green space is shown to reduce mental distress, depression and Attention Deficit- Hyperactivity Disorder (ADHD) symptoms in children. Access to a garden or living a short distance to/from green areas, as well as having the potential to lead to improvements in the environment, are associated with a general improvement in mental health and wellbeing.6 Both the Marmot Review and NICE have highlighted evidence that the presence of good quality outdoor green spaces encourages physical activity7 which is important across a wide range of health issues such as cardiovascular diseases, obesity, type 2 diabetes and mental/physical health. Increasing and improving the proportion of green spaces in urban centres also has a secondary positive impact on health through other wider environment determinants of health such as urban heat-island effect, surface flood risk and air quality. Who will experience the greatest impact?  Urban residents (through impact on quality of life)  Older people and children  People suffering from obesity, cardio-vascular diseases, diabetes  People suffering from mental distress and depression. ## The Greenwich Picture - 34 per cent of the borough surface has green space coverage; 3 per cent above the London average.8 - Within Greenwich, more than 40 per cent of households in 1 out of 17 wards, have deficient access to nature.9 - 20 per cent of Greenwich's population participate 5 times per week in physical activity for at least 30 minutes and 55 per cent participate once a week which is below the London average.10 - Greenwich's adult obesity prevalence is 23 per cent, which is higher than the London rate, 21 per cent, but lower than the national rate, 24 per cent.11 Pink coloured areas are defined as area of deficiency in access to local, small and pocket parks. Proximity rate is +/- 400m from households. http://www.gigl.org.uk/Ourdatasets/Openspace/tabid/117/Default.aspx Potential actions: Given the significant relationship between health and green spaces in the urban environment some key actions can be identified to improve quality and proximity in order to enhance access and use. This includes considering: - All London Green Grid Supplementary Planning Guidance to improve *biodiversity* function and connectivity of green spaces;12 - The Green Flag Award system to improve quality and promote access to green spaces.13 - Promoting physical activity in outdoor spaces through "outdoor gyms" and "guided walking exercise prescription" as a way to recover from cardiovascular diseases and illness.14 See also sections on surface water flood risk and healthy food. Case Study: Regenerating Burgess Park, London Borough of Southwark The regeneration of Burgess Park, in Southwark, was underpinned by a comprehensive plan that made the focus of the park a place for healthy living, showing how to combine ' natural' regeneration with health promotion15. This has also included opportunities for investment, growth and jobs. For example improved access to, and routes through, the park, alongside enhancements to the lakes, planting, lighting and on-site facilities, has made the park a much more attractive and welcoming place, encouraging play and informal recreation. The park also has over 10 km of running, cycling and fitness routes and a new BMX track, to cater for more formal sport and physical activity. Contact: Ruth Miller, Burgess Park Project Manager ruth.miller@southwark.gov.uk ## Suggested Further Reading Links To Public Health Outcomes Framework - Planning for Health (2009) HUDU - The Marmot review (2010) www.instituteofhealthequity.org - www.nice.org.uk - Benefit of Urban Parks, IFpra (2013): - www.ecehh.org Primary 1.16 Utilisation of outdoor space for exercise/health reasons Additional (for example) 2.6 Excess weight in 4-5 and 10-11 year olds 2.13 Proportion of physically active and inactive adults 2.23 Self-reported well-being - www.naturalengland.org.uk - www.hphpcentral.com - CMO (2011) Start Active, Stay Active ## Active Travel & Transport Travel is essential for connecting people to employment, recreation, education and health and community services. Most people travel in some way every day, making it part of everyday life and therefore a factor that can greatly affect the health of all London's citizens16. Travel includes walking and cycling, use of private vehicles, public transport and goods vehicles. In London more than 80 per cent of journeys take place on roads either by motor vehicle, bike or on foot; therefore road transport and street environments have a very significant impact on health and wellbeing17. There are inequalities in the impact of transport upon health, with the most deprived people and those using the most heavily trafficked roads experiencing the most negative health impacts18. Only a few London boroughs include a dedicated transport focus in their Joint Strategic Needs Assessment (JSNA), suggesting the impact of travel on health may be underestimated. What is its impact on health? A comprehensive public transport network provides many health benefits including access to services, reducing social isolation and increasing work and social opportunities. A major benefit of travel in London is that it enables people to maintain regular physical activity via walking (particularly as part of public transport trips) and cycling. Only around 20 per cent of Londoners currently meet the minimum recommendation for physical activity of 150 minutes per week19. Everyday physical activity is essential for good physical and mental health, contributing to the prevention of over 20 diseases including obesity, type 2 diabetes, cardiovascular disease and some cancers20. Cycling and walking can be easily incorporated into daily routines to meet physical activity needs. In London, approximately 4.3 million trips currently made by car or public transport have been identified as easily cyclable21. Creating opportunities which enable Londoners to walk and cycle has other potential health benefits including access to safe, green spaces. This could lead to reductions in congestion which, in turn, may reduce overheating and improve air quality. The negative impacts of transport in London are concentrated in the London's most heavily trafficked streets, where high concentrations of vehicles contribute to air and noise pollution and increased injury risk22. This can create the impression of a hostile environment for walking and cycling and can exacerbate health inequalities. Motor vehicles are responsible for 41-60 per cent of air pollutants in the UK, which have an impact on cardiovascular and respiratory diseases. People who live on or use heavily trafficked streets are the most adversely affected. ## The Greenwich Picture  On average 428,000 trips per day are made by people originating in Greenwich.23  Low numbers of people participate in active travel, with the percentage of people cycling to work below the Greater London average.  Use of motor vehicles is 9 per cent above the Greater London average but below the Outer London average.24  There was an average of 919 casualties and 9 fatalities per year on Greenwich's roads between 2005 and 2009: one of the highest in London.  The most heavily used road (excluding motorways) is the A2 with an average daily flow of 95,000 motor vehicles.25  The Borough has one cycle superhighway proposed in the Mayor's 'Vision for Cycling'.26 Source: London Travel Demand Survey Potential actions: - Designing street environments to encourage walking and cycling. - Designing and engineering roads to reduce motor vehicle speed and implement 20mph zones where appropriate. - Promoting a network of roads and paths that are safe and convenient for cycling and walking. - Supporting walking and cycling by ensuring that, where possible, the needs of cyclists and pedestrians are considered before other road users. - Promoting cycling through information, maps and cycle hire schemes. - Improving safety of heavily trafficked streets where most traffic related health risk is concentrated. See also section on air quality. Case Study: Cycling across Hackney Hackney has the highest levels of cycling in London. There are more cyclists than motorists in many parts of the borough. This is evidenced by the fact that 6 per cent of journey's originating from Hackney are on bike, higher than any other borough in London23. Since 2001 the Council has sought to increase the areas that are cycle friendly by improving the design and increasing the accessibility of the road network for cyclists.27 - Road safety has been improved by reducing motor traffic speeds and volumes. The aim is to enforce 20 mph speed limits across the borough on all residential roads.27 - Systematic improvements have been made to the public realm for pedestrians, cyclists and public transport users and a number of designated cycle routes such as the Hackney Park cycle route have been created.27 - Hackney has invested in a range of cycle parking bays including lockers in estates, hangars (on street bike/storage lockers), on residential streets and large bike ports at transport hubs such as railway stations and town centres. - A comprehensive free cycling training programme has targeted a range of audiences.27 Contact: Ben Kennedy, Hackney Council, ben.kennedy@hackney.gov.uk Example of a cycling improvement scheme Wordsworth Road/Palatine Road, Hackney ## Links To Public Health Outcomes Framework Suggested Further Reading - Healthy Transport Healthy Lives, British Medical Association (BMA) - NICE Walking and Cycling, Local Government Briefing - Mayors Vision for Cycling, 2013 GLA - London Borough of Hackney Sample of ## Primary 2.13 Proportion Of Physically Active And Inactive Adults Additional (For Example) 1.16 Utilisation Of Outdoor Space For Exercise/Health Reasons 2.7 Hospital Admissions Caused By Unintentional And Schemes for cycling & public realm (2013) deliberate injuries in under 18s 3.1 Fraction of mortality attributable to particulate air pollution - What are the health benefits of active travel: A systematic review of trials and cohort studies, PloSOne, 8 ## Surface Water Flood Risk Surface water flooding describes flooding on the land surface from sewers, drains, groundwater and runoff from land after a heavy rainfall event28. Surface water flooding events are difficult to predict but can cause significant disruptions to local populations and to health and other services. London is vulnerable to surface water flooding because some areas have poor drainage systems and large areas of impervious surfaces29. Approximately 480,000 London properties and ten hospitals are at risk of surface water flooding in London30. Surface water flooding is already a considerable risk and one that, without action, will increase in London due to population growth, urban expansion and ageing of drainage systems. In addition, changing climate patterns are likely to increase the number and intensity of large magnitude precipitation events leading to a likelihood of more frequent and larger magnitude surface water flooding events. Local Flood Authorities are responsible for mapping, assessing and managing local flood risks, identifying whom and what is at risk and the vulnerability of services such as hospitals and schools to surface water flooding. The Mayor's Regional Flood Risk Appraisal identifies surface water flood risk as the most likely cause of flooding in London. The GLA, Thames Water, the Environment Agency and London Councils have been developing and delivering a programme to manage this risk, known as Drain London. There are multiple ways in which flooding can create health risks: - Fast flowing water has multiple potential hazards such as moving debris which can cause physical injury and even death. Contaminated flood water containing pollutants such as chemicals and sewage can cause disease. - Flooding of health facilities results in disruption to access to healthcare facilities, with increased difficulty providing routine medical care and increased patient admissions in neighbouring facilities. - Exhaust emissions from machinery operating in the clean-up process and recovery from a flood can cause carbon monoxide poisoning31. - Disruptions in flood recovery, fear of repeat events and added effects of stress due to insurance claims and refurbishing properties can cause mental health problems. Up to 25 per cent of people who experienced flooding in their homes in the major UK floods in 2007 experienced mental health issues after the event32. Who might experience the greatest impact? Some areas in London are at risk of surface water flooding particularly where there is inadequate sewer/drainage capacity, and some groups are at greater risk4. These include people with limited mobility or/and those who are dependent on medication and/or regular healthcare at home or at a health/social care facility. Those with less flood awareness due to weak social networks and limited or no access to public warning systems and/or information are also at risk. The Greenwich Picture The Environment Agency will be releasing a national surface water flood risk map for each London borough in December 2013. Whilst this will show the areas at risk it should also be noted that any low lying area could also potentially be affected but may not be visible on the maps because of the difficulty in assessing surface water flood risk. The maps will provide borough-specific assessments. Potential actions: - Developing emergency plans to reduce effects of surface water flood risk. - Including integrated emergency planning for priority groups/services. Developing land management strategies such as green roofs to reduce likelihood of surface water flooding. - Incorporating Sustainable Urban Drainage Systems (SuDS) as an alternative to traditional approaches to managing runoff. - Identifying vulnerable and isolated people and implementing early warning systems and evacuation plans. - Planning for disruption of infrastructure and increase in patient volumes at health and social care facilities. See also section on green spaces and healthy food ## Case Studies: Purley (Lb Croydon) Community Flood Plan 6 - Purley is vulnerable to flooding and experienced a large flood event in 2007. In response the community developed a Community Flood Plan. - The flood plan is owned by the community, and aims to reduce the impact of flooding. - It advises the community on how to prevent flooding and what to do if it happens. - It is a low cost but effective way of reducing a wide range of impacts of flooding. - The community has created a number of flood wardens who play a central role in advising local citizens and businesses on the flood risk and actions they can take to reduce the impact and nature of flood events. ## Surface Water Flooding Event, London, July 2007 7 - In July 2007, 121mm of rainfall fell in London, mostly on July 20th, causing some significant surface water flooding. - Approximately 400 properties were flooded, 158 schools affected and two hospitals were closed as a result. - The closure of St George's Hospital caused major disruption.8 ## Suggested Further Reading Links To Public Health Outcomes Framework - GLA Regional Flood Risk Appraisal, 2013 - Drain Londonhttp://www.london.gov.uk/priorities/environment/loo king-after-londons-water/drain-london Programme London Climate Change Adaptation Strategy - Multi-Agency Flood Plan, LB Havering, 2012 - Floods in the European Union, Health effects and their prevention (2013), World Health Organisation (WHO) Primary: 3.7 Comprehensive, agreed interagency plans for responding to public health incidents and emergencies Additional (for example) 3.6 Public sector organisations with a board-approved sustainable development management plan ## Air Quality Good air quality has long been recognised a basic requirement for good health. The UK Air Quality Standards Regulations 2000, updated in 2010, set standards for a variety of pollutants that are considered harmful to human health and the environment. These are based on EU limit values and are for a range of air pollutants: sulphur dioxide, nitrogen dioxide, oxides of nitrogen, particulate matter (PM10 and PM2.5), lead, benzene, carbon monoxide, benzo(a)pyrene and ozone. Much of the focus of air quality action is on nitrogen dioxide (NO2) and particulate matter (PM). Particulate matter (PM10 and PM2.5) refers to a complex mixture of non-gaseous particles of varied physical and chemical composition. It is categorised by the size of the particulate. In London, road traffic is a significant source of PM mainly from exhaust emissions and wear, tyre and brake wear and dust from road surfaces. In addition, older furnaces and boilers may have an impact on the overall air quality environment within a house. Poor air quality could potentially compromise health and well-being. It should be noted that exceedences apply across the whole of London, particularly near built up areas and major roads. What is the impact on health? What is the evidence? Long-term exposure to poor air quality can contribute to the development of chronic diseases and can increase the risk of respiratory illness. In Greater London it is estimated that the equivalent of 4,267 deaths in London in 2008 were attributable to long-term exposure to PM2.5. It should be noted that this does not relate to real individuals, but is a statistical construct whereby all health impact associated with air pollution are amalgamated. Since everyone breathes the air where they are, a more realistic interpretation is that the risks are distributed across the whole population, with a total mortality impact of the concentrations equivalent to that number of deaths. At high concentrations NO2 can result in inflammation of a person's airways; long-term exposure can affect lung function and respiratory symptoms and can increase asthma symptoms. PM aggravates respiratory and cardiovascular conditions. The smaller the particle, the deeper it will deposit within the respiratory tract. The impact of PM2.5 on health is especially significant. Who may experience the greatest impact? - People who live or work close to areas with poor air quality - People with respiratory problems - People with heart problems The Greenwich Picture - On some of Greenwich's main arterial roads there are high concentrations of NO2 (see map) which are above the recommended limits. - Statistical tools are used by public health specialists to try to understand the comparative impact of different factors on mortality. Using these techniques, Greenwich is the 14th most affected area by poor air quality in London. 33 - In 2011 the GLA identified seven Air Quality Focus Areas within Greenwich. ## Potential Actions: - Promoting A Modal Shift To Encourage Higher Proportions Of Walking, Cycling And Use Of Public transport and less use of cars. This could include a wide range of measures from systemic action within the planning and transport system to one-off events such as car free days. Such measures could lead to significant improvements in air quality. - Promoting energy efficiency in homes, public and commercial offices. For more information see the Energy Company Obligation34. - Individual steps could be taken to: a) reduce personal contribution to air pollution such as engine idling; and, b) reduce risk of exposure where it is potentially hazardous to health (particularly for people with underlying vulnerabilities) through systems such as airText. See also section on active travel and transport. ## Case Studies: Reducing Exposure - City Air Mitigating Impact - Croydon Air Text 'CityAir' was launched in May 2011 in the City of London to encourage businesses to help to improve local air quality. Best practice guidance and case studies were produced to provide advice to City businesses on reducing emissions from buildings, encouraging staff to walk and cycle in the City, using purchase contracts to require low polluting vehicles and building air quality targets into environmental reporting. Information is available at www.cityoflondon.gov.uk/cityair. To date over 50 businesses have been engaged, representing over 40,000 employees. CityAir employee walking campaigns have been very popular. Contact: Ruth Calderwood ruth.calderwood@cityoflondon.gov.uk In 2005 the London Borough of Croydon developed with the European Space Agency and Cambridge Environment Research Consultants an air quality forecasting service called 'airTEXT'. AirTEXT provides information on pollution levels in the borough using 'low', 'moderate' and 'high' bandings. Whenever moderate or high pollution levels are expected, subscribers to airTEXT receive a text message, call or voicemail. This enables recipients to respond, if necessary, for example by taking a different route/mode of transport to work, keeping their medication with them or not exercising outside on certain days. In 2012 a new airTEXT app was developed which provides information on four health-relevant alerts: UV, pollen, air quality and temperature. Currently around 10,000 people use the airTEXT service through text, Twitter or the website. ## Suggested Further Reading Links To Public Health Outcomes Framework - GLA Local Authority Air Quality Guides - www.londonair.org.uk - www.comeap.org.uk - NICE Guidance PH41 Walking and cycling: local measures to promote walking forms of travel or recreation - Kilbane-Dawe (2012) 14 Cost Effective Primary 3.1 Fraction of mortality attributable to particulate air pollution Additional (for example) 2.13 Proportion of physically active and inactive adults 1.14 The percentage of the population affected by noise Actions to Cut Central London Air Pollution ## Healthy Food Access to healthy food is an important wider environmental determinant of health. Improving the food environment means enhancing the availability of affordable and nutritious food and recognising the relationship between the geography of food retailing and dietary patterns35. It also means considering of sustainable production, processing and delivery. Policy attention has focused on the role of local planning measures and the impact of large supermarkets, provision of food growing places, the physical environment and education on a healthy diet. Many factors influence the availability of healthy food. The predominance of unhealthy food and low income may interact with environmental factors to limit access. Access to healthy food can be measured through the following indicators: cost, quality, geography, mode of transportation, physical proximity and socio-economic variables. What is the impact on health? What is the evidence? Reduced access to healthy food and the ready and cheap availability of unhealthy foods (such as fastfood and takeaway outlets) increases the risk of a diet based on high consumption of sugar, saturated fat and salt and low in vegetables and fruit36. This could lead to obesity, cardiovascular disease, type 2 diabetes and some cancers associated with obesity. The National Obesity Observatory estimated the cost to the UK economy of overweight and obesity to be £15.8 billion per year (2007). This has an impact on children as well as adults. Studies have also found that an increased density of fast food restaurants is directly related to increased Body Mass Index (mass index showing body fat based on height and weight) and that having a fast food outlet within 160m of a school is associated with a 5 per cent increase in obesity37. The Greenwich Picture  Greenwich's adult obesity rate is 23 per cent. This is higher than the London average (21 per cent), but lower than the national average (24 per cent).38  Greenwich's obesity rate among primary school children (year 6) is 25 per cent. This is higher than the national and London rates (19 and 23 per cent respectively).39  In 12 out of 32 Middle Super Output Areas (two darkest blue areas on map), 33-42 per cent of the total population consuming five portions of fruits and vegetables a day.40  20 per cent of Greenwich's population participate five times per week in physical activity for at least 30 minutes and nearly 55 per cent participate once a week.41 ## Potential Actions - Developing Schemes To Promote Local And Easily Accessible Healthy Food From Retailers (For Example www.cieh.org/healthier-catering-commitment.html). - Using planning controls to manage proliferation of fast-food outlets on high streets and near schools. - Promoting the GLA Healthy Schools London Awards Initiative (www.healthyschoolslondon.org.uk). Healthy food choice in schools is recognised as a way to tackle obesity and chronic diseases caused by poor nutrition. This includes diet, education, and healthy meals provided at schools and accessible from nearby areas. - Capital Growth (www.capitalgrowth.org) initiatives have the potential to promote community food growing. These activities reconnect people to the food system, engages them in issues such as where their food comes from, seasonality, healthy eating, and food security. - Procuring from local food suppliers and retailers, signed up to the Healthier Catering Commitment Plan. See also section on green spaces and surface flood risk. Case Study: Fast-food Fix - LB Waltham Forest - Tackling the Takeaways: Making an Impact - Community engagement on 'takeaways' in the borough identified dissatisfaction with the number and location of 241 local hot food takeaways (HFT). This included schools, concerned that the proximity of HFTs to schools had a negative impact on healthy eating programmes. - A HFT corporate steering group was established to: - Ensure existing HFT businesses operated as responsibly as possible; - Develop strategies to tackle the wider social, environmental and economic issues associated with the proliferation of HFTs in the borough. Achievements: - Supplementary planning documents were developed restricting the opening of new HFT shops. So far, 20 applications have been refused planning permission and only 4 HFTs have been given planning permission. ## - Hfts In The Borough Have Been Reduced From 241 To 194 Contact: Gordon Glenday, Head Of Planning Policy And Regeneration Gordon.Glenday@Walthamforest.Gov.Uk Links To Public Health Outcomes Framework Suggested Further Reading  NICE guidance: www.nice.org.uk  Takeaways Toolkit (2012): see www.london.gov.uk  District Action on Public Health: http://districtcouncils.info/;  CIEH Food Policy, (2013): www.cieh.org  Healthy People, Healthy Lives, (2011);  Good planning for Good Food: see ## Primary: 2.11 Diet Additional (For Example): 2.6 Excess Weight In 4-5 And 10-11 Year Olds 2.12 Excess Weight In Adults 2.17 Recorded Diabetes www.sustainweb.org/publications/?id=192 ## Fuel Poverty There are three factors that can result in fuel poverty, often in combination: low income, poor energy efficiency in homes and increasing energy prices. A household is now defined as 'fuel-poor' if its total income is below the poverty line (taking into account housing energy costs) and its energy costs are higher than typical for its household type.42 Data on fuel poverty is collected from the English Housing Survey Domestic Fuel Inquiry and published annually by the Department of Energy and Climate Change (DECC). More than 560,000 households in London are estimated to be spending more than ten per cent of their basic income on energy (the previous official definition of fuel poverty).43. Fuel poverty has the potential to have an adverse impact on children already in poverty as well as to increase the numbers of children living in poverty. Fuel poverty is also known to have an impact on well-being as indicated in self-reported well-being surveys.44 What is the impact on health? What is the evidence? Fuel poverty can have a negative impact on health, especially on people with pre-existing medical conditions. Fuel poverty results in cold homes, exacerbating cardiovascular and respiratory conditions, rheumatoid arthritis and influenza, and negatively affects mental health.42 The effects of fuel poverty may be compounded by social isolation, poor emotional well-being, reduced mobility and poor diet. Cold homes are also known to affect cognitive performance. However, actual deaths are only one part of the problem. Age UK estimates the cost to the NHS of cold homes as £1.36 billion per year (not including additional costs to social services for subsequent care).45 The recent DECC fuel poverty framework attempts to monetise the health impacts of fuel poverty. It refers to a model estimating changes in people's health from the installation of energy efficiency measures (resulting from changes in the indoor temperature and pollutant exposure).46 Who might experience the greatest impact? Fuel poverty affects vulnerable groups such as older people, the group most likely to suffer excess winter deaths. Children, people with disabilities and/or those living in deprivation are also at greater risk of suffering from the effects of fuel poverty as they often need to spend longer time indoors and require heating for longer periods of time. Additionally, private sector tenants are at significantly greater risk of encountering the worst housing quality and are also least likely to access support or feel empowered to do anything about the issue. The Greenwich Picture - The older population of Greenwich is projected to rise from 27,300 (2012) to 38,200 (2025) and 54,100 (2040). 47 - A Fuel Poverty Risk score has been developed. Overall, the borough is at risk of fuel poverty with Blackheath Westcombe achieving the highest score but still ranking 243rd of all 625 London wards. - There are no Greenwich wards are at low risk of fuel poverty and seven are at high risk according to the fuel poverty risk indicator. On the positive side, one ward– Eltham West shows a positive trend of having significantly improving its risk score between 2006-2010.48 Source: GLA (2013) Fuel Poverty Risk Indicators Tool, available on London Datastore The Fuel Poverty Risk Index was developed by the London Assembly Health and Public Services Committee in their investigation into fuel poverty in London. It is calculated on the basis of twelve indicators across four sections: Housing Dwellings without central heating Uninsulated cavity walls Lofts with less than 150mm insulation Health Health Deprivation & Disability domain (ID2010) Standardised Mortality Ratio Incapacity benefit claimant rate Older people People aged 60 and over Older people claiming pension credit Worklessness Unemployment Poverty Income support claimant rate Child Poverty rates Households classified 'fuel poor' ## Potential Actions: The First Key Step To Any Intervention Is To Identify Vulnerable Areas/Individuals And Map The Extent Of The Problem. Vulnerable Individuals And Households Can Be Identified And Supported Through: - Close Collaboration With Third-Sector Organisations Which Are Working With Vulnerable groups/isolated populations/people to refer or inform them of available support. - Home energy improvements as a vital sustainable solution to fuel poverty. There are opportunities through initiatives such as the Green Deal and Energy Company Obligation49. The Mayor's RE:NEW Programme support team50 can offer advice on funding, procurement and best practice to partner with energy efficiency providers. In addition, the issue of overheating should be taken into account when implementing any energy efficiency works especially wall and loft insulation. Whilst take up of the Green Deal to date has not been significant, it remains an important delivery mechanism to reduce fuel poverty in London. (See section on overheating). - Promoting collaboration between local authorities and private landlords in line with upcoming energy efficiency legislation (2018 energy efficiency requirements51). - Raising awareness of benefits entitlement and support through public health campaigns, working with third sector organisations and the local community. ## Suggested Further Reading See also section on overheating and air quality. Case Study: Barts Health in Tower Hamlets - Reducing Fuel Poverty Barts Health has recently established a partnership project with British Gas and Global Action Plan that aims to reduce fuel poverty in Tower Hamlets. Hospital staff, GPs and community groups refer patients from vulnerable groups or those people living in hard-to-treat homes to the Energy Companies Obligation, supporting the installation of energy efficiency measures in low-income households. The project will train and support 40 health professionals (GPs, outpatient care staff and community nurses) plus community groups. The partnership initially aims to target 200 homes. The initiative is not just a referral mechanism but will raise awareness among vulnerable groups, medical practitioners and the wider community on what steps could be taken to address fuel poverty. Such an initiative could be linked with other seasonal health initiatives such as winter flu jab promotion. Contact: Fiona Daly, Barts Health NHS Trust, fiona.daly@bartshealth.nhs.uk Links to Public Health Outcomes Framework - Marmot Review Team, 2011 - The Health Impacts of Cold Homes and Fuel Poverty Primary 1.17 Fuel poverty Additional (for example) 1.1 Children in poverty 2.23 Self-reported well-being 4.15 Excess winter deaths - Age UK, 2012 - The Cost of Cold - Hills, 2012, Getting the measure of fuel poverty - DECC, 2013, Helping-households-to-cut-their-energy-bills - DECC, 2013, Fuel Poverty, A Framework for future action. - London Assembly, 2012, In from the cold? Tackling fuel poverty in London, GLA ## Overheating What do we mean by overheating? How do we measure it? Extreme weather events are more likely to be a factor affecting people's health in future years52. Heatwaves, such as the one in the summer of 2003 which caused the death of 2000 people, could become more frequent (London had an excess mortality of 42%, compared to England of 17%). The Urban Heat Island (UHI) effect means that urban areas tend to be hotter than rural areas. This is due to increased absorption of the sun on concrete compared with green or brown spaces, reduced cooling from breezes due to buildings and increased heat production from houses, industry, businesses and vehicles. This is especially relevant for London with its densely built-up central boroughs and high concentration of traffic and people. The UHI effect is not universally experienced across the city as it relates to availability of green space/water bodies, building density, amount of traffic and energy consumption. However there are particularly vulnerable spots in each borough, as well as vulnerable people across areas. (See maps below). When considering London as a whole, the costs associated with overheating mortality are expected to be around £7-78 million in the 2030s (473-712 heatattributable deaths); by the 2050s, this could rise to £13-149 million (1200-1838 heat-attributable deaths).53 What is the impact on health? Overheating54 can cause heat strokes, exacerbates existing cardiovascular and respiratory conditions and affects people with respiratory conditions due to a combination of overheating and poor air quality. A heatwave can also affect mental health with peak suicide and homicide rates reported during previous heatwaves in the UK. Research has shown a direct link between a temperature rise to more than 24˚C and risk of death.55 Additionally, people may suffer from heat-related illnesses, such as heat cramps, heat rash and heat syncope (fainting as a result of overheating). Overheating may lead to dehydration, especially in older people, and there is a strong link between high temperatures, dehydration and blood stream infections, also particularly in older people.56 Who will experience the greatest impact? Certain housing conditions (older and small top floor, purpose built flats because of the low solar protection offered by the top floor of poorly insulated flats; and newly constructed houses not suitably designed for extreme heat events and the quality of the built environment could potentially contribute to the overheating of an environment. Certain groups such as children have less efficient body cooling mechanisms and are therefore at greater risk. Similarly, the body's thermoregulatory mechanisms could be impaired in older people and those with chronic health conditions. Those considered vulnerable to overheating may not always perceive themselves to be at risk. Simple measures to reduce the negative impacts of overheating are not always implemented which could place these groups at even greater risk. The Greenwich Picture The map below shows temperature differences across the borough and also shows the effects of existing infrastructure and green space on overheating risk. Combined with data on vulnerable populations this will provide a more precise picture of the biggest risk areas. Model simulations of London's temperatures were provided by Dr. Sylvia I. Bohnenstengel (University of Reading) using the Met Office Unified Model and MORUSES (MetOffice Reading Urban Surface Exchange Scheme) (Bohnenstengel et al., 2010). London Average Screen Temperatures in degrees Celsius for the period 26 May-19 July 2006 Equal count mapping method: each interval; contains 7% of the total number of grid points Potential actions: The NHS Heatwave Plan for England 2013 suggests actions to mitigate and/ or ameliorate some of the effects of future heatwaves and hot weather.57 Short term actions include:  Modifying surface properties and integrating green infrastructure, for example, 'cool roofs', 'green roofs' and 'cool pavements' (paving materials that tend to reflect, provide cooler surfaces and increase water evaporation ratio).  Planting trees and vegetation and creating green spaces to enhance evaporation and shading, (temperatures in and around green spaces can be several degrees lower than their surroundings). The development of 'green spaces' can not only help to alleviate the impact of the UIH effect but has been shown to have other positive health benefits such as improving mental health and wellbeing. Increasing green infrastructure also improves air quality.  Insulating homes. This protects against hot weather as well as reducing heating needs in the winter.  Introducing an active transport plan or car-sharing schemes. These will reduce numbers of vehicles used leading to improvements in air quality, whist promoting healthy living.  Using reflective paint on south-facing walls and roofs. - Taking fuel poverty into account when implementing any energy efficiency works. - Considering using the planning process to influence planning decisions on housing and commercial properties' heat thresholds. - Retrofitting public buildings with energy-saving technology - including low-energy lighting and high-efficiency boilers. This presents one of a number of opportunities to improve on infrastructure, growth and support local job creation. The Plan makes the case for a medium term (10–30 years) and long term approach (30+ years). See also section on fuel poverty and air quality. Case Study: London Borough of Islington and the CRISP Project CRISP is a joint project between Islington Council and North London Cares that took place in the beginning of 2013. Research among residents aged 65+ concluded that the majority of elderly people did not take hot weather issues as seriously as cold weather issues. Although levels of information were generally found to be good, there were some everyday actions being taken that might exacerbate the risk of overheating. The project identified the need for a widespread information campaign on proper use of windows, curtains and fans. The research identified challenges of communicating information about overheating. The findings and recommendations will inform Islington's Council Seasonal Resilience Plan and the work of the Seasonal Health Interventions Network (SHINE). Contact: John Kolm-Murray, Islington Council john.kolm-murray@islington.gov.uk Links to Public Health Outcomes Framework ## Suggested Further Reading  NHS Heatwave Plan for England  RE:FIT is the Mayor of London's innovative scheme to reduce carbon emissions in Greater London, www.refit.org.uk  GLA (2011) London Climate Change Adaptation Strategy  London Climate Change Partnership (2012) Heat Thresholds Project: Final Report  Built Infrastructure for Older People in Conditions of Climate Change (BIOPICCC)  Design and Delivery of Robust Hospital Environments in a Changing Climate (De2RHECC) Primary: 3.7 Comprehensive, agreed inter-agency plans for responding to public health incidents and emergencies Additional (for example) 3.6 Public sector organisations with a board-approved sustainable development management plan ## References 1Centre for Disease Control and Prevention (CDC), 2013,from CDC (USA); www.cdc.gov/about/history/tengpha.htm 2 Evidence demonstrating links between access to green spaces and health: Coombes, E., Jones, A P, & Hillsdon, M. (2010). The relationship of physical activity and overweight to objectively measured green space accessibility and use. *Social science & medicine*, 70(6), 816-822; Maas, J., Verheij, R. A.,et al (2006). Green space, urbanity, and health: how strong is the relation? Journal of epidemiology and community health, 60(7), 587-592; Nielsen, T. S., & Hansen, K. B. (2007). Do green areas affect health? Results from a Danish survey on the use of green areas and health indicators. *Health & place*, 13(4), 839-850; Schipperijn, J., Bentsen, P et al (2013). Associations between physical activity and characteristics of urban green space. *Urban Forestry & Urban Greening*, 12(1), 109-116. Mitchell, R., & Popham, F. (2008). Effect of exposure to natural environment on health inequalities: an observational population study. The Lancet, 372(9650), 1655-1660. 3MENE Survey evidencing frequency, mode and motivation in access to Green Space, (2012-2013), from Natural England www.naturalengland.org.uk/ourwork/research/mene.aspx 4Local access to public open spaces, taken from Access to Public Open Space, (2012), London Data Store http://data.london.gov.uk/datastore/package/access-public-open-space-and-nature-ward ; 5Survey showing number of people participating in sport in local communities, taken from Active People Survey (2013), Sport England www.sportengland.org/research/active_people_survey.aspx 6 Use of small public urban green spaces and health benefits, Peschardt, K. K., Schipperijn, J., & Stigsdotter, U. K. (2012) Use of small public urban green spaces (SPUGS). *Urban Forestry & Urban Greening*, 11 (3), 235-244 7 Physical Activity and the Environment, taken from "Marmot Review (2010) Fair Society, Healthy Lives"; NICE (2008). Physical activity and the environment., PH Guidance 8 12GLA All London Green Grid Supplementary Planning Guidance ,(2012) taken from, www.london.gov.uk/priorities/planning/publications/all-london-green-grid-spg; Datasets to support this guidance, taken fromwww.gigl.org.uk/Ourdatasets/Openspace/tabid/117/Default.aspx; 13 Green flag award system for green spaces, taken from Keep Britain Tidy, http://greenflag.keepbritaintidy.org/ 14 Southwark Council outdoor gym, taken from www.southwark.gov.uk/info/200435/free_outdoor_activities/2611/outdoor_gyms/1 15 Burgess Park regeneration project July 2012, taken from www.southwark.gov.uk/news/article/792/burgess_park_to_reopen_after_8_million_transformation) 16 London Travel Demand Survey (LTDS),2011,taken from Transport for London, Travel in London, Supplementary Report: ,www.tfl.gov.uk 17 Evidence demonstrating link between transport and health, March 2013, Keeping well in hard times: Protecting and improving health & well-being in an income shortfall: taken from, London Health Inequalities Network. 18 Link between heavily trafficked streets and health impacts, 2005, taken from Health Development Agency Making the case: Improving health through transport. 19 Data showing physical activity rates in London, 2010, taken from Public Health England: Physical Activity in London: Key Facts. www.lho.org.uk/LHO_Topics/Health_Topics/Lifestyle_and_Behaviour/PhysicalActivity.aspx 20 Link between active travel and health, 2012, taken from British Medical Association, Healthy Transport= Healthy Lives, BMA,www.bma.org.uk 21 Analysis of cycling potential, 2010, taken from Transport for London, December Analysis of Cycling Potential, Travel in London, www.tfl.org.uk 22 Report showing negative impacts of transport in London, 2011, taken from Mackett, R.L. & Brown, R. ; Transport, Physical Activity and Health. Present knowledge and the way around. Centre for Transport Studies, University College London, www.cege.ucl.ac.uk 23 Number of travel trip by each modal share, 2011, taken from London Travel Demand Survey. Transport for London, www.tfl.org.uk 24 Reported road casualties in Great Britain, annual report 2011, taken from www.gov.uk 25 Most heavily vehicular used roads, 2000-2012, taken from Traffic Statistics, Department of Transport 26 The Mayor's proposed cycle superhighways for London, 2013, taken from Mayor's Vision for Cycling, GLA, www.tfl.gov.uk 27 Hackney's case study showing cycling promoting measures, 2013, taken from London Borough of Hackney Sample of Schemes for cycling & public realm. www.hackney.gov.uk ( 28 Surface Water Management Plan (SWMP), 2010, taken from, Technical Guidance. DEFRA www.defra.gov.uk 29 London Regional Flood Risk Appraisal, October 2009, taken from GLA, ; , www.london.gov.uk 30 Overall strategic plan for London, the London Plan, 2011, taken from GLA, www.london.gov.uk 31 Secondary impact of floods on health, 2013, World Health Organisation ; Floods in the WHO European Union, Health effects and their prevention. Edited by Bettina Menne and Virginia Murray, taken from Public Health England's website, www.gov.uk/government/organisations/public-health-england 32 Effects of floods on mental health, 2011, taken from Murray, V, Caldin et al (2011); The Effects of Floods on Mental Health, Health Protection Agency,www.hpa.org.uk 33 www.phoutcomes.info 34 https://www.gov.uk/green-deal-energy-saving-measures/how-the-green-deal-works 35Access to healthy food, taken from, White (2007), Food Access and Obesity, *Obesity reviews*, 8 (s1), 99- 107. ; Chartered Institute for Environment and Health, 2013, taken from Chartered Institute for Environment and Health Food Policy: http://cieh.org/. 36 Takeaways Toolkit, 2012, taken from, London Food Board and Chartered Institute of Environmental Health http://www.london.gov.uk/priorities/environment/promoting-healthy-sustainable-food/londonboroughs/takeaways-toolkit; 37 Effect of fast food restaurants on obesity and weight gain, taken from, Currie, J., Vigna, SD et al (2010), The effect of fast food restaurants on obesity and weight gain. American Economic Journal: Economic Policy, 32-63. 42 New Fuel Poverty Definition 2013, taken from Department of Energy and Climate Change (DECC), taken from Fuel Poverty, A Framework for future action. www.decc.gov.uk 43Tackling fuel poverty in London 2012, taken from GLA - London Assembly In from the cold? www.london.gov.uk 44 Fuel poverty impact on wellbeing, 2011, taken from, Marmot Review Team, The Health Impacts of Cold Homes and Fuel Poverty, www.gov.uk/government/organisations/public-health-england 45 Cost of fuel poverty to the NHS, 2012, taken from AgeUK, The Cost of Cold www.ageuk.org.uk/latestnews/archive/cold-homes-cost-nhs-1-point-36-billion 52 Heatwave Plan 2013, taken from Public Health England, Making the case: the impact of heat on health - now and in the future www.gov.uk/government/organisations/public-health-england 53 Potential costs of overheating including data, 2013, taken from Department for Environment, Food and Rural Affairs, The Economics of Climate Resilience: Health and Well-being Theme CA0401 www.defra.gov.uk 54 Overheating and health, 2011, taken from Health Protection Agency, Overheating and health: a review into the physiological response to heat and identification of indoor heat thresholds www.hpa.org.uk/webc/HPAwebFile/HPAweb_C/1317133912939 55Association of mortality with high temperatures in a temperate climate: England and Wales, Armstrong et al. (2010) Association of mortality with high temperatures in a temperate climate: England and Wales, Journal of Epidemiology and Health, vol.65:4, 340-345 56 Heatwave Plan 2013, taken from Public Health England, Making the case: the impact of heat on health - now and in the future www.gov.uk/government/organisations/public-health-england 57 Heatwave Plan 2013, taken from Public Health England, Making the case: the impact of heat on health - now and in the future www.gov.uk/government/organisations/public-health-england ## Further Reading  Local Authorities' strategies (e.g. Planning, Transport) are monitored on an annual basis and PHOF indicators may be relevant additions to these strategies and a way of spreading a public health approach across the Council: www.phoutcomes.info provides useful borough summaries for this approach.  The Index of Multiple Deprivation (IMD) highlights the impact of wider environmental determinants most adversely on those in more deprived areas: www.gov.uk/government/organisations/department-for-communities-and-localgovernment/series/english-indices-of-deprivation  Public Health has an important role in reminding other departments about health inequalities and intra borough inequalities. Basic summaries can be found at: www.apho.org.uk/?QN=P_HEALTH_PROFILES  The local authority planning process offers the opportunity to mainstream some of these issues through planning guidance. The Town & Country Planning Association offers a useful guide: www.tcpa.org.uk/data/files/TCPA_FINAL_Reuniting-health-planning.pdf  The NHS London Healthy Urban Development Unit www.healthyurbandevelopment.nhs.uk and their Watch Out for Health Checklist and the Health Impact Assessment Gateway http://www.apho.org.uk/default.aspx?QN=P_HIA offers useful insight across many fields including regeneration, social infrastructure planning, housing, policy development, planning advocacy and negotiations, planning obligations, development management, master planning, environmental and health impact assessment.  Some themes in this Guide, for example, (food, fuel poverty, active travel) are addressed in Keeping Well in Hard Times hwww.lho.org.uk/Download/Public/17975/1/Keeping per cent20well per cent20in per cent20hard per cent20times.pdf  There is a useful guide for developers on maximising environmental benefits at: www.environment-agency.gov.uk/research/planning/147852.aspx  Effect of exposure to natural environment on health inequalities: an observational population study http://eprints.gla.ac.uk/4767/1/4767.pdf  Great Outdoors: How Our Natural Health Service Uses Green Space To Improve Wellbeing www.fph.org.uk/uploads/bs_great_outdoors.pdf ## Public Health Outcomes Framework Mapping Environmental Determinants To The 2013-2016 Public Health Outcomes Framework | Primary | Improvements or worsening will have a direct impact on the indicator | | |-------------|-------------------------------------------------------------------------|-----| | Secondary | Improvements or worsening may have an impact on this indicator | | | | AQ - Air Quality | AT - Active Travel and Transport | GS - Access to Green Space | |-----------------------|-------------------------|--------------------------------------|------------------------------------| | FR - Surface Flooding | | OH - Overheating | FP - Fuel Poverty | | HF - Healthy Food | | | | | AQ AT | GS | FR | OH HF | FP | Domain 1 | |--------------------------------------------------------|-------|-------|----------|-------|--------------| | Improving the wider determinants of health | | | | | | | | | | | | | | 1.1 Children in poverty | | | | | | | 1.2 School readiness | | | | | | | 1.3 Pupil absence | | | | | | | 1.4 First time entrants to the youth justice system | | | | | | | | | | | | | | training | | | | | | | | | | | | | | secondary mental health services who live in stable | | | | | | | and appropriate accommodation | | | | | | | | | | | | | | significant mental illness | | | | | | | | | | | | | | conditions including adults with a learning disability | | | | | | | or who are in contact with secondary mental health | | | | | | | services | | | | | | | 1.9 Sickness absence rate | | | | | | | | | | | | | | England's roads | | | | | | | 1.11 Domestic abuse | | | | | | | 1.12 Violent crime (including sexual violence) | | | | | | | 1.13 Re-offending levels | | | | | | | | | | | | | | noise | | | | | | | 1.15 Statutory homelessness | | | | | | | | | | | | | | reasons | | | | | | | 1.17 Fuel poverty | | | | | | | 1.18 Social isolation | | | | | | | 1.19 Older people's perception of community safety | | | | | | | Primary | Improvements or worsening will have a direct impact on the indicator | | |-------------|-------------------------------------------------------------------------|-----| | Secondary | Improvements or worsening may have an impact on this indicator | | | | AQ - Air Quality | AT - Active Travel and Transport | GS - Access to Green Space | |-------------------------------------------------------|-------------------------|-------------------------------------|------------------------------------| | FR - Surface Flooding | | OH - Overheating | FP - Fuel Poverty | | HF - Healthy Food | | | | | | | | | | Domain 2 | | | | | Health Improvement | | | | | | | | | | | | | | | 2.1 Low birth weight of term babies | | | | | 2.2 Breastfeeding | | | | | 2.3 Smoking status at time of delivery | | | | | 2.4 Under 18 conceptions | | | | | 2.5 Child development at 2-21/2 years | | | | | 2.6 Excess weight in 4-5 and 10-11 year olds | | | | | 2.7 Hospital admissions caused by unintentional and | | | | | deliberate injuries in under 18s | | | | | 2.8 Emotional well-being of looked after children | | | | | 2.9 Smoking prevalence - 15 year olds | | | | | 2.10 Self-harm | | | | | 2.11 Diet | | | | | 2.12 Excess weight in adults | | | | | 2.13 Proportion of physically active and inactive | | | | | adults | | | | | 2.14 Smoking prevalence - adults (over 18s) | | | | | 2.15 Successful completion of drug treatment | | | | | 2.16 People entering prison with substance | | | | | dependence issues who are previously not known to | | | | | community treatment | | | | | 2.17 Recorded diabetes | | | | | 2.18 Alcohol-related admissions to hospital | | | | | 2.19 Cancer diagnosed at stage 1 and 2 | | | | | 2.20 Cancer screening coverage | | | | | 2.21 Access to non-cancer screening programmes | | | | | 2.22 Take up of the NHS Health Check programme - | | | | | by those eligible | | | | | 2.23 Self-reported well-being | | | | | 2.24 Injuries due to falls in people aged 65 and over | | | | | | | | | | | | AQ AT | GS | FR | OH HF | FP | |----|----|----------|-------|-------|----------|-------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Primary | Improvements or worsening will have a direct impact on the indicator | | |-------------|-------------------------------------------------------------------------|-----| | Secondary | Improvements or worsening may have an impact on this indicator | | | AQ - Air Quality | AT - Active Travel and Transport | GS - Access to Green Space | |-----------------------------------------------------------|-------------------------------------|------------------------------------| | OH - Overheating | FP - Fuel Poverty | FR - Surface | | Flooding | | | | HF - Healthy Food | | | | | | | | Domain 3 | | | | Health Protection | | | | | | | | 3.1 Fraction of mortality attributable to particulate air | | | | pollution | | | | 3.2 Chlamydia diagnoses (15-24 year olds) | | | | 3.3 Population vaccination coverage | | | | 3.4 People presenting with HIV at a late stage of | | | | infection | | | | 3.5 Treatment completion for Tuberculosis (TB) | | | | 3.6 Public sector organisations with a board approved | | | | sustainable development management plan | | | | 3.7 Comprehensive, agreed inter-agency plans for | | | | responding to public health incidents and emergencies | | | | | | | | Domain 4 | | | | Healthcare public health and preventing | | | | premature mortality | | | | | | | | 4.1 Infant mortality | | | | 4.2 Tooth decay in children aged 5 | | | | 4.3 Mortality rate from causes considered preventable | | | | 4.4 Under 75 mortality rate from all cardiovascular | | | | diseases (including heart disease and stroke) | | | | 4.5 Under 75 mortality rate from cancer | | | | 4.6 Under 75 mortality rate from liver disease | | | | 4.7 Under 75 mortality rate from respiratory diseases | | | | 4.8 Mortality rate from infectious and parasitic | | | | diseases | | | | 4.9 Excess under 75 mortality rate in adults with | | | | serious mental illness | | | | 4.10 Suicide rate | | | | 4.11 Emergency readmissions within 30 days of | | | | discharge from hospital | | | | 4.12 Preventable sight loss | | | | 4.13 Health-related quality of life for older people | | | | 4.14 Hip fractures in people aged 65 and over | | | | 4.15 Excess winter deaths | | | | 4.16 Estimated diagnosis rate for people with | | | | dementia | | | | | | | | AQ | AT | GS | FR | OH | HF | FP | |-------|-------|-------|-------|-------|-------|-------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | AQ | Tr | GS | FR | OH | HF | FP | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Participation in Physical Green Space Access Deficiency (% value Activity % per week - Adult Obesity Prevalence Adult Obesity per Ward) Obesity - Borough Green Space Surface Total Ward N. Ward with Access Deficiency % Households 1 time a week 5 times per week LA London England Barking & Dagenham 33.6 17.0 4.0 over 50% 45.1 15.4 28.7 Barnet 41.3 21.0 4.0 over 40% 54.9 17.6 17.9 Bexley 31.7 21.0 4.0 over 40% 60.8 20.0 26.4 Brent 21.9 21.0 4.0 over 40% 49.4 16.3 21.2 Bromley 57.8 22.0 2.0 over 50% 62.4 21.1 21.8 Camden 24.8 18.0 5.0 over 50% 65.1 26.0 15.5 City of London 4.8 0.0 0.0 1.0 52.8 28.7 City of Westminster 21.5 20.0 4.0 over 50% 59.3 25.4 15.0 20.7 24.2 Croydon 37.1 24.0 7.0 over 50% 58.9 19.8 24.3 Ealing 30.9 23.0 6.0 over 50% 48.2 14.6 18.1 Enfield 45.6 21.0 8.0 over 50% 50.7 18.6 23.2 Greenwich 34.4 17.0 1.0 over 40% 55.4 19.5 22.6 Hackney 23.2 19.0 5.0 over 40% 58.9 24.0 22.6 Hammersmith & Fulham 19.1 16.0 5.0 over 50% 66.4 27.6 15.6 Haringey 25.5 19.0 6.0 over 40% 54.9 17.7 20.1 Harrow 34.6 21.0 8.0 over 50% 51.7 17.1 19.2 Havering 59.3 18.0 7.0 over 50% 52.5 16.4 27.3 Participation in Physical Green Space Access Deficiency (% value Activity % per week - Adult Obesity Prevalence Adult Obesity per Ward) Obesity - Borough Green Space Surface Total Ward N. Ward with Access Deficiency % Households 1 time a week 5 times per week LA London England Hillingdon 49.2 22.0 2.0 over 50% 48.9 14.1 23.2 Hounslow 39.6 20.0 5.0 over 40% 52.4 17.8 20.5 Islington 12.4 16.0 4.0 over 50% 61.3 22.4 18.0 Kensington & Chelsea 15.1 18.0 1.0 over 50% 63.5 21.5 13.9 Kingston upon Thames 36.4 16.0 5.0 over 50% 61.2 23.1 16.7 Lambeth 17.3 21.0 7.0 over 50% 62.0 30.2 20.7 20.7 24.2 Lewisham 22.5 18.0 3.0 over 40% 56.4 21.3 23.7 20.7 24.2 Merton 34.6 20.0 3.0 over 40% 55.0 17.5 19.1 20.7 24.2 Newham 23.9 20.0 9.0 over 50% 45.7 17.3 25.3 20.7 24.2 Redbridge 40.6 21.0 5.0 over 40% 54.5 19.4 22.3 20.7 24.2 Richmond upon Thames 50.8 18.0 1.0 over 50% 69.3 27.4 14.9 20.7 24.2 Southwark 24.9 20.0 7.0 over 50% 59.5 19.5 22.5 20.7 24.2 Sutton & Merton 32.0 18.0 4.0 over 50% 64.2 19.7 21.6 20.7 24.2 Tower Hamlets 15.2 17.0 5.0 over 50% 55.9 19.7 19.4 20.7 24.2 Waltham Forest 31.4 20.0 8.0 over 40% 56.2 20.3 23.4 20.7 24.2 Wandsworth 26.9 20.0 2.0 over 50% 66.4 26.9 15.0 20.7 24.2 ## Active Travel And Transport Data | | Number of | Annual Casualties on | |----------------------|-------------------------------------------------|-------------------------| | | 'Travels per | the Road, 2005- | | day' (000's) | 2009 average | | | Barking & Dagenham | | | | 280 | 604 | 1 | | Barnet | | | | 769 | 1,344 | 3 | | Bexley | | | | 357 | 644 | -12 | | Brent | | | | 592 | 918 | -2 | | Bromley | | | | 691 | 929 | -6 | | Camden | | | | 744 | 902 | 3 | | City of London | | | | 262 | 369 | 11 | | Croydon | | | | 720 | 1,208 | 2 | | Ealing | | | | 633 | 1,155 | -15 | | Enfield | | | | 594 | 1,033 | 7 | | Greenwich | | | | 428 | 919 | 1 | | Hackney | | | | 404 | 948 | -8 | | Hammersmith & Fulham | 494 | 745 | | Haringey | | | | 483 | 830 | 10 | | Harrow | | | | 422 | 534 | -21 | | Havering | | | | 477 | 903 | -10 | | Hillingdon | | | | 563 | 1,028 | -8 | | Hounslow | | | | 488 | 959 | 4 | | Islington | | | | 486 | 742 | 33 | | Kensington & Chelsea | | | | 472 | 818 | -2 | | Kingston upon Thames | | | | 378 | 430 | 3 | | Lambeth | | | | 614 | 1,234 | 6 | | Lewisham | | | | 476 | 968 | 10 | | Merton | | | | 431 | 522 | -2 | | Newham | | | | 590 | 1,014 | -10 | | Redbridge | | | | 524 | 866 | 9 | | Richmond upon Thames | | | | 447 | 486 | 7 | | Southwark | | | | 582 | 1,137 | 0 | | Sutton | | | | 393 | 576 | -7 | | Tower Hamlets | | | | 561 | 977 | -3 | | Waltham Forest | | | | 387 | 865 | -6 | | Wandsworth | | | | 621 | 925 | 14 | | Westminster | | | | 1168 | 1,695 | -3 | | Average | | | | 531 | 886 | | | Source | | | | London Travel | | | | Demand Survey | Reported Road Casualties, Great Britain, gov.uk | | % Change 2005-2009 to Average Fatalities Number of 2011 2005-2009 Vehicles 6 95634 ## Air Quality Data Fraction (%) of mortality attributable to long term exposure to PM2.5 Rank Barking & Dagenham 7.1 14 27% 3 Barnet 6.8 10 21% 15 Bexley 6.6 7 18% 1 Brent 7.2 17 29% 6 Bromley 6.3 1 13% 1 Camden 7.7 24 38% 5 City of London 9 33 61% 2 Croydon 6.5 5 16% 5 Ealing 7.2 17 29% 5 Enfield 6.6 7 18% 10 Greenwich 7.2 17 29% 7 Hackney 7.8 26 39% 8 Hammersmith and Fulham 7.9 27 41% 5 Haringey 7.1 14 27% 9 Harrow 6.4 3 14% 5 Havering 6.3 1 13% 3 Hillingdon 6.5 5 16% 8 Hounslow 7.1 14 27% 10 Islington 7.9 27 41% 3 Kensington and Chelsea 8.3 31 48% 3 Kingston upon Thames 6.7 9 20% 2 Lambeth 7.7 24 38% 9 Lewisham 7.2 17 29% 9 Merton 6.9 12 23% 4 Newham 7.6 23 36% 6 Redbridge 7 13 25% 4 Richmond upon Thames 6.8 10 21% 4 Southwark 7.9 27 41% 7 Sutton 6.4 3 14% 3 Tower Hamlets 8.1 30 45% 6 Waltham Forest 7.3 21 30% 7 Wandsworth 7.3 21 30% 4 Westminster 8.3 31 48% 8 Source: % different from UK average Number of Air Quality Focus Areas ## Table 4 Healthy Food Data Childhood Adult Participation in Physical Obesity % Consumption of 5 portions of fruits and Obesity Activity % per week Prevalence (6yrs vegetables a day Prevalence old) LA Once a week 5 times per week LA Total MSOA N. Areas (MSOA) with highest % of consumption % Intervals Barking & Dagenham 28.7 45.1 15.4 22 8 (25.40 - 31.20) Barnet 17.9 54.9 17.6 41 16 (43.90 - 56-10) Bexley 26.4 60.8 20 28 10 (31.20 - 37.20) Brent 21.2 49.4 16.3 34 13 (38.20 - 45.30) Bromley 21.8 62.4 21.1 39 15 (27.20 - 45.30) Camden 15.5 65.1 26 28 10 (44.60 - 55.10) City of London 52.8 28.7 48 City of Westminster 15 59.3 25.4 24 10 (48.60 - 52.10) Croydon 24.3 58.9 19.8 44 17 (35.50 - 48.8) Ealing 18.1 48.2 14.6 39 15 (41.10 - 55.40) Enfield 23.2 50.7 18.6 36 14 (33.90 - 41.90) Greenwich 22.6 55.4 19.5 32 12 (32.70 - 42.20) Hackney 22.6 58.9 24 27 10 (34.90 - 41.60) Hammersmith & Fulham 15.6 66.4 27.6 25 10 (41.70 - 48.20) Haringey 20.1 54.9 17.7 36 14 (39.20 - 48.00) Harrow 19.2 51.7 17.1 31 12 (39.70 - 47.60) Havering 27.3 52.5 16.4 30 12 (30.80 - 37.30) Hillingdon 23.2 48.9 14.1 32 12 (34.20 - 45.40) Hounslow 20.5 52.4 17.8 28 10 (36.90 - 47.20) Islington 18 61.3 22.4 23 7 (27.60 - 40.80) Kensington & Chelsea 13.9 63.5 21.5 21 8 (50.70 - 54.30) Kingston upon Thames 16.7 61.2 23.1 20 8 (41.90 - 49.40) Lambeth 20.7 62 30.2 35 13 (36.00 - 42.90) Lewisham 23.7 56.4 21.3 36 14 (36.00 - 42.90) Merton 19.1 55 17.5 25 10 (41.40 - 55.40) Newham 25.3 45.7 17.3 37 13 (32.60 - 36.60) Redbridge 22.3 54.5 19.4 33 12 (35.50 - 43.30) Richmond upon Thames 14.9 69.3 27.4 23 8 (44.70 - 48.30) Southwark 22.5 59.5 19.5 33 11 (37.50% - 43.30) Sutton 21.6 64.2 19.7 24 9 (35.20 - 44.30) Tower Hamlets 19.4 55.9 19.7 31 12 ( 29.70 - 42.90) Waltham Forest 23.4 56.2 20.3 28 10 (33.70 - 37.40) Wandsworth 15 66.4 26.9 37 15 (42.30 - 46.80) Average 20.6 57.0 20.7 30.7 11.6 48.0 London 20.7 22.53 England 24.2 19.2 Source Health Needs Assessment Toolkit National Obesity Observatory (2010-2011) Health Needs Assessment Toolkit ## Table 5 Fuel Poverty Data Excess winter deaths 2010/11 Population Aged 65 Households in privatelyrented 2011 Percentage in privately-rented 2011 2012 2025 2040 Barking and Dagenham 60 19,700 24,700 35,900 17,000 22.9 Barnet 90 49,400 65,600 88,100 28,000 20.5 Bexley 90 38,500 45,100 56,300 10,000 10.9 Brent 40 33,800 46,300 61,100 26,000 29.2 Bromley 190 54,200 64,200 79,500 17,000 12.6 Camden 70 24,800 30,200 39,300 29,000 26.8 City of London 10 1,100 1,700 2,800 1,000 8.6 Croydon 70 46,200 61,200 84,100 19,000 13.9 Ealing 90 37,500 49,000 65,300 29,000 24.3 Enfield 150 40,000 49,900 64,300 27,000 22.7 Greenwich 70 27,300 38,200 54,100 18,000 19.7 Hackney 30 17,900 23,900 34,500 21,000 22.8 Hammersmith and Fulham 40 16,900 20,200 26,100 21,000 26.4 Haringey 60 23,000 29,000 38,600 20,000 23.3 Harrow 60 34,800 43,700 50,000 18,000 22.2 Havering 130 44,000 53,800 64,600 10,000 9.4 Hillingdon 120 36,400 44,300 56,100 21,000 19.8 Hounslow 110 27,800 35,500 45,900 25,000 27.9 Islington 30 18,400 22,500 31,000 22,000 24.2 Kensington and Chelsea 50 20,100 26,600 33,500 18,000 23.0 Kingston upon Thames 70 21,100 26,600 34,100 16,000 22.6 Lambeth 60 23,700 31,200 45,600 29,000 23.2 Lewisham 90 26,600 32,100 44,800 25,000 21.7 Merton 60 23,800 29,800 39,800 19,000 24.4 Newham 70 21,300 30,900 44,300 29,000 35.4 Redbridge 80 34,300 41,200 51,400 25,000 25.8 Richmond upon Thames 40 26,500 33,100 42,000 17,000 21.5 Southwark 90 22,900 30,200 43,500 29,000 22.4 Sutton 60 28,600 34,500 44,100 14,000 16.9 Tower Hamlets 40 15,800 20,600 31,200 32,000 33.9 Waltham Forest 110 26,500 34,600 48,100 24,000 26.6 Wandsworth 150 27,700 33,000 43,600 41,000 34.6 Westminster 20 25,200 30,400 39,400 44,000 35.9 75.8 28357.6 35872.7 47363.6 22454.5 22.9 Source: ## Acknowledgements Project Team-Responsible for project management, project delivery and writing the guides: Annette Figueiredo- Principal Policy & Programme Officer, Resilience and Quality of Life Team-GLA; Jason Strelitz, Public Health Specialist, GLA Alena Ivanova; Elena Guidorzi; Joe Parsons- MA/MSc postgraduate students-University of London, Kings College, GLA work placements Dr Angie Bone-Consultant in Public Health Medicine, Extreme Events and Health Protection, Public Health England The Project Team would like to thank everyone who has been involved in the project and contributed to the production of the guides. Particular thanks go to: GLA Staff Helen Walters, Head of Health Alex Nickson, Policy & Programmes Manager, Resilience and Quality of Life Team Peter Massini, Principal Policy & Programme Officer, Resilience and Quality of Life Team Lucy Saunders, Public Health Specialist, Health Team Jonathan Pauling, Principal Policy Officer, Food, Economic & Business Policy Team Mark Ainsbury, Senior Policy Officer, Food, Economic & Business Policy Team Elliot Treharne, Principal Policy & Programme Officer, Resilience and Quality of Life Team Liz Prosser, Senior Project Officer, Healthy Schools London, Health Team Kat McKinlay, Policy Officer, Transport Team Gareth Baker, GIS Officer, GIS and Infrastructure Team Michael Jeffreys. GIS Officer, GIS and Infrastructure Team Alison Murray, Programme Officer, Regeneration Team Emma Williamson, Principal Strategic Planner, Planning Team Susan Pape, Internal Communications Officer, HR & Organisational Development, Communications Team Una Buckley, Employee Engagement Manager, HR & Organisational Development Charlotte Hall, Health Inequalities Programme Leader, Health Team Larissa Bulla, Principal Policy & Programme Officer, Energy & Waste Team Kevin Reid, Principal Policy & Programme Officer, Resilience and Quality of Life Team Rebecca Roper, Childhood Obesity and Health Team Support Officer, Health Team GLA Design Team Other Colleagues Alex Trouton, Policy and Information Officer, Lambeth and Southwark Public Health Department Jonathan Hiderbrand, Director of Public Health, London Borough of Kingston Caroline Hancock, Senior Public Health Analyst - Public Health England Thomas Abeling, PhD Researcher, UNITED NATIONS UNIVERSITY, Institute for Environment and Human Security (UNU,EHS) Paul James, Director of the United Nations Global Compact, Cities Programme John Kolm-Murray, Seasonal Health Officer, Islington Council Fiona Daly - Environmental Manager, Barts Health NHS Trust Gordon Deuchars, Policy and Campaigns Manager, Age UK London Dr Anna Mavrogianni, Lecturer in Environmental Design and Engineering, UCL Jonathon Taylor, Research Associate, UCL Professor Virginia Murray, Head of Extreme Events and Health Protection, PHE Professor Sue Grimmond - Department of Meteorology, University of Reading Other formats and languages For a large print, Braille, disc, sign language video or audio-tape version of this document, please contact us at the address below: Public Liaison Unit Greater London Authority Telephone **020 7983 4100** City Hall Minicom **020 7983 4458** The Queen's Walk www.london.gov.uk More London London SE1 2AA You will need to supply your name, your postal address and state the format and title of the publication you require. If you would like a summary of this document in your language, please phone the number or contact us at the address above. | Chinese | Hindi | |------------|----------| | | | | | | | Vietnamese | Bengali | | | | | | | | Greek | Urdu | | | | | | | | Turkish | Arabic | | | | | | | | Punjabi | Gujarati | | | | | | | | | |
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## Annex Approvals Committee - October/November 2010 1. Since the last Board meeting, our approvals committee has considered one urgent application by correspondence on 15 October and has met twice to consider applications requiring approval of consultancy contracts over £20,000 and all external recruitment. 2. The cases considered are listed below: | Committee | Meeting date | Ref: No. & | |------------------------|-----------------|----------------------| | directorate | | | | Summary of | | | | application | | | | Consultancy/ | | | | recruit | | | | Decision | | | | Recruitment | | | | Additional | | | | operations | | | | advice | | | | 25 October 2010 | 50 | | | Approved | | | | | | | | (fees for services, 10 | | | | days' work) | | | | | | | | 25 October 2010 | 51 | | | Consultancy | Approved | | | Appointment of | | | | specialist | | | | recruitment | | | | consultants for | | | | new chief | | | | executive | | | | £82,250 | | | | 25 October 2010 | 52 | | | Consultancy | Not approved | | | Passenger | | | | priorities for | | | | data - | | | | qualitative | | | | research | | | | £35,000 | | | | 1 November 2010 | 54 | External recruitment | | Recruitment of | | | | two temporary | | | | economists | | | | 1 November 2010 | 56 | External recruitment | | External | | | | recruitment of | | | | chief executive | | | ## Urgent Item By Correspondence | 15 October 2010 | 48 | |--------------------|----------| | Consultancy | Approved | | Cost and | | | revenue sharing | | | between | | | Network Rail | | | and train | | | operators | | Further details of any of the above applications and decisions are available from Brian Warrener 3. The committee were also provided with details of any applications below £20,000 which are subject to approval by corporate services. There have been 5 applications approved totalling £ 30,700.
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## Target. Public Bodies employing more than 250 people are required to have regard to the target of 2.3% of employees being new starting apprentices. 2018 is the first year Public Bodies have been required to publish this data. The reporting period ran from 1st April 2017 to 31st March 2018. | Information | Figures | |------------------------------------------------------------------|--------------------------------------------------------------| | 4895 | Number of employees who were working for the organisation in | | England on 31 March 2017 | | | 4215 | | | | | | Number of employees who were working for the organisation in | | | England on 31 March 2018 | | | | | | 483 | | | | | | Number of new employees who started working for the | | | organisation in England between 1 April 2017 and 31 March 2018 | | | | | | | | | Number of apprentices who were working for the organisation in | | | England on 31 March 2017 | | | 25 | | | Number of apprentices who were working for the organisation in | | | England on 31 March 2018 | | | 27 | | | Number of new apprentices in England whose apprenticeship | | | agreements started between 1 April 2017 and March 2018 | | | 23 | | | | | | 4.76% | | | Percentage of apprenticeship starts (both new hires and existing | | | employees who started an apprenticeship) as a proportion of | | | employment starts between 1 April 2017 and 31 March 2018 | | | Percentage of total headcount that were apprentices on 31 March | | | 2018 | | | 0.64% | | | 0.47% | | | Percentage of apprenticeship starts (both new hires and existing | | | employees who started an apprenticeship) between 1 April 2017 | | | and 31 March 2018 as a proportion of total headcount on 31 March | | | 2017 | | | | |
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## Hm Revenue & Customs Business Expenses: 1 July - 30 September 2011 Please note - these figures may not include some costs that have yet to be invoiced and will be updated to reflect any additional spend. ## Dame Lesley Strathie Dcb - Chief Executive And Permanent Secretary | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | | | | | | | NIL RETURN | | | | | | | | | | | | | | | | | ## Dave Hartnett - Permanent Secretary For Tax | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|--------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 01/07/11 | London | Conference | | | | 04/07/11 | France | Inter- | | | | Governmental | | | | | | Meeting | | | | | | £374.41 | | £58.71 | £36.24 | | | 06/07/11 | Hull | Office Visit | | £53.98 | | 13/07/11 | York | Office Visit | | £66.00 | | 24/08/11 | | | | | | Switzerland | Inter- | | | | | Governmental | | | | | | Meeting | | | | | | £439.65 | £68.14 | £31.00 | £116.78 | Personal Expenses | | - £10 | | | | | | £665.57 | | | | | | - | | | | | | 25/08/11 | | | | | | 05/09/11 | Cambridge | Speaking | | | | Engagement | | | | | | | £30.50 | £27.40 | | | | 08/09/11 | London | Speaking | | | | Engagement | | | | | | | | £11.00 | | | | 13/09/11 | London | Speaking | | | | Engagement | | | | | | | | £17.00 | | | | 14/09/11 | Liechtenstein | Inter- | | | | Governmental | | | | | | Meeting | | | | | | £231.01 | | | | | | 15/09/11 | London | Speaking | | | | Engagement | | | | | | | | £39.00 | | | | 26/09/11 | Lincoln | Speaking | | | | Engagement | | | | | | | £43.36 | £74.00 | | | | | | | | | ## Stephen Banyard - Acting Director General, Personal Tax | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|--------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 05/07/11 | | | | | | - | | | | | | 07/07/11 | | | | | | Dundee | Office Visit | £254.49 | £19.10 | £7.00 | | | | | | | | 15/07/11 | Leicester | Office Visit | | £76.50 | | 25/07/11 | Leicester | Office Visit | | £85.10 | | 03/08/11 | | | | | | - | | | | | | 04/08/11 | | | | | | Lincoln | Departmental | | | | | Business | | | | | | | £38.65 | | | | | 08/08/11 | | | | | | - | | | | | | 09/08/11 | | | | | | Liverpool | Office Visit | | £125.50 | £9.00 | | 29/09/11 | | | | | | - | | | | | | 30/09/11 | | | | | | Lincoln | Departmental | | | | | Business | | | | | | | £107.30 | | | | | | | | | | ## Steve Lamey - Director General, Benefits & Credits | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|--------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 05/07/11 | London | Staff Event | | | | 06/07/11 | London | Departmental | | | | Business | | | | | | | | £46.97 | | | | 06/07/11 | St Austell | Staff Event | £132.96 | | | 12/07/11 | Preston | Departmental | | | | Business | | | | | | | £133.92 | £16.00 | | | | 19/07/11 | | | | | | - | | | | | | Preston/ | Meeting | | £46.02 | £36.20 | | Netherton | | | | | | 20/07/11 | | | | | | 21/07/11 | Preston | Departmental | | | | Business | | | | | | | £73.22 | £5.20 | | | | 25/07/11 | Preston | Meeting | | £92.11 | | 28/07/11 | | | | | | - | | | | | | Belfast | Staff Event | £246.18 | | £87.00 | | 29/07/11 | | | | | | 01/08/11 | Preston | Meeting | | £87.96 | | 03/08/11 | Middlesbrough | Departmental | | | | Visit | | | | | | £126.39 | £62.42 | £35.00 | £8.95 | | | 10/08/11 | | | | | | Preston | Staff Event | | £75.26 | £20.00 | | - | | | | | | 11/08/11 | | | | | | 16/08/11 | | | | | | - | | | | | | 18/08/11 | | | | | | Preston | Departmental | | | | | Business | | | | | | | £116.96 | £42.50 | £100.30 | | | | | | | | 22/08/11 - 23/08/11 Preston Meeting £125.72 £20.50 £63.00 13/09/11 Preston Meeting £88.92 £27.40 21/09/11 Preston Meeting £67.61 £17.40 £3.50 28/09/11 - 29/09/11 Preston Staff Event £82.46 £68.70 £92.80 ## Melanie Dawes - Director General, Business Tax | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|--------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 05/07/11 | London | Meeting | | | | 11/07/11 | Oxford | Speaking | | | | Engagement | | | | | | | £22.46 | £40.00 | | | | 25/07/11 | Bournemouth | Office Visit | | £29.96 | | 04/08/11 | Harwich | Office Visit | | £31.50 | | 08/08/11 | Lincoln | Speaking | | | | Engagement | | | | | | | £25.61 | | | | | 09/08/11 | London | Departmental | | | | Business | | | | | | | | £7.00 | | | | 15/09/11 | Manchester | Office Visit | | £133.96 | | | | | | | ## Mike Eland - Director General, Enforcement And Compliance | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|-------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 08/07/11 | London | Meeting | | £3.80 | | 09/08/11 | London | Conference | | £3.80 | | 12/08/11 | Worthing | Staff Visit | | £18.60 | | 17/08/11 | | | | | | - | | | | | | Aberdeen | Staff Visit | £88.00 | | £47.20 | | 1808/11 | | | | | | 24/08/11 | Belfast | Staff Visit | £179.87 | | | 21/09/11 | London | Staff Visit | | £3.80 | | 29/09/11 | | | | | | Coventry | Staff Visit | | £71.00 | £3.40 | | - | | | | | | 30/09/11 | | | | | | | | | | | ## Simon Bowles - Chief Finance Officer | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|--------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 01/07/11 | Maidstone | Office Visit | | £40.75 | | 04/07/11 | Manchester | Staff Event | | £130.42 | | 06/07/11 | Nottingham | Staff Event | | £101.16 | | 07/07/11 | Worthing | Staff Event | | | | 07/07/11 | Brighton | Office Visit | | £25.12 | | 21/07/11 | Reading | Office Visit | | £8.70 | | 31/08/11 | Newcastle | Staff Event | £158.98 | | | 19/09/11 | Lincoln | Staff Event | | £31.15 | | 29/09/11 | London | Staff Event | | | | | | | | | ## Mike Falvey - Chief People Officer | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|--------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 01/07/11 | Lincoln | Staff Event | | £41.36 | | 22/07/11 | Lincoln | Staff Event | | £41.36 | | 29/07/11 | Stoke on Trent | Office Visit | | £56.61 | | 29/09/11 | Lincoln | Staff Event | | £140.96 | | - | | | | | | 30/09/11 | | | | | | | | | | | ## Anthony Inglese - General Counsel And Solicitor | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|--------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 12/07/11 | Peterborough | Office Visit | | £21.00 | | 14/07/11 | Ipswich | Office Visit | | £38.00 | | 19/07/11 | Ipswich | Office Visit | | £16.00 | | 28/07/11 | Norwich | Office Visit | | £16.00 | | 19/09/11 | Sunningdale | Speaking | | | | Engagement | | | | | | | £3.95 | | | | | | | | | | ## Phil Pavitt - Chief Information Officer | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-------------------|----------------|--------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 18/07/11 | Lincoln | Staff Event | | | | 20/07/11 | | | | | | - | | | | | | Cornwall | Office Visits | | | £302.18 | | 22/07/11 | | | | | | 26/07/11 London | External | | | | | Meeting | | | | | | | | £8.00 | | | | 09/08/11 | London | Departmental | | | | Business | | | | | | | | £26.00 | | | | 31/08/11 | | | | | | Newcastle | Departmental | | | | | Business | | | | | | £194.54 | £21.80 | | £151.03 | | | - | | | | | | 01/09/11 | | | | | | 30/09/11 Reading | External | | | | | Meeting | | | | | | | £41.10 | £10.00 | £4.25 | | | | | | | | ## Mike Clasper - Non Executive Chairman | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|--------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 30/07/11 | Oxford | Departmental | | | | Business | | | | | | | | £28.00 | | | | 01/08/11 | Hinckley | Meeting | | | | 09/08/11 | London | Meeting | | | | | | | | | ## John Spence - Non Executive Director * John Spence is registered blind therefore the expenses claimed are higher than that of other Non Executive Directors | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 12/07/11 | London | HMRC Board | | £15.40 | | 19/07/11 | London | Meeting | | £8.50 | | 27/07/11 | London | Meeting | | £9.85 | | 09/08/11 | London | Meeting | | £15.40 | | 23/08/11 | London | Meeting | | £9.85 | | 01/09/11 | London | Meeting | | £15.40 | | 12/09/11 | London | Meeting | | £15.40 | | 15/09/11 | London | Meeting | | £8.50 | | 20/09/11 | London | Meeting | | £15.40 | | 21/09/11 | London | Meeting | | £15.40 | | | | | | | ## Phil Hodkinson - Non Executive Director | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | 09/08/11 | London | Meeting | | £9.25 | | 01/09/11 | London | Meeting | | £21.25 | | | | | | | ## Colin Cobain - Non Executive Director | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (Including | |-----------------|----------------|------------|-----------|---------------------| | Hospitality | | | | | | Received/Given) | | | | | | Total | | | | | | Cost £ | | | | | | | | | | | | | | | Air | Rail | | Meals | | | | | | | | | | | | Other | | | | | | | | | | | | NIL RETURN | | | | | | | | | | | ## Philippa Hird - Non Executive Director * Philippa does not make individual claims for business costs. DATES DESTINATION PURPOSE TRAVEL OTHER (Including Hospitality Received/Given) Total Cost £ Air Rail Taxi/Car/ Accommodation/ Meals Other NIL RETURN
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mobile network operators. This file contains mobile network coverage and data usage information from the operators, aggregated at local authority level. The coverage data was collected as a snapshot in May 2015. The capacity data was collected over the month of June 2015. This data should be viewed alongside the Connected Nations Report 2015 and methodology document, which summarise our approach to the data analysis and details how each of the metrics are defined. Due to variations in mobile performance over time, the file should not be regarded as a definitive and fixed view of the UK's mobile infrastructure. However, the information provided in this file may
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| Organisation Name | Purchase_Order_Number | Order_Date Total_Value Supplier_Name | Account_Name | Service | |-----------------------------------|-------------------------|-------------------------------------------------------------|---------------------------------------|--------------------------------| | Rochdale Borough Council d1061609 | 03/10/2016 | £8,820.00 CLOVER SECURITY SERVICES LIMITED | TRAINING | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1061647 | 03/10/2016 | £12,000.00 PATROL | AGENCY | PROPERTY AND HIGHWAYS | | Rochdale Borough Council e1021898 | 03/10/2016 | £323,042.33 INSPIREDSPACES ROCHDALE PROJECT CO1 LTD | PFI SCHEMES RPIX | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1021905 | 03/10/2016 | £15,319.36 FAMILY ACTION | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004853 | 03/10/2016 | £105,000.00 TRAFFORD MBC | OTHER LOCAL AUTHORITIES | FINANCE SERVICES | | Rochdale Borough Council ph101507 | 03/10/2016 | £16,866.88 WOMENS HOUSING ACTION GROUP | PH OTHER CONTRACTS | PUBLIC HEALTH | | Rochdale Borough Council d1061669 | 04/10/2016 | £14,254.70 DOBSON UK LTD | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1061672 | 04/10/2016 | £12,445.00 S T HEDGES QUINN LTD | IMPROVEMENTS-MODERNISATION | ECONOMY DIRECTORATE | | Rochdale Borough Council e1021907 | 04/10/2016 | £411,893.26 INSPIREDSPACES ROCHDALE PROJECTCO2 LTD | PFI SCHEMES RPIX | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1021916 | 04/10/2016 | £9,332.50 PURE INNOVATIONS LIMITED | TRAVELLING GENERAL EXPENSES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1021917 | 04/10/2016 | £9,332.50 PURE INNOVATIONS LIMITED | TRAVELLING GENERAL EXPENSES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council ph101508 | 04/10/2016 | £90,750.00 PENNINE CARE NHS | PH PENNINE CARE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council ph101509 | 04/10/2016 | £355,417.00 PENNINE CARE NHS | PH PENNINE CARE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council ph101510 | 04/10/2016 | £124,574.58 BIG LIFE CENTRES | PH BIG LIFE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council q1007878 | 04/10/2016 | £25,948.00 RESTORE PLC | DATA COLLECTION | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1061693 | 05/10/2016 | £5,250.00 GC MINI BUS SERVICES | TAXI HIRE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1061699 | 05/10/2016 | £6,930.00 ROCHDALE BOROUGH SHOPMOBILITY | GRANTS TO THE VOLUNTARY SECTOR | ECONOMY DIRECTORATE | | Rochdale Borough Council f1004859 | 05/10/2016 | £8,000.00 SECURITY PLUS LIMITED | SECURITY | LEARNING DIS & MENTAL HEALTH | | Rochdale Borough Council ph101511 | 05/10/2016 | £27,392.00 PENNINE CARE NHS | PH PENNINE CARE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council ph101514 | 05/10/2016 | £78,383.70 VIRGIN CARE SERVICES LIMITED | VIRGIN CARE | PUBLIC HEALTH | | Rochdale Borough Council q1007885 | 05/10/2016 | £9,900.00 MANCHESTER CITY COUNCIL | AGENCY STAFF | FINANCE SERVICES | | Rochdale Borough Council x1013010 | 05/10/2016 | £9,930.00 ME LEARNING LIMITED | TRAINING | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council q1007892 | 06/10/2016 | £42,438.00 UPDATA INFRASTRUCTURE UK LTD | TELEPHONE EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1061743 | 07/10/2016 | £28,224.36 CROMWELL POLYTHENE LIMITED | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council ph101524 | 07/10/2016 | £11,977.49 POLICE AND CRIME COMMISSIONER FOR GTR MANCHESTER | CONTRACTED SERVICES | PUBLIC HEALTH | | Rochdale Borough Council q1007899 | 07/10/2016 | £43,310.71 XEROX UK LTD | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1061779 | 10/10/2016 | £6,000.00 ENTERPRISE MANCHESTER PARTNERSHIP LTD | CONTRACTED SERVICES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council f1004869 | 10/10/2016 | £41,163.99 OFFICE DEPOT UK LIMITED | PRINTING & STATIONERY | FINANCE SERVICES | | Rochdale Borough Council f1004870 | 10/10/2016 | £20,202.00 NEPRO LIMITED | AGENCY STAFF | FINANCE SERVICES | | Rochdale Borough Council s1020852 | 10/10/2016 | £28,008.08 THE STROKE ASSOCIATION | VOLUNTARY ASSOCIATIONS | BETTER CARE FUND POOLED BUDGET | | Rochdale Borough Council d1061836 | 11/10/2016 | £7,056.00 CLOVER SECURITY SERVICES LIMITED | TRAINING | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1021973 | 11/10/2016 | £7,138.40 ROC NORTHWEST LTD | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1021976 | 11/10/2016 | £14,588.00 ROSSENDALE SCHOOL PRIORY | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1021977 | 11/10/2016 | £10,104.34 BELMONT SCHOOL LIMITED | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1021978 | 11/10/2016 | £10,658.00 BELMONT SCHOOL LIMITED | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1021979 | 11/10/2016 | £11,197.30 WATERLOO LODGE SCHOOL | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1021988 | 11/10/2016 | £6,728.00 ROC NORTHWEST LTD | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1021989 | 11/10/2016 | £7,333.26 ROC NORTHWEST LTD | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004874 | 11/10/2016 | £6,069.70 CO-OP PAYPOINT | BANK CHARGES | FINANCE SERVICES | | Rochdale Borough Council s1020861 | 11/10/2016 | £13,089.01 MACK4 LIMITED | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1020862 | 11/10/2016 | £7,904.00 TERRY GROUP LTD | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1020863 | 11/10/2016 | £6,190.00 D W TAYLOR & SON | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council d1061881 | 12/10/2016 | £33,250.00 EMO OIL LIMITED | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1061888 | 12/10/2016 | £7,530.85 TYRE FORCE NW LTD | TYRES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1061889 | 12/10/2016 | £7,296.00 MIDDLETON CARS | TAXI HIRE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1021993 | 12/10/2016 | £12,000.00 OPEN OBJECTS SOFTWARE LTD | SOFTWARE | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004878 | 12/10/2016 | £28,451.00 SECURITY PLUS LIMITED | TRANSACTIONS-EXPENDITURE | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1007946 | 12/10/2016 | £9,422.84 BINDMONT PRINT SERVICES LTD | PRINTING & STATIONERY | FINANCE SERVICES | | Rochdale Borough Council q1007952 | 12/10/2016 | £7,821.00 PAUL SMITH CO PLMBG BLDG SER LTD | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council r1001552 | 12/10/2016 | £6,670.04 URBAN VISION PARTNERSHIP LTD | AGENCY STAFF | ECONOMY DIRECTORATE | | Rochdale Borough Council x1013041 | 12/10/2016 | £11,656.39 ROSS CARE | EQUIPMENT - GENERAL | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022000 | 13/10/2016 | £29,559.09 AXIOM EDUCATION (ROCHDALE) LIMITED | MEALS | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022011 | 13/10/2016 | £85,290.16 INSPIREDSPACES ROCHDALE LTD | NEW CONSTRUCTION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1007959 | 13/10/2016 | £9,524.00 HEMPSONS | PUBLIC TRANSPORT | FINANCE SERVICES | | Rochdale Borough Council d1061921 | 14/10/2016 | £12,921.49 F W SHERRATT LTD | ROADWORKS | PROPERTY AND HIGHWAYS | | Rochdale Borough Council d1061926 | 14/10/2016 | £6,776.28 ENTERPRISE FLEX-E-RENT | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022023 | 14/10/2016 | £711,687.70 AXIOM EDUCATION (ROCHDALE) LIMITED | PFI SCHEMES RPIX | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004882 | 14/10/2016 | £5,000.00 NORTHGATE PUBLIC SERVICES (UK) LTD | EXTERNAL CONTRACTED PRINTING | FINANCE SERVICES | | Rochdale Borough Council ph101541 | 14/10/2016 | £11,261.39 POLICE AND CRIME COMMISSIONER FOR GTR MANCHESTER | CONTRACTED SERVICES | PUBLIC HEALTH | | Rochdale Borough Council q1007972 | 14/10/2016 | £39,065.00 MANCHESTER CITY COUNCIL | AGMA | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1061947 | 17/10/2016 | £20,512.27 F W SHERRATT LTD | ENVIRONMENTAL WORKS LANDSCAPE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022037 | 17/10/2016 | £44,100.00 POSITIVE STEPS | EXTERNALLY MANAGED FUNDS | EARLY HELP AND SCHOOLS | | Rochdale Borough Council d1061968 | 18/10/2016 | £7,500.00 ROCHDALE MEMORIAL SERVICE | MATERIAL - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1007989 | 18/10/2016 | £36,393.83 Oracle Corporation UK Limited | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council x1013089 | 18/10/2016 | £27,000.00 BLACKBURN WITH DARWEN BC | ADOPTION PAYMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1062012 | 19/10/2016 | £8,000.00 STREAMLINE TAXIS | TAXI HIRE | NEIGHBOURHOODS AND ENVIRONMENT | | Organisation Name | Purchase_Order_Number | Order_Date Total_Value Supplier_Name | Account_Name | Service | |-----------------------------------|-------------------------|-------------------------------------------------------------------------------------------|---------------------------------------|--------------------------------| | Rochdale Borough Council d1062013 | 19/10/2016 | £14,238.00 SSI SCHAEFER LIMITED | PURCHASE OF OTHER EQUIPMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062014 | 19/10/2016 | £6,500.00 STREAMLINE TAXIS | TAXI HIRE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1007994 | 19/10/2016 | £22,690.00 SOFTCAT LTD | IT MAINTENANCE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1007996 | 19/10/2016 | £20,000.00 DAC BEACHCROFT CLAIMS LTD | INPUT VAT - ADJUSTMENTS | FINANCE SERVICES | | Rochdale Borough Council q1007997 | 19/10/2016 | £5,029.60 ELECTORAL REFORM SERVICES | IT EQUIPMENT | FINANCE SERVICES | | Rochdale Borough Council d1062038 | 20/10/2016 | £144,480.00 CROMWELL POLYTHENE LIMITED | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062040 | 20/10/2016 | £7,229.15 NORTHGATE VEHICLE HIRE LIMITED | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062049 | 20/10/2016 | £6,450.00 ENTERPRISE MANCHESTER PARTNERSHIP LTD | CONTRACTED SERVICES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062052 | 20/10/2016 | £10,312.24 WHEELDON BROTHERS WASTE LIMITED | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008009 | 20/10/2016 | £7,000.00 STHREE PARTNERSHIP LLP | CAPITAL SALARIES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008011 | 20/10/2016 | £18,480.00 STHREE PARTNERSHIP LLP | AGENCY STAFF | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008016 | 20/10/2016 | £17,423.40 IDOX SOFTWARE LTD | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062072 | 21/10/2016 | £6,000.00 TAMESIDE METROPOLITAN BOROUGH COUNCIL | CONTRACTED SERVICES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council ph101546 | 21/10/2016 | £14,490.00 TURNING POINT SERVICES LIMITED | CONTRACTED SERVICES | PUBLIC HEALTH | | Rochdale Borough Council ph101547 | 21/10/2016 | £17,940.00 TURNING POINT SERVICES LIMITED | CONTRACTED SERVICES | PUBLIC HEALTH | | Rochdale Borough Council s1020892 | 21/10/2016 | £5,267.00 STANNAH LIFT SERVICES LTD | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1020894 | 21/10/2016 | £6,864.00 NEWLINE ADAPTATIONS LTD | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1020896 | 21/10/2016 | £9,381.00 K P DODD CONSTRUCTION LIMITED | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council d1062080 | 24/10/2016 | £6,990.00 PLAYBROKERS LTD | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062095 | 24/10/2016 | £5,376.00 CLOVER SECURITY SERVICES LIMITED | TRAINING | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022104 | 24/10/2016 | £11,197.34 BELMONT SCHOOL LIMITED | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022106 | 24/10/2016 | £10,566.16 THE TOGETHER TRUST | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022107 | 24/10/2016 | £23,059.13 BIRTENSHAW HALL SCHOOL | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022110 | 24/10/2016 | £12,253.08 THE TOGETHER TRUST | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022111 | 24/10/2016 | £7,325.86 THE TOGETHER TRUST | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022112 | 24/10/2016 | £11,483.26 THE TOGETHER TRUST | OTHER LA`S - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022113 | 24/10/2016 | £21,680.40 NEW BRIDGE SCHOOL | OTHER EST - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1008024 | 24/10/2016 | £8,447.12 CIVICA UK LIMITED | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council s1020907 | 24/10/2016 | £11,550.00 ACTION FIRST IPEOPLE LTD | EXPENSES - GENERAL | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council d1062132 | 25/10/2016 | £10,800.00 ROCHDALE DEVELOPMENT AGENCY | BASIC SALARIES | ECONOMY DIRECTORATE | | Rochdale Borough Council d1062133 | 25/10/2016 | £7,580.00 ROCHDALE DEVELOPMENT AGENCY | BASIC SALARIES | ECONOMY DIRECTORATE | | Rochdale Borough Council e1022120 | 25/10/2016 | £10,000.00 THE TUTOR TRUST | INDEPENDENT UNITS | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1008030 | 25/10/2016 | £563,111.00 AGILISYS LIMITED | AGILISYS CONTRACT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008032 | 25/10/2016 | £8,323.71 PHOENIX SOFTWARE LIMITED | PURCHASE OF ICT HARDWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council s1020922 | 25/10/2016 | £5,180.00 D W TAYLOR & SON | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council x1013110 | 25/10/2016 | £5,000.00 CHRISTINE FOSTER LIMITED | AGENCY STAFF | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council x1013113 | 25/10/2016 | £9,000.00 CARITAS CARE LTD | SUBSIDISED ADOPTERS PMTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council x1013114 | 25/10/2016 | £9,000.00 CARITAS CARE LTD | SUBSIDISED ADOPTERS PMTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council x1013115 | 25/10/2016 | £8,340.00 ADOPTION MATTERS NORTHWEST | ACTIVITIES | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council ph101557 | 26/10/2016 | £32,500.00 COUNCIL FOR VOLUNTARY SERVICE ROCHDALE | PH OTHER CONTRACTS | PUBLIC HEALTH | | Rochdale Borough Council q1008039 | 26/10/2016 | £17,504.00 AGILISYS LIMITED | AGILISYS CONTRACT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council x1013122 | 26/10/2016 | £27,000.00 TRAFFORD MBC | ADOPTION PAYMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1062160 | 27/10/2016 | £9,795.32 J A CRYER EXCAVATION & GROUNDWORK CONTRACTORS LTD ENVIRONMENTAL WORKS LANDSCAPE | NEIGHBOURHOODS AND ENVIRONMENT | | | Rochdale Borough Council d1062166 | 27/10/2016 | £115,510.20 WARM ZONES CIC | GRANTS TO OTHER BODIES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062167 | 27/10/2016 | £115,510.20 WARM ZONES CIC | GRANTS TO OTHER BODIES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062174 | 27/10/2016 | £14,229.62 AECOM INFRASTRUCTURE AND ENVIRONMENT UK LTD | DEMOLITION | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022129 | 27/10/2016 | £9,750.00 PERMANENT FUTURES LTD | AGENCY STAFF | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1008044 | 27/10/2016 | £42,000.00 STHREE PARTNERSHIP LLP | AGENCY STAFF | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council r1001561 | 27/10/2016 | £352,523.36 VBA JOINT VENTURE LTD | ENVIRONMENTAL WORKS LANDSCAPE | ECONOMY DIRECTORATE | | Rochdale Borough Council x1013123 | 27/10/2016 | £8,654.34 SPORT WORKS | ACTIVITIES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council d1062188 | 28/10/2016 | £394,505.79 COMMUNITY LIGHTING PARTNERSHIP ROCHDALE LTD | PFI SCHEMES RPIX | PROPERTY AND HIGHWAYS | | Rochdale Borough Council x1013132 | 28/10/2016 | £60,000.00 NEWCASTLE CITY COUNCIL | ADOPTION PAYMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council e1022149 | 31/10/2016 | £14,531.00 OLDHAM COUNCIL | OTHER EST - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1008061 | 31/10/2016 | £75,000.00 TUSKERDIRECT LIMITED | TRANSACTIONS-EXPENDITURE | FINANCE SERVICES | | Rochdale Borough Council s1020932 | 31/10/2016 | £7,000.00 ACTION FIRST IPEOPLE LTD | FEES / COMMISSION | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council x1013141 | 31/10/2016 | £43,000.00 BOLTON MBC | ADOPTION PAYMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1062227 | 01/11/2016 | £8,900.00 ROCHDALE BOROUGHWIDE HOUSING | CONTRACTED SERVICES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062235 | 01/11/2016 | £10,000.00 UNITY PARTNERSHIP LTD | ROADWORKS | PROPERTY AND HIGHWAYS | | Rochdale Borough Council d1062245 | 01/11/2016 | £5,344.80 DELMATIC LIGHTING MANAGEMENT | PROPERTY - WORKS ELEMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062246 | 01/11/2016 | £7,000.00 WHEELDON BROTHERS WASTE LIMITED | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062247 | 01/11/2016 | £6,000.00 WHEELDON BROTHERS WASTE LIMITED | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062253 | 01/11/2016 | £10,555.00 STRAND PRIVATE HIRE | TAXI HIRE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022158 | 01/11/2016 | £10,000.00 SUPPLY DESK | SOFTWARE | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1008099 | 01/11/2016 | £5,260.20 CLYDE & CO | LEGAL SERVICES EXTERNAL | ECONOMY DIRECTORATE | | Rochdale Borough Council d1062272 | 02/11/2016 | £138,262.20 RIVERSIDE TRUCK RENTAL | LONG TERM CONTRACTED EXTERNAL HIRE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062283 | 02/11/2016 | £33,250.00 EMO OIL LIMITED | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Organisation Name | Purchase_Order_Number | Order_Date Total_Value Supplier_Name | Account_Name | Service | |-----------------------------------|-------------------------|-----------------------------------------------------|-------------------------------------------------------------------------|--------------------------------| | Rochdale Borough Council e1022180 | 02/11/2016 | £196,513.27 INSPIREDSPACES ROCHDALE PROJECT CO1 LTD | NEW CONSTRUCTION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022181 | 02/11/2016 | £17,119.00 INSPIREDSPACES ROCHDALE PROJECT CO1 LTD | NEW CONSTRUCTION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council ph101562 | 02/11/2016 | £21,012.00 THE PENNINE ACUTE HOSPITALS NHS TRUST | PH PENNINE CARE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council ph101564 | 02/11/2016 | £6,400.00 KAPOOR CHEMISTS LTD | FEES / COMMISSION | PUBLIC HEALTH | | Rochdale Borough Council d1062329 | 03/11/2016 | £32,560.00 UNITY PARTNERSHIP LTD | CONSULTANT FEES | PROPERTY AND HIGHWAYS | | Rochdale Borough Council e1022195 | 03/11/2016 | £323,458.54 INSPIREDSPACES ROCHDALE PROJECT CO1 LTD | PFI SCHEMES RPIX | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022196 | 03/11/2016 | £28,813.75 BURY MBC | OTHER EST - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council ph101565 | 03/11/2016 | £90,750.00 PENNINE CARE NHS | PH PENNINE CARE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council ph101566 | 03/11/2016 | £355,417.00 PENNINE CARE NHS | PH PENNINE CARE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council f1004907 | 04/11/2016 | £50,000.00 CRITIQOM LIMITED | POSTAGE | FINANCE SERVICES | | Rochdale Borough Council q1008128 | 04/11/2016 | £26,000.00 MIDLAND SOFTWARE LTD | SOFTWARE | FINANCE SERVICES | | Rochdale Borough Council q1008129 | 04/11/2016 | £7,500.00 CAPITA RESOURCING LIMITED | RECRUITMENT AGENCY FEES | FINANCE SERVICES | | Rochdale Borough Council d1062354 | 07/11/2016 | £13,237.50 ROCHDALE TOWN CENTRE MANAGEMENT CO | GRANTS TO THE NON VOLUNTARY SECTOR | ECONOMY DIRECTORATE | | Rochdale Borough Council d1062359 | 07/11/2016 | £31,520.00 OLDHAM & ROCHDALE GROUNDWORK TRUST LTD | FEES -CONSTRUCTION CONVERSION RENOVATION NEIGHBOURHOODS AND ENVIRONMENT | | | Rochdale Borough Council d1062360 | 07/11/2016 | £14,238.00 SSI SCHAEFER LIMITED | PURCHASE OF OTHER EQUIPMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062361 | 07/11/2016 | £13,089.60 SSI SCHAEFER LIMITED | PURCHASE OF OTHER EQUIPMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062365 | 07/11/2016 | £6,720.00 OFFICE DEPOT UK LIMITED | ACTIVITIES | PUBLIC HEALTH | | Rochdale Borough Council d1062376 | 07/11/2016 | £14,304.80 H BELL & SONS ROCHDALE LTD | PROPERTY - WORKS ELEMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022213 | 07/11/2016 | £384,356.06 INSPIREDSPACES ROCHDALE PROJECTCO2 LTD | PFI SCHEMES RPIX | EARLY HELP AND SCHOOLS | | Rochdale Borough Council d1062396 | 08/11/2016 | £12,000.00 LAMBERT SMITH HAMPTON GROUP LTD | SURVEYORS FEES | ECONOMY DIRECTORATE | | Rochdale Borough Council d1062397 | 08/11/2016 | £7,932.13 NORTHGATE VEHICLE HIRE LIMITED | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062404 | 08/11/2016 | £6,758.68 ENTERPRISE FLEX-E-RENT | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062430 | 08/11/2016 | £24,272.57 RAMBOLL UK LTD | MINOR BUILDING WORKS | PROPERTY AND HIGHWAYS | | Rochdale Borough Council d1062434 | 08/11/2016 | £5,610.00 SCARAB SWEEPERS LIMITED | VEHICLE MAINTENANCE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062435 | 08/11/2016 | £14,324.00 GROUNDWORK LANDSCAPES LIMITED | PURCHASE OF FURNITURE AND EQUIPMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062436 | 08/11/2016 | £5,000.00 CLOVER SECURITY SERVICES LIMITED | SECURITY | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022218 | 08/11/2016 | £72,630.82 INSPIREDSPACES ROCHDALE LTD | NEW CONSTRUCTION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022219 | 08/11/2016 | £10,161.59 INSPIREDSPACES ROCHDALE LTD | NEW CONSTRUCTION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004911 | 08/11/2016 | £6,027.11 CO-OP PAYPOINT | BANK CHARGES | FINANCE SERVICES | | Rochdale Borough Council d1062477 | 09/11/2016 | £22,578.00 ROCHDALE BOROUGHWIDE HOUSING | GRANTS TO THE NON VOLUNTARY SECTOR | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062481 | 09/11/2016 | £18,000.00 WHEELDON BROTHERS WASTE LIMITED | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062483 | 09/11/2016 | £6,922.70 TYRE FORCE NW LTD | TYRES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022233 | 09/11/2016 | £85,018.98 DIOCESE OF SALFORD | NEW CONSTRUCTION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022236 | 09/11/2016 | £18,725.47 BURY MBC | OTHER EST - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1008138 | 09/11/2016 | £8,977.02 SOFTCAT LTD | PURCHASE OF ICT HARDWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062499 | 10/11/2016 | £6,349.40 BRUEL & KJAER LIMITED | EQUIPMENT - GENERAL | PUBLIC HEALTH | | Rochdale Borough Council f1004917 | 10/11/2016 | £14,225.00 CAPITA TREASURY SOLUTIONS LTD | CONSULTANT FEES | FINANCE SERVICES | | Rochdale Borough Council f1004919 | 10/11/2016 | £105,000.00 TRAFFORD MBC | OTHER LOCAL AUTHORITIES | FINANCE SERVICES | | Rochdale Borough Council ph101582 | 10/11/2016 | £9,660.00 TURNING POINT SERVICES LIMITED | CONTRACTED SERVICES | PUBLIC HEALTH | | Rochdale Borough Council q1008148 | 10/11/2016 | £54,217.00 AGILISYS LIMITED | AGILISYS CONTRACT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022247 | 11/11/2016 | £9,995.00 CHESHIRE AND GREATER MANCHESTER CRC | ACTIVITIES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022249 | 11/11/2016 | £44,100.00 POSITIVE STEPS | EXTERNALLY MANAGED FUNDS | EARLY HELP AND SCHOOLS | | Rochdale Borough Council r1001564 | 11/11/2016 | £57,246.45 THE PLANNING INSPECTORATE | ACTIVITIES | ECONOMY DIRECTORATE | | Rochdale Borough Council e1022259 | 14/11/2016 | £684,060.38 AXIOM EDUCATION (ROCHDALE) LIMITED | PFI SCHEMES RPIX | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1008167 | 14/11/2016 | £21,000.00 RESTORE DOCUMENT MANAGEMENT | DATA COLLECTION | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council w1001607 | 14/11/2016 | £90,000.00 ALTERNATIVE FUTURES GROUP LTD | INDIVIDUAL SERVICE FUND | LEARNING DIS & MENTAL HEALTH | | Rochdale Borough Council w1001608 | 14/11/2016 | £61,000.00 CAREWATCH CARE SERVICES LTD | HOME CARE - ADULT SERVICES | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council x1013208 | 14/11/2016 | £8,654.34 SPORT WORKS | ACTIVITIES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council x1013209 | 14/11/2016 | £18,000.00 ADOPTION FOCUS | ADOPTION PAYMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council w1001611 | 15/11/2016 | £10,140.00 NHS HEYWOOD MIDDLETON AND ROCHDALE CCG | EXPENSES - GENERAL | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council x1013217 | 15/11/2016 | £5,000.00 CHRISTINE FOSTER LIMITED | AGENCY STAFF | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1062586 | 16/11/2016 | £11,615.00 JEREMY BENN ASSOCIATES LTD | GRANTS TO THE NON VOLUNTARY SECTOR | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022281 | 16/11/2016 | £8,550.00 PSYCHOLOGY PEOPLE | BASIC SALARIES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004929 | 16/11/2016 | £10,204.00 CAPITA BUSINESS SERVICES LIMITED | SOFTWARE | FINANCE SERVICES | | Rochdale Borough Council s1020979 | 16/11/2016 | £5,411.85 STANNAH LIFT SERVICES LTD | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council x1013218 | 16/11/2016 | £9,900.00 INTERCOUNTRY ADOPTION CENTRE | ADOPTION PAYMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1062633 | 17/11/2016 | £31,000.00 TRANSPORT FOR GREATER MANCHESTER | ROADWORKS | PROPERTY AND HIGHWAYS | | Rochdale Borough Council d1062648 | 17/11/2016 | £61,030.00 UNITY PARTNERSHIP LTD | CONSULTANT FEES | PROPERTY AND HIGHWAYS | | Rochdale Borough Council ph101591 | 17/11/2016 | £15,676.74 VIRGIN CARE SERVICES LIMITED | VIRGIN CARE | PUBLIC HEALTH | | Rochdale Borough Council q1008197 | 17/11/2016 | £7,500.00 EXPERIAN LIMITED | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062668 | 18/11/2016 | £14,500.00 UNITY PARTNERSHIP LTD | CONSULTANTS FEES | PROPERTY AND HIGHWAYS | | Rochdale Borough Council f1004933 | 18/11/2016 | £76,800.00 AXON RESOURCING LIMITED | AGENCY STAFF | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council q1008201 | 18/11/2016 | £9,900.00 MANCHESTER CITY COUNCIL | AGENCY STAFF | FINANCE SERVICES | | Rochdale Borough Council q1008202 | 18/11/2016 | £9,900.00 MANCHESTER CITY COUNCIL | AGENCY STAFF | FINANCE SERVICES | | Rochdale Borough Council q1008207 | 18/11/2016 | £410,934.87 ZURICH INSURANCE PLC | TRANSACTIONS-EXPENDITURE | FINANCE SERVICES | | Rochdale Borough Council q1008208 | 18/11/2016 | £71,800.00 ZURICH INSURANCE PLC | TRANSACTIONS-EXPENDITURE | FINANCE SERVICES | | Organisation Name | Purchase_Order_Number | Order_Date Total_Value Supplier_Name | Account_Name | Service | |-----------------------------------|-------------------------|--------------------------------------------------------------|-------------------------------------------------------------------------|--------------------------------| | Rochdale Borough Council d1062682 | 21/11/2016 | £12,640.82 CARIBOU GREEN WARMTH LLP | GRANTS TO THE NON VOLUNTARY SECTOR | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062691 | 21/11/2016 | £8,000.00 TRINITY MIRROR PUBLISHING LTD | ADVERTISING | PROPERTY AND HIGHWAYS | | Rochdale Borough Council d1062701 | 21/11/2016 | £36,550.00 MECHPLANT NORTH WEST LIMITED | PURCHASE OF PLANT AND MACHINERY | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022310 | 21/11/2016 | £24,318.76 AXIOM EDUCATION (ROCHDALE) LIMITED | MEALS | EARLY HELP AND SCHOOLS | | Rochdale Borough Council q1008212 | 21/11/2016 | £28,166.50 TRIMBLE UK LIMITED | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council x1013239 | 21/11/2016 | £8,640.00 ADOPTION MATTERS NORTHWEST | ACTIVITIES | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1062724 | 22/11/2016 | £12,000.00 LAMBERT SMITH HAMPTON GROUP LTD | SURVEYORS FEES | ECONOMY DIRECTORATE | | Rochdale Borough Council d1062726 | 22/11/2016 | £21,583.43 TURNER AND TOWNSEND | OTHER SURVEYS | ECONOMY DIRECTORATE | | Rochdale Borough Council d1062743 | 22/11/2016 | £33,250.00 EMO OIL LIMITED | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008221 | 22/11/2016 | £33,988.28 SPECIALIST COMPUTER CENTRES PLC | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062752 | 23/11/2016 | £18,935.08 KEEPMOAT REGENERATION LTD | FEES -CONSTRUCTION CONVERSION RENOVATION NEIGHBOURHOODS AND ENVIRONMENT | | | Rochdale Borough Council q1008230 | 23/11/2016 | £25,340.00 XMA LIMITED | PURCHASE OF FURNITURE AND EQUIPMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062803 | 24/11/2016 | £7,920.00 MIDDLETON CARS | TAXI HIRE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022342 | 24/11/2016 | £9,995.00 RELATE GREATER MANCHESTER SOUTH | ACTIVITIES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022343 | 24/11/2016 | £9,995.00 CHESHIRE AND GREATER MANCHESTER CRC | ACTIVITIES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022351 | 24/11/2016 | £12,000.00 IDOX SOFTWARE LTD | SOFTWARE | EARLY HELP AND SCHOOLS | | Rochdale Borough Council ph101606 | 24/11/2016 | £124,574.58 BIG LIFE CENTRES | PH BIG LIFE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council q1008239 | 24/11/2016 | £9,000.00 OULDER HILL COMMUNITY SCHOOL | RENTS | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022353 | 25/11/2016 | £6,717.36 BOOKTRUST | REFERENCE BOOKS/NEWSPAPERS/PERIODICALS | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022358 | 25/11/2016 | £7,442.22 AXIOM EDUCATION (ROCHDALE) LIMITED | DEV CAP - NEW CONSTRUCTION,CONVERSION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council s1021006 | 25/11/2016 | £12,175.00 HIGH BARN CONSTRUCTION LIMITED | TRANSACTIONS-EXPENDITURE | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1021017 | 25/11/2016 | £7,420.00 TERRY GROUP LTD | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1021018 | 25/11/2016 | £8,028.00 HIGH BARN CONSTRUCTION LIMITED | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1021019 | 25/11/2016 | £5,525.00 HIGH BARN CONSTRUCTION LIMITED | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council d1062847 | 28/11/2016 | £8,700.00 F R SHARROCK LIMITED | PURCHASE OF PLANT AND MACHINERY | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council f1004939 | 28/11/2016 | £12,000.00 MWUK LTD | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008255 | 28/11/2016 | £6,561.00 TG PRODUCTION SUPPLY LTD | EVENTS | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008264 | 28/11/2016 | £11,500.00 AON LIMITED | TRANSACTIONS-EXPENDITURE | FINANCE SERVICES | | Rochdale Borough Council s1021020 | 28/11/2016 | £23,250.00 PETRUS | SERVICE LEVEL AGREEMENTS | LEARNING DIS & MENTAL HEALTH | | Rochdale Borough Council s1021021 | 28/11/2016 | £23,250.00 PETRUS | SERVICE LEVEL AGREEMENTS | LEARNING DIS & MENTAL HEALTH | | Rochdale Borough Council s1021026 | 28/11/2016 | £7,752.00 BROADWAY BUILDING CONTRACTORS OLDHAM LTD | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1021027 | 28/11/2016 | £7,890.00 NEWLINE ADAPTATIONS LTD | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1021029 | 28/11/2016 | £7,537.85 HIGH BARN CONSTRUCTION LIMITED | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1021035 | 28/11/2016 | £5,097.00 STANNAH LIFT SERVICES LTD | TRANSACTIONS-EXPENDITURE | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council s1021036 | 28/11/2016 | £23,266.94 FLETCHER BUILDING SERVICES LIMITED | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council w1001629 | 28/11/2016 | £469,167.21 THE PENNINE ACUTE HOSPITALS NHS TRUST | CONTRACTS | BETTER CARE FUND POOLED BUDGET | | Rochdale Borough Council w1001630 | 28/11/2016 | £469,167.21 THE PENNINE ACUTE HOSPITALS NHS TRUST | CONTRACTS | BETTER CARE FUND POOLED BUDGET | | Rochdale Borough Council d1062863 | 29/11/2016 | £394,505.79 COMMUNITY LIGHTING PARTNERSHIP ROCHDALE LTD | PFI SCHEMES RPIX | PROPERTY AND HIGHWAYS | | Rochdale Borough Council d1062870 | 29/11/2016 | £15,000.00 DECIPHER IMPACT LIMITED | EQUIPMENT - GENERAL | PUBLIC HEALTH | | Rochdale Borough Council ph101619 | 29/11/2016 | £15,911.34 CENTRAL MANCHESTER UNIVERSITY HOSPITALS NHS TRUST | SERVICE LEVEL AGREEMENTS | PUBLIC HEALTH | | Rochdale Borough Council q1008272 | 29/11/2016 | £18,358.00 XMA LIMITED | PURCHASE OF ICT HARDWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062881 | 30/11/2016 | £32,300.87 GROUNDWORK LANDSCAPES LIMITED | PURCHASE OF FURNITURE AND EQUIPMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062914 | 30/11/2016 | £33,250.00 EMO OIL LIMITED | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council f1004942 | 30/11/2016 | £5,500.00 NORTHGATE PUBLIC SERVICES (UK) LTD | EXTERNAL CONTRACTED PRINTING | FINANCE SERVICES | | Rochdale Borough Council q1008277 | 30/11/2016 | £6,000.00 LIQUIDLOGIC LTD | SOFTWARE | EARLY HELP AND SCHOOLS | | Rochdale Borough Council s1021039 | 30/11/2016 | £37,138.00 NHS HEYWOOD MIDDLETON AND ROCHDALE CCG | CONTRACTS | BETTER CARE FUND POOLED BUDGET | | Rochdale Borough Council s1021047 | 30/11/2016 | £5,195.00 ADAPT BUILDING SERVICES LTD | IMPROVEMENTS-EXTENSIONS & ALTERATIONS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council d1062943 | 01/12/2016 | £5,687.97 CURTINS CONSULTING | SURVEYORS FEES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1062963 | 01/12/2016 | £40,000.00 A E YATES LTD | ROADWORKS | PROPERTY AND HIGHWAYS | | Rochdale Borough Council f1004943 | 01/12/2016 | £21,482.02 G4S TOTAL SECURITY LIMITED | TRANSACTIONS-EXPENDITURE | EARLY HELP AND SCHOOLS | | Rochdale Borough Council ph101623 | 01/12/2016 | £44,638.49 NHS HEYWOOD MIDDLETON AND ROCHDALE CCG | CONTRACTED SERVICES | PUBLIC HEALTH | | Rochdale Borough Council q1008287 | 01/12/2016 | £32,000.00 MODIS | AGENCY STAFF | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008295 | 02/12/2016 | £8,747.33 KHIPU NETWORKS LTD | PURCHASE OF ICT HARDWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council s1021057 | 02/12/2016 | £14,350.00 ACTION FIRST IPEOPLE LTD | FEES / COMMISSION | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council x1013279 | 02/12/2016 | £14,333.00 AFTER ADOPTION | ADOPTION PAYMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1063025 | 05/12/2016 | £19,880.00 BARTEC AUTO ID LTD | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council ph101625 | 05/12/2016 | £90,750.00 PENNINE CARE NHS | PH PENNINE CARE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council ph101626 | 05/12/2016 | £355,417.00 PENNINE CARE NHS | PH PENNINE CARE CONTRACT | PUBLIC HEALTH | | Rochdale Borough Council q1008301 | 05/12/2016 | £15,519.00 FREEDOM COMMUNICATIONS | IT MAINTENANCE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council r1001570 | 05/12/2016 | £22,983.44 BRAHM FUNDCO 2 LTD | CHARGES-COMMITAL | ECONOMY DIRECTORATE | | Rochdale Borough Council x1013280 | 05/12/2016 | £28,667.00 AFTER ADOPTION | ADOPTION PAYMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council x1013281 | 05/12/2016 | £28,667.00 CCS ADOPTION | ADOPTION PAYMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council x1013284 | 05/12/2016 | £7,817.62 AFTER ADOPTION | ACTIVITIES | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1063056 | 06/12/2016 | £7,821.00 PAUL SMITH CO PLMBG BLDG SER LTD | REPAIRS & ALTS OF BUILDINGS | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022429 | 06/12/2016 | £11,321.34 NORTH RIDGE HIGH SCHOOL | OTHER EST - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004947 | 06/12/2016 | £5,886.14 CO-OP PAYPOINT | BANK CHARGES | FINANCE SERVICES | | Organisation Name | Purchase_Order_Number | Order_Date Total_Value Supplier_Name | Account_Name | Service | |-----------------------------------|-------------------------|--------------------------------------------------------|---------------------------------------|--------------------------------| | Rochdale Borough Council q1008305 | 06/12/2016 | £6,300.00 EMAP PUBLISHING LIMITED | BUDGET TO BE ALLOCATED | FINANCE SERVICES | | Rochdale Borough Council d1063078 | 07/12/2016 | £14,238.00 SSI SCHAEFER LIMITED | PURCHASE OF OTHER EQUIPMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063080 | 07/12/2016 | £21,048.25 THE RIVERSIDE GROUP LIMITED | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063083 | 07/12/2016 | £14,168.00 EARLEY ORNAMENTALS LTD | TREES, SHRUBS, PLANTS | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063087 | 07/12/2016 | £5,000.00 A E YATES LTD | BRIDGES STRUCTURAL WORK | ECONOMY DIRECTORATE | | Rochdale Borough Council d1063099 | 07/12/2016 | £97,322.79 CARIBOU GREEN WARMTH LLP | GRANTS TO THE NON VOLUNTARY SECTOR | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022430 | 07/12/2016 | £16,810.00 AXIOM EDUCATION (ROCHDALE) LIMITED | DEV CAP - NEW CONSTRUCTION,CONVERSION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004949 | 07/12/2016 | £17,892.14 G4S CASH SOLUTIONS UK LIMITED | TRANSACTIONS-EXPENDITURE | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004951 | 07/12/2016 | £40,209.75 NEPRO LIMITED | AGENCY STAFF | FINANCE SERVICES | | Rochdale Borough Council f1004952 | 07/12/2016 | £45,534.83 NEPRO LIMITED | AGENCY STAFF | FINANCE SERVICES | | Rochdale Borough Council q1008312 | 07/12/2016 | £10,000.00 VICTIM SUPPORT & WITNESS SERVICE | GRANTS TO THE NON VOLUNTARY SECTOR | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008314 | 07/12/2016 | £32,988.25 VICTIM SUPPORT & WITNESS SERVICE | GRANTS TO THE NON VOLUNTARY SECTOR | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022441 | 08/12/2016 | £15,210.55 AXIOM EDUCATION (ROCHDALE) LIMITED | NEW CONSTRUCTION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022448 | 08/12/2016 | £97,976.79 INSPIREDSPACES ROCHDALE PROJECT CO1 LTD | NEW CONSTRUCTION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council r1001571 | 08/12/2016 | £22,983.44 BRAHM FUNDCO 2 LTD | CHARGES-COMMITAL | ECONOMY DIRECTORATE | | Rochdale Borough Council r1001572 | 08/12/2016 | £22,983.44 BRAHM FUNDCO 2 LTD | CHARGES-COMMITAL | ECONOMY DIRECTORATE | | Rochdale Borough Council r1001573 | 08/12/2016 | £22,983.44 BRAHM FUNDCO 2 LTD | CHARGES-COMMITAL | ECONOMY DIRECTORATE | | Rochdale Borough Council s1021072 | 08/12/2016 | £7,200.00 PREPAID FINANCIAL SERVICES | CONTRACTED SERVICES | LEARNING DIS & MENTAL HEALTH | | Rochdale Borough Council d1063128 | 09/12/2016 | £9,750.00 LAMBERT SMITH HAMPTON GROUP LTD | TRANSACTIONS-EXPENDITURE | FINANCE SERVICES | | Rochdale Borough Council d1063130 | 09/12/2016 | £10,192.50 TYRE FORCE NW LTD | TYRES | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063153 | 09/12/2016 | £5,500.00 BROXAP LIMITED | PURCHASE OF FURNITURE AND EQUIPMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063160 | 09/12/2016 | £6,484.00 CLYDE & CO | LEGAL SERVICES EXTERNAL | ECONOMY DIRECTORATE | | Rochdale Borough Council q1008328 | 09/12/2016 | £6,637.50 JGM AGENCY | PUBLICITY | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063163 | 12/12/2016 | £8,869.17 EGBERT H TAYLOR & CO LTD | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063164 | 12/12/2016 | £21,600.00 WINTERBURNS OF ROCHDALE | MINOR BUILDING WORKS | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063180 | 12/12/2016 | £14,596.44 ROCHDALE HOUSING INITIATIVE | CONDITION SURVEYS | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022456 | 12/12/2016 | £698,094.14 AXIOM EDUCATION (ROCHDALE) LIMITED | PFI SCHEMES RPIX | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022461 | 12/12/2016 | £33,176.14 AXIOM EDUCATION (ROCHDALE) LIMITED | MEALS | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022462 | 12/12/2016 | £44,100.00 POSITIVE STEPS | EXTERNALLY MANAGED FUNDS | EARLY HELP AND SCHOOLS | | Rochdale Borough Council e1022469 | 12/12/2016 | £5,258.28 OFFICE DEPOT UK LIMITED | PRINTING | EARLY HELP AND SCHOOLS | | Rochdale Borough Council x1013299 | 12/12/2016 | £5,000.00 CHRISTINE FOSTER LIMITED | AGENCY STAFF | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1063190 | 13/12/2016 | £6,781.00 JMHA | PROPERTY REFURBISHMENT (HOUSING) | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063191 | 13/12/2016 | £14,000.00 JMHA | PROPERTY REFURBISHMENT (HOUSING) | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063206 | 13/12/2016 | £6,989.40 ENTERPRISE FLEX-E-RENT | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063208 | 13/12/2016 | £7,656.00 NO WORRIES IT LTD | ACTIVITIES | ECONOMY DIRECTORATE | | Rochdale Borough Council e1022472 | 13/12/2016 | £8,156.00 OLDHAM COUNCIL | OTHER EST - SEN PROVISION | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004955 | 13/12/2016 | £17,900.00 OFFICE DEPOT UK LIMITED | PRINTING & STATIONERY | FINANCE SERVICES | | Rochdale Borough Council f1004956 | 13/12/2016 | £8,550.00 NORTHGATE PUBLIC SERVICES (UK) LTD | SOFTWARE | FINANCE SERVICES | | Rochdale Borough Council s1021080 | 13/12/2016 | £8,110.00 BROADWAY BUILDING CONTRACTORS OLDHAM LTD | TRANSACTIONS-EXPENDITURE | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council w1001635 | 13/12/2016 | £59,515.54 ROSS CARE | OTHER AGENCIES | BETTER CARE FUND POOLED BUDGET | | Rochdale Borough Council w1001636 | 13/12/2016 | £63,272.21 ROSS CARE | OTHER AGENCIES | BETTER CARE FUND POOLED BUDGET | | Rochdale Borough Council w1001637 | 13/12/2016 | £51,205.00 ROSS CARE | OTHER AGENCIES | BETTER CARE FUND POOLED BUDGET | | Rochdale Borough Council w1001638 | 13/12/2016 | £22,100.00 PETRUS | SERVICE LEVEL AGREEMENTS | LEARNING DIS & MENTAL HEALTH | | Rochdale Borough Council w1001639 | 13/12/2016 | £91,364.00 ALTERNATIVE FUTURES GROUP LTD | INDIVIDUAL SERVICE FUND | LEARNING DIS & MENTAL HEALTH | | Rochdale Borough Council d1063244 | 14/12/2016 | £15,050.00 RUSHTONS DEVELOPMENTS LTD | PROPERTY REFURBISHMENT (HOUSING) | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063260 | 14/12/2016 | £6,550.00 BELFIELD COMMUNITY PRIMARY SCHOOL | RENTS | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063262 | 14/12/2016 | £14,238.00 SSI SCHAEFER LIMITED | PURCHASE OF FURNITURE AND EQUIPMENT | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063264 | 14/12/2016 | £11,757.09 NORTHGATE VEHICLE HIRE LIMITED | TRANSACTIONS-EXPENDITURE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022475 | 14/12/2016 | £321,982.20 INSPIREDSPACES ROCHDALE PROJECT CO1 LTD | PFI SCHEMES RPIX | EARLY HELP AND SCHOOLS | | Rochdale Borough Council d1063279 | 15/12/2016 | £5,000.00 HOWLEY JOINERY AND PROPERTY MAINTENANCE | GRANTS TO THE NON VOLUNTARY SECTOR | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063280 | 15/12/2016 | £31,520.00 GROUNDWORK OLDHAM AND ROCHDALE | MINOR BUILDING WORKS | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022489 | 15/12/2016 | £411,585.71 INSPIREDSPACES ROCHDALE PROJECTCO2 LTD | PFI SCHEMES RPIX | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004978 | 15/12/2016 | £10,825.44 AON LIMITED | TRANSACTIONS-EXPENDITURE | FINANCE SERVICES | | Rochdale Borough Council r1001582 | 15/12/2016 | £140,196.77 CANAL & RIVER TRUST | ROCHDALE CANAL MAINTENANCE | ECONOMY DIRECTORATE | | Rochdale Borough Council r1001583 | 15/12/2016 | £10,105.00 OLDHAM COUNCIL | CONSULTANT FEES | ECONOMY DIRECTORATE | | Rochdale Borough Council x1013326 | 15/12/2016 | £5,310.00 YOUTH JUSTICE BOARD | SERVICE LEVEL AGREEMENTS | | | CHILDREN'S SOCIAL CARE | | | | | | Rochdale Borough Council d1063313 | 16/12/2016 | £23,616.57 AECOM INFRASTRUCTURE AND ENVIRONMENT UK LTD | DEMOLITION | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063320 | 16/12/2016 | £8,030.00 ROCHDALE MEMORIAL SERVICE LTD | EQUIPMENT - GENERAL | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council e1022497 | 16/12/2016 | £5,347.37 OFFICE DEPOT UK LIMITED | PRINTING | EARLY HELP AND SCHOOLS | | Rochdale Borough Council d1063345 | 19/12/2016 | £10,789.96 TURNER AND TOWNSEND | CONDITION SURVEYS | ECONOMY DIRECTORATE | | Rochdale Borough Council f1004984 | 19/12/2016 | £7,500.00 INFORM CPI LTD | SOFTWARE | FINANCE SERVICES | | Rochdale Borough Council ph101655 | 19/12/2016 | £16,866.88 WOMENS HOUSING ACTION GROUP | PH OTHER CONTRACTS | PUBLIC HEALTH | | Rochdale Borough Council ph101656 | 19/12/2016 | £16,866.88 WOMENS HOUSING ACTION GROUP | PH OTHER CONTRACTS | PUBLIC HEALTH | | Rochdale Borough Council ph101657 | 19/12/2016 | £16,866.88 WOMENS HOUSING ACTION GROUP | PH OTHER CONTRACTS | PUBLIC HEALTH | | Rochdale Borough Council ph101658 | 19/12/2016 | £16,866.88 WOMENS HOUSING ACTION GROUP | PH OTHER CONTRACTS | PUBLIC HEALTH | | Rochdale Borough Council q1008338 | 19/12/2016 | £12,536.00 SOFTCAT LTD | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Organisation Name | Purchase_Order_Number | Order_Date Total_Value Supplier_Name | Account_Name | Service | |-----------------------------------|-------------------------|---------------------------------------------------------|------------------------------------|--------------------------------| | Rochdale Borough Council s1021099 | 19/12/2016 | £5,325.00 D W TAYLOR & SON | MINOR BUILDING WORKS | PHYSICAL DIS & OLDER PEOPLE | | Rochdale Borough Council d1063392 | 20/12/2016 | £80,642.43 CARIBOU GREEN WARMTH LLP | GRANTS TO THE NON VOLUNTARY SECTOR | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council ph101660 | 20/12/2016 | £32,500.00 COUNCIL FOR VOLUNTARY SERVICE ROCHDALE | PH OTHER CONTRACTS | PUBLIC HEALTH | | Rochdale Borough Council q1008345 | 20/12/2016 | £7,812.00 SOFTBOX LTD | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008346 | 20/12/2016 | £14,755.31 SPECIALIST COMPUTER CENTRES PLC | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063419 | 21/12/2016 | £10,000.00 AECOM INFRASTRUCTURE AND ENVIRONMENT UK LTD | SITE INVESTIGATION | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council d1063431 | 22/12/2016 | £319,809.22 COMMUNITY LIGHTING PARTNERSHIP ROCHDALE LTD | PFI SCHEMES RPIX | PROPERTY AND HIGHWAYS | | Rochdale Borough Council e1022515 | 22/12/2016 | £6,626.07 ERNST & YOUNG LLP | CONSULTANTS FEES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council f1004995 | 22/12/2016 | £5,453.70 LG RESEARCH AND CONSULTANCY | ADVICE/SUPPORT | FINANCE SERVICES | | Rochdale Borough Council q1008349 | 22/12/2016 | £5,400.00 LIQUIDLOGIC LTD | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council q1008350 | 22/12/2016 | £15,308.77 EDENHOUSE SOLUTIONS LTD | SOFTWARE | NEIGHBOURHOODS AND ENVIRONMENT | | Rochdale Borough Council x1013349 | 22/12/2016 | £10,000.00 VISION FOR EDUCATION LIMITED | ACTIVITIES | EARLY HELP AND SCHOOLS | | Rochdale Borough Council r1001587 | 23/12/2016 | £5,000.00 NETWORK RAIL INFRASTRUCTURE LTD | CONTRACTED SERVICES | ECONOMY DIRECTORATE | | Rochdale Borough Council r1001587 | 23/12/2016 | £5,000.00 NETWORK RAIL INFRASTRUCTURE LTD | CONTRACTED SERVICES | ECONOMY DIRECTORATE |
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# The Public Data Group # Statement On Public Data ## Spring 2015 Update ## Contents Introduction ............................................................................................................................................ 3 Who are the Public Data Group? ............................................................................................................ 4 How PDG data being used? ..................................................................................................................... 5 Actions arising from the PDG survey ...................................................................................................... 6 Map and examples of where PDG data is being used ............................................................................ 7 What are PDG already doing to encourage wider usage of their data? ................................................. 8 How Public Data Group members fit into the pathway of support for data driven businesses .......... 10 Annex A: Breakdown of responses to the PDG survey ......................................................................... 11 Annex B: Update on previous commitments ........................................................................................ 16 Annex C: Further details on the data available from PDG members .................................................... 18 Introduction The Public Data Group (PDG) brings together four public sector bodies - Companies House, Land Registry, Met Office and Ordnance Survey - that collect, refine, manage and distribute data on the nation's companies, property, weather and geography. Collectively they form a substantial part of the National Information Infrastructure1. The Public Data Group's data is made available through a variety of channels and licences and includes both commercial agreements and the provision of Open Data2. The value of the data, and services built on that data, which are charged for, is vast - with Ordnance Survey data widely used in the insurance sector, and the billions of pounds saved by the use of Met Office data in the aviation industry as just two examples. Equally, the value of the Open Data released by the Public Data Group is very significant and growing. The most recent estimate placed the value of Open Data released by PDG at over £900m annually3. Given the growing interest and importance of open data to the economy and society we felt it was important to provide in one short document a description of the kind of data these organisations already make available, their rationale towards open data. We therefore published a Summer Statement in July 2014. This update builds on the previous statement and provides an assessment of progress on earlier commitments. It particularly focuses on the efforts of PDG to support businesses and therefore presents the results of a recent survey of organisations using PDG data. It also includes case studies on some of the responses we received, as well as setting out the actions we have taken since the survey. This document also provides background information on the various challenge activities undertaken by PDG members and the impact they have achieved. If you have any questions please do not hesitate to get in touch at PDG@bis.gsi.gov.uk. Who are the Public Data Group? The Public Data Group was created in 2011 as an Advisory Group to Ministers at the Department of Business, Innovation and Skills. PDG has an independent Chair and brings together Companies House, Land Registry, Met Office and Ordnance Survey. Public Data Group members perform key public roles and produce a wide range of nationally important data. The four organisations contain within them world leading expertise on both their subject matters and on the manipulation and management of data. They underpin a whole range of vital activities within the UK while also carrying the flag of British excellence globally - attending and advising numerous international bodies. The following descriptions and statistics aim to both capture the essence of the role they play within the nation's economy as well as giving a sense of the sheer scale and complexities of their activities. Companies House: registers the incorporation and dissolution of companies and examines, stores and disseminates information delivered under the Companies Act and related legislation. There are around 3.4 million companies registered in the UK, and approximately 600,000 new companies were incorporated last year. Over 130 million documents are accessible on the register of companies. Land Registry: registers the ownership of land and property in England and Wales. It is one of the largest transactional databases in Europe. Land Registry dealt with 26.3 million transactions in 2013/14. 86 per cent of the land mass of England and Wales is registered, adding up to more than 13 million hectares. Over 24 million titles are recorded in the Land Register. ## Met Office: Is The Uk'S National Weather Service. One of the world's most accurate forecasters, using more than 10 million global weather observations a day, an advanced atmospheric model, a high performance supercomputer and meteorological expertise to create 3,000 tailored forecasts and briefings a day. ## Ordnance Survey: Is Great Britain'S National Mapping Authority. It produces the definitive digital picture of Britain's geography and holds the largest database of its kind anywhere in the world, made up of almost half a billion features. In 12/13 99.6% of significant real-world features, which are greater than six months old, were represented in Ordnance Survey's geographic data. How PDG data being used? In order to better understand how PDG data is being used by organisations, and to help build an evidence base to better target efforts to support the data agenda, we recently ran a survey. We are grateful to all those who took part and helped to promote the survey. The section below provides a summary of the results. A further breakdown of the results in included in Annex A and an anonymised file of the survey responses will be available on Data.Gov.UK. ## Who And How We received 143 responses from organisations including a range of size and sectors - from GCSE students, to established major financial institutions. Responses supported the idea that the value in data lies in combining it with other data sources. In fact almost 86% of responses from those using data were using data from more than one source. There were very few instances of organisations using the same combination of data sets but the importance of both Ordnance Survey data and data from Local Authorities was clearly made. Another noticeable point is the number of respondents who aren't exclusively using open data. 40% for example were using paid data from private sources in addition to other data sources. ## Awareness Responses to the survey showed that there are multiple sources of information about data available. PDG websites were only listed by 22% of respondents as the place they found the most information. Although it is arguably to be expected that PDG websites may not be the first users look if there search is for public sector information in general the low percentage does suggest that more could maybe be done to make PDG websites more accessible. On awareness of both the open and paid for data offered by PDG, the majority seemed aware but a significant minority did not .This suggests that further work may necessary in this area. ## Accessibility Respondents were also asked to rank from 1 to 5 the challenges they faced using PDG data with 1 being easiest and 5 being hardest. 'Pricing' and 'licencing' were identified as the biggest challenges. 'Formatting', 'skills' and 'awareness' were generally deemed less of an issue. In terms of other practical steps that PDG could take to simplify usage of their data, the creation of a 'contact point' came out top overall. The overwhelming theme from the additional comments box was that there should be a list of public sector data assets. This was encouraging confirmation of the importance of the National Information Infrastructure (NII) being developed by Cabinet Office and PDG members look forward to continuing to engage with its development. See a note on PDG's approach to the NII here. ## Developer Licences Finally, the survey also asked questions around 'Developer Licences'. Here the dominant theme was for that these licenses should be as generous as possible - both in terms of revenue businesses could make before paying and the timescale for which they could hold the licence. Actions arising from the PDG survey The results of the survey were discussed at a roundtable that brought together a range of policy perspectives from across Government as well as representatives of data-using businesses. The meeting was attended by PDG members, the Shareholder Executive, Cabinet Office, the National Archives, the Open Data Institute and two data businesses, Geoltyix and Doorda. The discussion was extremely useful and helped both to provide a sense check of the results of the survey and to develop actions for PDG members going forward. On awareness, the discussion highlighted the challenge users face in finding and easily understand the information that they needed. Alternative ways of making licencing easier to understand and use, and of how awareness of data sets could be increased were therefore discussed. On accessibility, the conversation focused on contact points as the main request from respondents. It was noted that, while PDG members did already provide contact points, these could be made easier to find. In addition, in order to keep the costs of such contact points and other customer support to a reasonable level, FAQs on common issues should also be used. On the developer licences, the discussion was broader than the issue of cost and time limit as there was a clear understanding that users would like the most generous terms available. The importance of simplicity and ease of access were stressed and the potential scope for using the new OS developer licence terms as a basis from which to work was also raised. Based on the results of the survey and the roundtable discussion, PDG members have agreed to: - Explore the steps they could take to make data pages, licencing terms and relevant information more easily discoverable via general internet searches and easier to understand. - Look for opportunities to provide case studies of how others are using data and signposting to other relevant data sets and alongside data portals and new rata releases. - Develop and improve FAQs to address common questions alongside data portals. - Work with The National Archives and others to develop a simple toolkit for developer licenses that could be used and customised by others to reflect their bespoke needs but provide a common naming and approach and incorporate into the UK Government Licensing Framework. The PDG businesses will provide an update on progress against these actions in winter 2015. Map and examples of where PDG data is being used Please note not all responders agreed to have their details included on the map and that therefore there are more some responses not shown. Description: Martin Dodd @eggmoonstudio is an independent app developer based in Liverpool UK and entered the mobile software market in 2012 with the release of Scope Nights: Astronomy Weather for iPhone, iPad and iPad touch, recommended as a Hot Product by Sky and Telescope Magazine. Scope Nights uses the UK 3-hourly site specific forecast data feed from Met Office DataPoint. Data Used: Met Office Open Data Sector: Data/Technology Site: http://eggmoonstudio.com Description: emapsite is an established location content platform and spatial data aggregator providing a single on demand hosted managed source for open and paid-for geographic data from Ordnance Survey, BGS, EA and many other open and proprietary sources. Data used: Companies House, Land Registry, Ordnance Survey, Data.Gov.UK, Paid for private sector data providers Sector: Geospatial/mapping Site: www.emapsite.com Description: The largest open database of companies and company data in the world. We are used by a wide variety of users, including government, companies, banks, journalists and civil society. Data Used Companies House Free Data,Data.Gov.UK, Local Government sources, Central Government sources, other public resources, including Gazette notices, Health & Safety violations, etc. Sector: Data/Technology Site: https://OpenCorporates.com data modelling and analytics company. Producing location specific data on flood risks to a variety of customers, specifically insurers. Data Used Ordnance Survey, Data.Gov.UK Sector: Environment and weather Site: www.ambiental.co.uk Description: Data strategy consulting: data architecture, data modelling, data governance, business integration and business analytics. Data Used: Ordnance Survey, Data.Gov.UK, Paid for private sector data providers Sector: Data/Technology Site: http://ekoner.com/aboutme Description: Provides research and analysis, mainly to public sector on economic, planning ad other issues. Data Used: Companies House, Land Registry Ordnance Survey, Local Government sources Sector: Research and consulting Site: http://www.analytics cambridge.co.uk What are PDG already doing to encourage wider usage of their data? PDG members firmly believe that simply releasing data in the hope that someone uses it is not the best way to support innovation and growth in the UK. They therefore take part in a range of activities from attending events, offering skills training and running challenges with funding and support as prizes. The following section outlines some of the more notable examples and provides a timeline of past and future events. ## Geovation Not including the most recent challenge on housing which was jointly sponsored by Ordnance Survey and Land Registry, there have been 7 GeoVation Challenges since 2009, which together have created 28 new ventures and awarded £637,000 in funding. Topics have ranged from "How can we connect communities and visitors along the Wales Coast Path?" to "How can we help British business improve environmental performance?" OS's approach is intended to produce a business or venture that is well grounded in a problem worth solving, with a well scoped solution and a business model that sustains the solution to that problem has most chance of success. The challenge goes through a variety of stages from ideas generation, speaking to experts, initial hacks, refining ideas and receiving training, culminating in 10 teams with solid business ideas making a final pitch for funding. It's specifically not a one off event. Examples of ventures created include: - Liftshare.com who were awarded £36,500 for the idea of a web-based platform that makes travel more cost-effective and less damaging to the environment through bringing people together to share car journeys. Liftshare.com has also just increased its number of employees from 18 to 29. - Carbon Prophet (AR Carbon) was awarded £30,000 for the idea of a carbon trading scheme that mitigates the damaging effects of UK greenhouse gas emissions by encouraging farmers to exploit the natural ability of soil to absorb CO2 by changing their soil management practices. Launching later this year it is anticipated this project will initially create at least 20 new jobs. More information can be found here. Ordnance Survey are building on their success with GeoVation to create a Geospatial Innovation Hub. The Hub, located on the fringes of London's Knowledge Quarter, will be home to a multifunctional team of entrepreneurial thinkers drawn from OS's own talent pool and the broader geospatial industry, as well as those new to the industry that have been selected from developer, new media space and creative and design communities. More information can be found here. Met Office hacks Met Office are also particularly active in the hack space with two recent events providing a good example of the scope of their activity: - Arranged a hack as part of NASA's International Space App Challenge generating ideas such as clothing that connects to the Internet, a mobile app that finds the cheapest wifi connection or tracking air pollution with your phone. More details are here. - Were partners in the V&A's Digital Design Weekend where participants and audiences were invited to explore digital value, cultural value and 'making' value. See here. ## Recent Events 2014 •*2 July:* **Land Registry** hosted their first hack event at Head Office, Croydon to support developers | - | |-----------------------------| | Knowledge Network in Berlin | | | •Young Rewired State Centre - Festival of Code for under 18s **(Met Office, Ordnance Survey)** •*3 - 4 Sept*: Strange Weather hackathon at Science Gallery, Dublin. Event designed and delivered in partnership - **Met Office** with the Science Gallery and Tapastreet | - | |-------------------------------------------------------------------------------------------| | including Microsoft Research, BBC R&D, Dundee Uni and Exeter College. | | http://productresearch.dundee.ac.uk/hacking-in-front-of-an-audience-met-office-at-the-va/ | •GeoVation Housing Chellenge launched (**Land Registry** and **Ordnance Suvey**) | - | 17 - 19 Oct | : Connected Exeter at | Met Office | HQ, RAMM, Exeter College, Phoenix, Spacex, Exeter FabLab | |-------------------------------------------------------------------------------------------------|---------------|--------------------------|-----------------|-------------------------------------------------------------| | •Various dates - Open Data Masterclasses ( | Land Registry | and | Ordnance Survey | ) | | •24-26 Oct: MozFest, Met Office provided a coupl eof Masterclass sessions as part of the Event. | | | | | •20th to 21st January - **Land Registry** presented at the EuroGeographics International Workshop on Spatial Data and Map Quality in Malta •21st-22nd **Ordnance Survey** supported the Open Data Camp UK ## Still To Come… •17th June Met Office and Enviromental Science to Services Partnership (ESSP) are presenting at "Collabouration Nation" at the the Digital Catapult. This is a sessionfor winners of the "Solving Business Problems with ENviromental Data" competition to present elevator pitches of projects. •From the second quarter of 2015 **Companies House** will be making all its digital information available free of charge and will run an event showcasing the information. In addition they will be running hackathons in June-July (dates not yet settled) which will open up opportunities for entrepreneurs to come up with innovative ways of using the information. ## How Public Data Group Members Fit Into The Pathway Of Support For Data Driven Businesses Getting access to data -Public data is increasingly accessible for example: - Data.Gov.UK brings together access to much of the public sectors data - As well supporting the creation of new data making research data available to users is a core part of the Research Councils' remit and is undertaken in a variety of ways. http://www.rcuk.ac.uk/research/datapolicy/ - Public Data Group members collect refine, manage and distribute data on the nation's companies, property, weather and geography. Catalyst support for using data - There are a range of activities aimed at encouraging and supporting the use of data such as: - InnovateUK's range of catalytically activity including its Small Business Research Initiative (SBRI), Innovation Vouchers and various data focused challenges. - The Digital Catapult is actively engaged with data projects such as its Trusted Data Accelerator and initiatives around health, environmental and personal data. - The Open Data Institute is playing a key role in supporting the development of open data businesses, particularly through its Open Data Challenge Series. - Public Data Group members are actively engaged with encouraging businesses to use their data through hacks and other events. This support will be taken to the next level through the creation of Ordnance Survey's Geospatial Innovation Hub aimed at providing geospatial expertise, guidance and support to developers and opportunities for collaborations with established businesses. Infrastructure for using data - There are also numerous activities to ensure that there is the appropriate infrastructure to allow people to use data effectively such as: - The Hartree Centre's data intensive computing platforms mean they're perfectly placed to develop, test and deploy new software, whilst our shared memory platform - one of the UK's largest - equips us with the capacity to analyse big datasets, whether at rest or streaming in real time. - The Alan Turing Institute will catalyse a major collaboration between research and business and will be a national institute of global significance bringing together advanced mathematics and computing for human benefit across a wide range of sectors. - PDG members are contributing through the Met Office's new High Performance Computer which as one of the most powerful supercomputers in the world when fully installed, will also be a catalyst for regional growth in the South West, supporting collaboration and partnerships between science, business and academia. ## Support For Growing Your Business All of these activities are supported by the wider framework for supporting UK business with much more information and guidance available here: http://www.greatbusiness.gov.uk/ ## Awareness And Usage Question 1: Have you used any of the following in the last 12 months? Almost 86% of responses from those using data were using data from more than one organisation. Question 2: Which one of the following sources provided most of your information on the data sets held by PDG members? | Source of information | Count of responses | % of responses | |-----------------------------------------------|-----------------------|-------------------| | Other - please specify (free text box below) | 58 | 40.56% | | PDG members' websites | 31 | 21.68% | | This survey | 29 | 20.28% | | Data.Gov.UK | 22 | 15.38% | | Government publications | 3 | 2.10% | "Other" included a long list of sources from Local Authorities to specific online commentators e.g. Owen Boswarva. Question 3: Before reading this survey, to what extent were you aware that the vast majority of the data held by the PDG members was available for commercial re-use? | | Count of responses | % of responses | |------------------|-----------------------|-------------------| | Fully aware | 43 | 30.07% | | Not at all aware | 22 | 15.38% | | Somewhat aware | 78 | 54.55% | Question 4: To what extent are you aware that PDG members make large amounts of their data available for free? | | Count of responses | % of responses | |------------------|-----------------------|-------------------| | Fully aware | 44 | 30.77% | | Not at all aware | 24 | 16.78% | | Somewhat aware | 75 | 52.45% | ## Access Question 5: How easy did you find it to identify and use the free data sets?" | | Count of responses | % of responses | |-------------------------------------------------|-----------------------|-------------------| | Not applicable (have never used free data sets) | 9 | 6.29% | | Very easy | 9 | 6.29% | | Somewhat easy | 55 | 38.46% | | Somewhat hard | 36 | 25.17% | | Very hard | 34 | 23.78% | Question 6: How easy did you find it to identify and use those data sets that require payment? | | Count of responses | % of responses | |-----------------------------------------------------|-----------------------|-------------------| | Not applicable (have never used paid for data sets) | 40 | 27.97% | | Very easy | 15 | 10.49% | | Somewhat easy | 38 | 26.57% | | Somewhat hard | 19 | 13.29% | | Very hard | 31 | 21.68% | | | | | Question 7: Please rank from 1-5 any challenges you have faced when using data from a PDG member (figures are average ranking) | | | Fewer than 10 | |------------|-----|------------------| | employees | | | | 10 - 50 | | | | employees | | | | 51 - 250 | | | | employees | | | | 251 - 1000 | | | | employees | | | | More than | | | | 1000 | | | | employees | | | | Licence | 4 | 3.8 | | Price | 4 | 3.5 | | Awareness | 3.8 | 2.7 | | Format | 2.8 | 2.6 | | Skills | 2.8 | 1.9 | | | | | Question 8: Do you consider any of the following factors a requirement/pre-requisite for you to make effective use of data? | Total | % of Total | 10 - 50 | |------------|---------------|------------| | employees | | | | 51 - 250 | | | | employees | | | | 251 - 1000 | | | | employees | | | | | Fewer | | | than 10 | | | | employees | | | | More than | | | | 1000 | | | | employees | | | | 54 | 5 | 7 | | Point | | | | APIs | 24 | 8 | | 21 | 2 | 3 | | Tools | | | | 17 | 4 | 2 | | Data | | | | None | 15 | 11 | ## Developer Licences Question 9: Before reading this survey was you aware that "Developer Licences" (e.g. licences that allow free usage of data in the development phase of a project) were available? | Total % of Total | | |-----------------------|-----| | | | | 10 - 50 | | | employees | | | 51 - 250 | | | employees | | | 251 - 1000 | | | employees | | | Fewer | | | than 10 | | | employees | | | More than | | | 1000 | | | employees | | | No | 63 | | Yes | 20 | Question 10: In your opinion, what is the maximum level of annual commercial income a business should be generating to qualify for a "Developer Licence"? | 51 - 250 | More than | Total | % of | 10 - 50 | |-------------|--------------|----------|---------|------------| | employees | employees | | | | | 251 - 1000 | | | | | | employees | 1000 | Total | | | | | Fewer than | | | | | 10 | | | | | | employees | employees | | | | | More | 51 | 11 | 6 | 1 | | than | | | | | | £50,000 | | | | | | Up to | 2 | 2 | 1 | 0 | | £10,000 | | | | | | Up to | 7 | 2 | 0 | 1 | | £20,000 | | | | | | Up to | 16 | 6 | 2 | 6 | | £5,000 | | | | | | Up to | 7 | 2 | 2 | 0 | | £50,000 | | | | | Question 11: In your opinion, what is the maximum time a Developer Licence should be available for? | | Fewer than | 10 - 50 | 51 - 250 | 251 - 1000 | More than | Total | % of | |-----------|---------------|------------|-------------|---------------|--------------|----------|---------| | 10 | employees | employees | employees | 1000 | Total | | | | employees | employees | | | | | | | | Longer | 60 | 13 | 7 | 1 | 11 | 92 | 64.34% | | than 1 | | | | | | | | | year | | | | | | | | | Up to 1 | 1 | | | 1 | 1 | 3 | 2.10% | | month | | | | | | | | | Up to 1 | 15 | 5 | 2 | 3 | 4 | 29 | 20.28% | | year | | | | | | | | | | 3 | 2 | 2 | 1 | 8 | 5.59% | Up to 3 | | months | | | | | | | | | 7 | 2 | | 1 | 1 | 11 | 7.69% | Up to 6 | | months | | | | | | | | Selected comments: - A clear and succinct license e.g. akin to CC licenses - A developer licence should allow to un-restricted analysis and exploration of the data. - Terms and conditions should be limited to only preventing the use of data in fully published products or service - Any company should be able to get a developer license (even if they're a brand new start up so not VAT registered etc). Developer Licenses should be as simple and flexible as possible. - Cooperative, as required, ie. able to discuss need. Flexibility. - The system really needs to be friendlier to small start-up businesses. - I think the data providers should be allowed to watermark developer data. - When someone applies for a licence, possibly making them aware of other relevant data might be worthwhile. - It needs to cover the use of national data (not small sample) in industry standard format limited to internal non-commercial use. Technical documentation and support would be beneficial. - Should not constrain the developer in terms of quantity or time as it may be necessary to performance test applications with large datasets. - Consider rate limits or other mechanisms to allow developers to develop and test but protect the data. ## Background Information On Who Responded Question 14: What is the size of your organisation? | Organisation size | Count of | |--------------------------|---------------| | responses | | | % of responses | % of total UK | | businesses (for | | | comparison) | | | Fewer than 10 employees | 83 | | 10 - 50 employees | 23 | | 51 - 250 employees | 11 | | 251 - 1000 employees | 8 | | More than 1000 employees | 18 | Question 15: Which category best describes your company's area of business? | Sector | Count of | % of responses | |-----------------------------|-------------|-------------------| | responses | | | | Housing/Real Estate | 38 | 26.57% | | Data/Technology | 27 | 18.88% | | Other | 18 | 12.59% | | Geospatial/mapping | 14 | 9.79% | | Environment and weather | 11 | 7.69% | | Education | 10 | 6.99% | | Business and Legal Services | 8 | 5.59% | | Research and consulting | 7 | 4.90% | | Scientific Research | 7 | 4.90% | | Energy | 1 | 0.70% | | Finance and investment | 1 | 0.70% | | Commitment | Status | Comments | |----------------------------------------------------------------|-------------|------------------| | Making a range of substantial data sets available as Open Data | | | | | | | | Companies House will be making all of their | | | | digital data available free of charge from the | | | | second quarter of 2015. | | | | In 2015 Land Registry intends to develop a | | | | Publication Platform which will provide easy | | | | access to all their existing and future datasets. | | | | In 14/15 Land Registry intend to make the whole | | | | Index Map polygon layer covering England and | | | | Wales available at a cost recovery price and OS | | | | licencing conditions. | | | | Land Registry will release their Price Paid Data | | | | for commercially owned properties for free by | | | | March 2015. | | | | Met Office is adding more data to the DataPoint | | | | API and providing INSPIRE compliant formats | | | | | | | | | | | | In addition it is developing a system to create the | | | | National Archive for the Nations Memory of the | | | | Weather - a collection of the historical | | | | observation data - and a selection of this will be | | | | available as Open Data | | | | Ordnance Survey committed to new | | | | enhancements to their Open Data portfolio | | | | In addition they are working with the | | | | Department for the Environment, Food and | | | | Rural Affairs to provide consultancy, technology | | | | and to enhance public access (through a portal) | | | | to Rights of Way data. | | | | Setting the standard for the quality of UK open data | | | | | | | | Improvements to Linked Data | In progress | CH is working to | | geospatially link their | | | | records. | | | | Ensuring that all PDG data sets available on | | | | Data.Gov.UK have been assessed against the | | | | Open Data Certificate from the Open Data | | | | On track | Further information | |------------------------|---------------------------| | will be provided in | | | coming months. | | | On track | | | On track | Planned for first half of | | the 2015/2016 | | | financial year | | | On track | Planned for first half of | | the 2015/2016 | | | financial year | | | Complete | Real time datafeed of | | last 24 hours Marine | | | Observations now | | | available as Open | | | In progress | Further information | | will be provided in | | | coming months. | | | Exceeded | A package of new open | | data products was | | | announced in February | | | including maps of road | | | and water networks as | | | well as brand new | | | vector map designed | | | to work with latest | | | mobile and web | | | platforms. See | | | here | for | | more details | | | On hold. | Release of Data Fund | | and Breakthrough | | | Fund requests for | | | funding of LAs | | | rejected. | | | Some complete, some | | | in progress | | | CH have undertaken | | | the process for their | | | corporate data and are | | Institute by December 2014. | | Further enhancing support to developers to generate economic growth | | |-------------------------------------------------|-----------------------------------------------------------------------|------------------------------------------| | Review of developer licences | In progress | See above. | | In addition, Ordnance Survey are implementing a | | | | try-before-you-buy scheme for new commercial | | | | partners (3 months royalty free access to | | | | premium data). | | | | | | | | PDG will look to combine and extend existing | | | | challenge programmes | | | | | | | | Each PDG member will offer a user group forum | | | | by | | 2015 ensuring that users have a space to | | discuss issues and access to direct advice. | | | | | | | in discussions with the ODI on how to assess their remaining data. LR have undertaken the certification process. MO have undertaken the certification process (completed by ODI) but not yet published. Rating assessed as Standard with some elements of Expert achieved, OS have not completed this as yet as the focus has been on the new open data releases and licence changes Complete OS are also exploring further options to increase developer access and in March will be removing minimum royalties for all partners Complete/ In progress Joint GeoVation Challenge sponsored by Land Registry and Ordnance Survey was launched on 10 September 2014 In progress CH implemented a developers Hub. LR will launch a forum by June 2015. Met Office User Forum through Google Groups continues to be supported. OS offers three separate forums: OS Open Data, OS Open Space and Public Sector. All data is either available at cost recovery or as open data. Companies House has a range of open data products. These include basic information on companies, that is accessed over 300230 million times a year, to a free bulk accounts data product: ## Free Basic Company Information The Free Company Data Product is a downloadable data snapshot containing basic company data of live companies on the register. CH's free company data product contains basic company data of all live companies on the register in reusable format. The files have been downloaded over 22,000 times since its launch. ## Free Accounts Data Product The accounts data product is a free, downloadable file containing approximately 2.4 million accounts that have been filed digitally with CH (available as iXBRL data as a .html file, or XBRL data as a .xml file). This puts the UK in a world leading position in providing accounts data free of charge. The accounts files contain accounts elements including: - Directors' Report - Auditors Report - Profit and Loss - Balance Sheet - Notes to the Balance Sheet - Footnotes (for micro-entity accounts) iXBRL submissions reference UK GAAP taxonomy and contains 6,654 possible elements, of which a sub-set of minimum tagging list of 1,253 elements has been determined by HMRC.XBRL submissions reference multiple UK GAAP taxonomies, which will have similar numbers of elements. ## Uri The URI is a service using a simple Uniform Resource Identifier (URI) for each company on the register. The URI is a unique web address that represents the company (using the 'business.data.gov.uk' domain); and will return basic company details for that company (as per the fields above for the free basic information product). It has been accessed over 460 million times. ## Mobile App The CH mobile app allows free access to basic company details, with additional features such as statistics and frequently viewed companies. It has been downloaded by approximately 135,000 users. All information recorded on the Register is available through the Open Register albeit at a cost per title. Commercial Services are available which provide products and services, using Register data in a useable and accessible format. The existing open data offer includes: Price paid data - dating back to 1995 in excel, csv and linked data formats for records. This means that there are available more than 19 million definitive records of monthly residential property price data (sold for market value). Available in txt , csv file or linked data. The INSPIRE dataset - which depicts the legal extent of all Freehold properties in England and Wales is one of the most popular and frequently downloaded datasets on Data.Gov.UK. House Price Index - a comparison of the average house price today with what it was in January 1995, with the index set then at 100. It includes figures at national, regional, county and London borough level. Available as the monthly pdf doc, background data in csv/excel and linked data. Background Data Tables for download PDF doc Search the House Price Index (beta) Transaction Data - provides information about the number and types of applications that have been completed by conveyancers. The 1862 Act Register - contain scanned images of Land Registry's historical 1862 Act Register. The original records are in 272 volumes, containing a mix of handwritten or typed pages made from parchment, waxed linen or paper, and printed documents and deed plans. The digital version is an exact replica of the original paper version. The Met Office has a large range of data available under the Open Government Licence. In broad terms it can be described as the data behind that which is published on the Met Office Public Website. Data which isn't Open is made available either through Met Office Standard Terms and Conditions or for research purposes. DataPoint is the Met Office API which makes available both daily and 3 hourly forecasts, updated hourly, for over 5,000 locations, as open data. The data is provided in a format that is suitable for application developers. Over the last six months there have been around 40 million data requests with an average daily data download of around 54 GB. Examples of the data accessible through DataPoint include: layer - a map overlay for the UK showing a forecast of total cloud cover for the UK. The underpinning model data used to create the Public Weather Service outputs is available through the ECOMET Wholesale Catalogue. A range of models are made available from Global atmospheric to Northwest Shelf Seas. This data is primarily used by competing weather service providers both UK and overseas. A range of Historic data is currently available at no charge for private or research use through the Library or from a dedicated sales team for commercial use. The UK academic community have access to both archived model data and observations through an arrangement with BADC (British Atmospheric Data Centre), free of charge. The Ordnance Survey offers an extensive suite of commercial products which are available for free for developmental use in either a limited form, for a limited duration or under limits to their use. OS Open Data already provides over 10 quality assured, continuously updated products, from postcodes and boundaries to digital maps, providing a one-stop shop to start using their products such as: Ordnance Survey also provides an API (OS OpenSpace) which enables developers to embed Ordnance Survey mapping in their solution. This has over 10,000 registered users and over 2,000 active sites running. Further products have been announced, including the new OS OpenMap which will provide a new street level dataset designed to be the most detailed open data mapping product available for Great Britain, as well as an Open Water Network and Improved Gazetteer, and will be available at the end of March 2015. More details on these, and other improvements, can be found here.
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FRAMEWORK OF STANDARDS FOR ARCHIVES Our new framework of standards, incorporating suggestions made by consultation respondents, has now been drawn together. This framework of standards, as proposed in our consultation paper, will inform and support The National Archives' (TNA) new standard for records repositories, which is currently being prepared by TNA inspection and advisory staff. The majority of the following standards were proposed in The National Archives' November 2003 consultation paper on the framework of standards. Others were proposed for inclusion by one or more respondents to that consultation paper. This list will now be referred to as "The National Archives' Framework of Standards". A secondary list of best practice guidance follows the list of standards below. This second list contains publications which, while not actually standards in themselves, offer guidance which TNA recognises as being of particular value to all those concerned with the wellbeing of archives. Both the standards list and the best practice guidance list will remain dynamic as we pilot-test and evaluate the framework this year. We will continue to take account of suggestions and comments raised by consultation respondents and other colleagues, and look forward to a dialogue with the archival community as we make progress with this work. THE NATIONAL ARCHIVES' FRAMEWORK OF STANDARDS Records Storage BS 5454:2000 Recommendations for the Storage and Exhibition of Archival Documents Public Access National Council on Archives: Public Services Quality Group, A Standard for Access to Archives (2003) final endorsed edition (work in progress) Cataloguing International Council on Archives, General International Standard of Archival Description [ISAD (G)], 2nd edition, 1999 International Council on Archives, International Standard Archival Authority for Corporate Bodies, Persons and Families, (ISAAR (CPF)), 1996 (currently being revised: new edition expected 2004) National Council on Archives, Rules for the Construction of Personal, Place and Corporate Names, 1997 BS 6879 / ISO 3166-2: 1998, Codes for the representation of names of countries and their subdivisions, Part 2 Conservation and preservation BS 4971:2002, Repair and allied processes for the conservation of documents - Recommendations BS 1153: Recommendations for processing and storage of silver-gelatine-type microfilm Records Management BS ISO 15489-1: 2001, *Information & documentation - records management* ISO 9706: 1994 Information and documentation - Paper for documents - requirements for permanence Electronic Records BS 4783 Storage, transportation and maintenance of magnetic media in data processing and information storage Parts 1-8, 1988-94. BEST PRACTICE GUIDANCE General Standing Conference on Archives in Museums, Code of practice on archives for museums and galleries in the United Kingdom, 2002 National Preservation Office preservation guidance leaflets, available at http://www.bl.uk/services/npo/publicationsleaf.html Museums and Galleries Commission, Standards in the museum care of photographic collections, 1996 Records Storage Museums, Libraries and Archives Council, Benchmarks in Collections Care: a self-assessment checklist, 2002 Kitching C, Edgar H and Milford I, Archival documents: guide to the interpretation of BS 5454:2000, PD 0024, 2001 Jones M and Beagrie N, Preservation management of digital materials: a handbook, Resource and The British Library, 2001 BS ISO 10214: 1991 Processed photographic materials: filing enclosures for storage Public Access Museums, Libraries and Archives Council, *Inspiring Learning for All*, 2004 Museums, Libraries and Archives Council, *The Disability Portfolio*, 2003 Tim Padfield, *Copyright for Archivists and Users of Archives*, 2nd edition 2004 Cabinet Office, *Charter Mark Standard*, http://www.chartermark.gov.uk/apply/CharterMarkStandard.pdf Cataloguing International Council on Archives, General International Standard of Archival Description [ISAD (G)], 1994. International Council on Archives, International Standard Archival Authority for Corporate Bodies, Persons and Families, (ISAAR (CPF)), 1996 (currently being revised: new edition expected 2004). National Council on Archives, Rules for the Construction of Personal, Place and Corporate Names, 1997 Conservation and preservation Pickford C, Rhys-Lewis J and Weber J, Preservation and Conservation: a guide to policy and practices in the preservation of archives, Best Practice Guideline 4, Society of Archivists, 1997 Records Management Public Record Office, Standards for the management of Government records (Introduction, File Creation, Tracking Records, Disposal Scheduling, Guidelines on the Planning of Records Appraisal, Retention, Storage of semi- Current Records), 1998-99. British Standards Institution, *'Records Management -A Code of Practice'* (work in progress). Electronic Records PD 0008:1999 - A code of practice for Legal Admissibility and Evidential Weight of Information Stored Electronically Public Record Office, Management, appraisal and preservation of electronic records (Vol.1 Principles; Vol.2 Procedures), 2nd editions, 1999. Missenden Consulting, *Archives in the Digital Age: a study for Resource*, Resource, 2002 Staffing Investors in People UK, *Investors in People: The Standard*, 2004
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# July 2017 HM Revenue and Customs statement on publication of The National Archives' Information Management Assessment report. The National Archives carried out an Information Management reassessment of HMRC in July 2016. The final report is published today. HMRC was honest and transparent in its approach to this assessment, which recognises our 'good practice' in the way we protect our information, particularly the security of our customer records. We acknowledge that the report has identified areas where we can improve further. We have published an action plan to address these, notably on information asset governance and information risk management. Our action plan will ensure that we continue to manage and protect our information appropriately, which is critical to HMRC's role of collecting the money that pays for the UK's public services. We look forward to ongoing collaboration with The National Archives so we continue to improve the way that we manage our information.
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## Advisory C Ouncil On National Records A Nd Archives Date: 18 November 2019 Time: 11:00-16:30 Venue: Talks Room, The National Archives, Kew Chair: Sir Terence Etherton, Master of the Rolls Minutes: Anne Hardy, Secretary to the Council Members: Mr Trevor Woolley, Deputy Chair Ms Hillary Bauer, (Deputy Chair of the Forum) Mr Michael Smyth Ms Lesley Ferguson Dr Helen Forde Lady Moira Andrews Ms Liz Copper Mr John Wood Dr Peter Gooderham Ms Jeannette Strickland Mr Martin Howard Professor Phillip Johnson Professor Leon Litvack Ms Helene Pantelli Mr David Rossington Mr Martin Uden Non-members: TNA: Mr Jeff James, Chief Executive and Keeper Ms Lucy Fletcher, Director for Government Mr Sam Whaley, Head of Strategy and CEO's Office Ms Victoria D avis, Senior Access Manager Ms Helen Potter, H ead of the Freedom of Information Centre Ms Anne Hardy, Secretary to the Advisory Council DCMS: Mr Charles Alexander, Lead Non-Executive Director. MR's Office: Mr Samuel Allan, Office of the Master of the Rolls SUMMARY O F ACTIONS Actions agreed at the meeting Item 2: ACTION: any member who is interested in taking part in the Working Group should contact the Deputy Chair. Item 3: ACTION: MOD are to be asked to provide a written update for February. The possibility of inviting them to the May meeting should also be left open. Item 4: ACTION: members asked that copies of the memorandum and checklists be provided to them in accessible form. Item 5: ACTION: it was agreed that a TNA pa per on the history of the Forum should be circulated to the wider membership. Item 7 ACTION: the Code of Practice to be included as an item on the agenda for the February 2020 meeting. ACTION: an invitation to be extended to the Deputy Chair to attend a meeting of the Code of Practice Steering Group. ACTION: TNA t o update the retention application/ update templates to reflect the revised retention criteria. ACTION: the Secretary to make the arrangements for the April file audit exercise. ACTION: files which are potentially of interest for audit purposes should be flagged at the meeting where the relevant schedule entry is discussed. ACTION: TNA t o consider how best to feed back the audit findings to departments Item 9 ACTION: new members to be phased into the FOI Panel process by the Secretary. ## Item 10 ACTION: TNA t o provide the Chair with information on the location of the 43 Places of Deposit. Item 11 ACTION: The Deputy Chair and the Secretary will discuss further the idea that, as part of its continuous improvement work, t he Council invites feedback from departments. ACTION: The Deputy Chair agreed to check the ICO website for Section 27 guidance and to circulate it. ACTION: any members who are interested in obtaining or renewing Developed Vetting Security Clearance should inform the Secretary. 1. Welcome, introductions, apologies and declarations of conflicts of interest 1.1 The Chair welcomed the attendees, including six new members, who were attending their first meeting. 1.2 There were apologies from Mr Stephen Hawker, a new member. 1.3 The Chair asked members to declare any conflicts of interest which they had identified in relation to the business of the meeting. 1.4 The following recusals apply: 1.4.1 Ms Liz Copper is an employee of the BBC, so will not comment on BBC matters. 1.4.2 Mr Michael Smyth is unable to comment on matters relating to the Chagos Islands and Diego Garcia. 2. Minutes and matters arising There were no formal minutes to approve, as the September meeting was a training session. A sum mary of the July minutes has been uploaded to the website. Item 2.1 - Wash-up following the September training session The Chair invited members to reflect on the September training session, which included presentations from ICO, FCO and the TNA D igital team. Members thought that the sessions went well and were informative, although there were issues with timing, which meant that the session overran. Paper 2.2 - Action Log and Paper 2.2.1 - Action Log Updates The Chair went through the most recent updates to the action log. A nu mber of actions were considered as specific agenda items. The most significant of the finalised actions are the completion of the process of recruitment and the induction of seven new Council members, six of whom were able to attend the November meeting. The Chair also noted that: 2.2.1 now that the new members have been appointed, the Council is ready to take on responsibility for the public interest test for FOI requests under Section 65 of FOIA, although the details have yet to be agreed between DCMS an d the Cabinet Office. It was noted that currently the Council has no role in considering FOI requests which engage Sections 23 and 24 of FOIA, which should be reviewed as part of the revision of the Code of Practice. 2.2.2 the Chair would write to the new Secretary of State once he or she is appointed following the general election about the proposed delegation to the Council under section 66 of FOIA. 2.3.3 there would be merit in reviving the Working Group and anyone interested in joining was invited to contact the Deputy Chair. ACTION: any member who is interested in taking part in the Working Group should contact the Deputy Chair. ## 3. Access To Records Issues 3.1 Four representatives from MOD attended in person to present on two ongoing issues - the NDA/ AWE records, which have been t he subject of previous appearances at the Council, and the Service Personnel Records (which include the related issue of the Guards papers, which was previously discussed at the July meeting). 3.2 TNA had also clarified the status of "access under review" records. A note had been provided to the Chair and Deputy Chair in the first instance. FOI requests for these records could be handled under Section 65 or 66 of FOIA. If the former, there would be no requirement for the Council to consider the public interest in release through panels under such time as the Council took on such responsibility in relation to Section 65 cases more generally. 3.3 Overall, both members and TNA staff were content with the proposals, although there are residual concerns about timescales. 3.4 Members had also sought further information about the legal and practical effects of records being temporarily categorised as "access under review" status. TNA noted that a note had been provided to the Chair and Deputy Chair, in the first instance 3.5 Members also reiterated the need for the media group to be prepared to handle any media interest, as per the action log. ACTION: MOD are to be asked to provide a written update for February. The possibility of inviting them to the May meeting should also be left open. 3.6 The department had sought retentions in respect of both the guards and the service personnel records. ## 4. Access To Records 4.1 There were no further recusals. General 4.2 A sche dule of closure applications, together with a schedule of retention applications, was sent to members prior to the meeting. Members were asked to raise any queries within 10 days. 4.3 The Senior Access Manager collated the queries and a list of them was circulated with the papers for this meeting, with responses being provided, where possible. 4.4 At the meeting, members were asked if they were content with the responses provided, whether in written form or orally. Where a response had not been provided, or members remained unhappy, the queries were carried forward. 4.5 The Council formally approved the acceptance of schedules seen outside the meeting, with the exception of any queries which were brought to the meeting. ## Outstanding Queries 4.6 Paper 4.1 Queries outstanding from remote schedule The Council was content to approve the applications on the basis of the clarification or additional information provided by the departments, as more fully described in the Annex to these minutes. 4.7 Paper 4.2 - Queries on Closure and Retention Schedules (July 2019) The Council was content to approve the applications on the basis of the clarification or additional information provided by the departments, as more fully described in the Annex to these minutes. ## 4.8 Paper 4.3 - Queries On Closure And Retention Schedules (November And September 2019) The Council was content to approve the applications on the basis of the clarification or additional information provided by the departments, as more fully described in the Annex to these minutes. 4.9 Other discussion points ACTION: members asked that copies of the memorandum and checklists be provided to them in accessible form. 5. Forum Update (NB: this item took place after item 6 as the meeting was running slightly late) 5.1 The Chair noted that he had chaired the full Forum meeting on 22 September 2019. The meeting was combined with the September training session, so three Council members who are not also members of the Forum attended. The meeting focussed on a new strategy and action plan for the Forum, which will be discussed further at its next meeting, which is to be held on 11 December. The need to do a skills audit of members was also identified and this is in hand. It has also been suggested that members convene by teleconference if necessary between meetings. 5.2 The Chair noted that it was a useful session and that he had learned more about the Forum and its role as a sub-committee of the Council. ACTION: it was agreed that a TNA paper on the history of the Forum should be circulated to the wider membership. 5.3 The Deputy Chair of the Forum then presented her update. She noted that role of the Council in advising the Historical Manuscripts Commission on Acceptance in Lieu cases. She said the Forum would like to be more actively involved in issues of concern to the archives and academic communities relating to non-government archives. 5.4 It was noted that TNA also undertakes a lot of activity in these areas and that it sometimes does so "behind the scenes". 5.5 In addition, a symposium to celebrate HMC 150 took place on 14 October. The Deputy Chair of the Forum acted as a panel member for this. LUNCH was provided. ## 6. Mps Presentation 6.1 MPS representatives attended in person further to their July retention application, as the Council had requested further information. 6.2 The departmental attendees described ongoing efforts to address the review backlog. This largely consists of paper files, but there is some digital material. 6.3 The department noted that it was happy to provide regular updates to the Council. 6.4 It also noted that the problem is finite, as MPS records produced after March 2000 are no longer public records for the purposes of the Public Records Act 1958. DECISION: it was noted that the current retentions expire in 2020, so members asked that the department provide a written update in May 2020. ## 7. Administrative Matters This section dealt with ongoing administrative and process matters which have arisen, largely from the ongoing work of the Working Group, but also from the September training session. ## Item 7.1.1 - Section 46 Code Of Practice Review The Director for Government Audience gave a short oral update on progress on the Code of Practice review, for information. She explained the background to and purpose of the Code and noted that the last review was in 2009, so an update is needed, not least to reflect the move to digital records. The process is taking some time, as there is an obligation to consult with statutory stakeholders, such as Cabinet Office and the Office of the Information Commissioner (ICO). It was also agreed that an invitation would be extended to the Deputy Chair to attend a meeting of the Steering Group which was planned for January. A copy of the near-final draft of the Code should be available after this meeting and will be circulated to members. ACTION: the Code of Practice to be included as an item on the agenda for the February 2020 meeting. ACTION: an invitation to be extended to the Deputy Chair to attend a meeting of the Steering Group. The following three items were briefly introduced by Ms Lucy Fletcher. They had all previously been presented to the Council so were approved. The need to update the templates to reflect the revised retention criteria was noted, though. ACTION: TNA to update the retention application/ update templates to reflect the revised retention criteria. ## Paper 7.1.2 - Revised Retention Criteria This is a proposed retirement of criteria 3.5 and 7. ## Paper 7.1.3A - Revised Retention Application Template This is a further update on a proposed simplification and standardisation by TNA of the template used by departments when making retention applications. Innovations include a new system of drop-down menu options; a new section on "context" and more information on required timescales. ## Paper 7.1.3B - Revised Update Template This is a proposed simplification and standardisation by TNA of the template used by departments when providing updates. This was specifically requested by members, to include a red/amber/ green status; an indication of milestones achieved to date and a detailed justification for any application of over three years' duration. A suggestion that departments should have an additional field where they could propose an update date was rejected, after discussion. ## Paper 7.1.4 - The Journey Of The File This paper summarised a presentation which was due to be included in the September training session. However, this had to be deferred because of timing issues. Members thought it a useful and insightful document and recommended that this it be included in TNA standard guidance, if possible. ## Paper 7.1.5 - October File Audit Report A panel of three Council members attended at TNA premises on 31 October to conduct a review of transferred files. This followed on from a similar process in April. The purpose of these sessions is to compare the closure schedule entries for various items with the closed extract(s) which are eventually transferred to TNA and to check for anomalies. A member of the review panel presented the findings and there was a discussion as to how feedback on these could be provided to TNA and departments. All participants agreed that it had been a useful exercise. They noted that: - Some derogatory comments did not in practice seem a good basis for withholding information. However, it was thought that this issue had been addressed to an extent by the current practice of members asking for details of the particular comments relied on. - There was one instance where there seemed to be a cataloguing error. - On one file, some comments were erroneously cited as legal opinion. They also noted some practical points, such as the need to select a number of files for review, due to the risk that selected items might be unavailable. A suggestion that audits could perhaps be held quarterly was rejected on resourcing grounds. ACTION: the Secretary to make the arrangements for the April file audit exercise. ACTION: files which are potentially of interest for audit purposes should be flagged at the meeting where the relevant schedule entry is discussed. ACTION: TNA to consider how best to feed back the audit findings to departments. ## Paper 7.1.6 - Ico Decision An FOI request relating to the Denning papers which the Council received last year went to Internal Review and was subsequently the subject of an appeal to the ICO. The decision is now available. It upholds the Council's position, although a couple of technical points were raised and the delay in responding were noted. No further action is to be taken. The Secretary confirmed that the Council's processes have been reviewed as a result of this request and are now more streamlined. ## 8. Departmental Retention Requests Twenty-eight papers were submitted for consideration at the meeting. It was therefore agreed, in line with the process used at the February session, that that the applications from Arm's Length Bodies should be dealt with out of committee, with members noting in advance any papers which they would specifically like to discuss during the session and the rest to go forward to the Secretary of State. The Council considered papers from departments relating to the retention of records. In addition, a number of departments had provided updates, further to requests from members made at previous meetings. The Council's decisions made in respect of each paper are noted below. Any resulting approval recommendations then go forward to the Secretary of State. ACTION: The Head of Governance will write to departments to notify them of the Council's recommendations, including any which will go forward to the Secretary of State with regard to their retention requests. There were applications for retentions of between one and six years from the following departments:  Department for Business, Energy and Industrial Strategy  Department for the Environment, Food and Rural Affairs  Department for International Relations  Department for Transport  Department of Work and Pensions  Department for Education  Foreign and Commonwealth Office  Department of Health and Social Care  HM Treasury  Home Office  Ministry for Housing Communities and Local Government  Ministry of Justice  Northern Ireland Office  Cabinet Office There were applications for retentions of between two and three years from the following arm's length bodies:  Crown Prosecution Service  Medicines and Healthcare products Regulatory Agency  Competition and Markets Authority Updates were received from the following departments:  The Charity Commission  HM Revenue and Customs ## 9. Foi Panel Update - Paper 9 9.1 The Head of the FOI Centre gave an overview of the issues and work undertaken by panels. She also presented the most recent service statistics. She also noted three recent issues: redaction of records; application of Section 27 and application of Section 38. She highlighted work to update FOI guidance, notably on Section 40. The Section 38 guidance is in progress and should be available shortly. 9.2 The continued high volume of cases was also noted, as were ongoing staffing issues. 9.3 There is an intention to phase the new members into the Panel process on the basis that there will be one of them per panel, and that they will not act as the Panel Chair until they have gained some experience of the process. ACTION: new members to be phased into the FOI Panel process by the Secretary. ## 10. Ceo'S Update - Paper 9 10.1 TNA's CEO gave his update on current issues and ongoing matters. He noted progress with the National Archives Trust and the planned relaunch of the Discovering Collections, Discovering Communities conference, as well as new grant funding which has been announced. He also covered the HMC 150 celebrations and his tour of regional archives. The Chair asked if he could be provided with information on the location of the 43 Places of Deposit. ACTION: TNA to provide the Chair with information on the location of the 43 Places of Deposit. 10.2 He also noted the work of TNA's legislation team, which as part of the CEO's role as the Queen's Printer, is currently ensuring that the online legal database legislation.gov.uk is preparing all the legislation ready for Brexit. The Chair noted his admiration for the work of this team. ## 11. Any Other Business 11.1 It was agreed that any of the new (or indeed the existing) members who are interested in obtaining or renewing Developed Vetting Security Clearance should inform the Secretary. ACTION: any members who are interested in obtaining or renewing Developed Vetting Security Clearance should inform the Secretary. 11.2 When asked for feedback on their first meeting, new members said that there had been a lot of business to get through and a lot to take in, but that it had been a very interesting session. They thought that the Schedules process was perhaps a bit unwieldy (although longerstanding members noted that the process had actually become more streamlined and less paper-intensive than it had been previously). The new members also noted their approval of the new remuneration arrangements. It was suggested that as part of its continuous improvement work, the Council could invite feedback from stakeholders. The Deputy Chair and the Secretary agreed to discuss this further. ACTION: the Deputy Chair and the Secretary will discuss further the idea that, as part of its continuous improvement work, the Council invites feedback from departments. It was noted that there is guidance on Section 27 (which had come up a few times in discussions) on the ICO website. ACTION: The Deputy Chair agreed to check the ICO website for Section 27 guidance and to circulate it. 11.3 There being no further business, the meeting was closed. Date of Next Meeting: The next meeting of the Council was to be held on: **10 February 2020,** at TNA premises.
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# Employment Appeal Tribunal Rolls Building, 7 Rolls Buildings, Fetter Lane, London Ec4A 1Nl At the Tribunal On 29 July 2019 Judgment handed down on 18 October 2019 # Before The Honourable Mr Justice Choudhury (President) (Sitting Alone) MR COLLERIDGE BESSONG APPELLANT PENNINE CARE NHS FOUNDATION TRUST RESPONDENT ## Judgment (Appeal & Cross-Appeal) ## Appearances | For the Appellant | Ms Karon Monaghan | |--------------------------------|----------------------| | (One of Her Majesty's Counsel) | | | Mr Nathaniel Caiden | | | (of Counsel) | | | Instructed by: | | | Legal Services | | | Royal College of Nursing | | | Chesham House | | | St Georges Square | | | Bolton BL1 2HB | | | For the Respondent | Ms Joanne Connolly | | (of Counsel) | | | (Written submissions only) | | | Instructed by: | | | Hempsons Solicitors | | | 16th Floor City Tower | | | Piccadilly Plaza | | | Manchester M1 4BT | | | | | ## Summary Race Discrimination - Harassment, Third-Party Harassment The issue in this appeal is whether s.26 (1) of the **Equality Act 2010** ("the 2010 Act") should be interpreted so as to impose liability on an employer for third-party harassment against employees. The Claimant worked as a mental health nurse and was assaulted by a patient on racial grounds. Whilst the Tribunal found that as a result of various failures on the part of the employer, including a failure to ensure that all incidents of racial abuse were reported, the Claimant had been indirectly discriminated against, it rejected the Claimant's claim of harassment because the employer's failings were not themselves related to race. On appeal, the Claimant argued that s.26(1) of the 2010 Act should be construed in accordance with Directive 2000/43/EC ("the Race Directive") under which it is sufficient for liability to arise where the act of harassment "takes place" without any requirement that the employer's failings themselves had to be related to race. Held: Dismissing the appeal, that on a proper construction of the Race Directive there is a requirement for the unwanted act (in this case, the employer's failings) to be related to race and the words "takes place" in Article 2(3) of the Race Directive do not give rise to the interpretation for which the Claimant contends. The EAT is in any event bound by the decision of the Court of Appeal in **Unite the Union v Nailard** [2019] ICR 28, which confirms that there is currently no explicit liability under the 2010 Act on an employer for failing to prevent thirdparty harassment. ## The Honourable Mr Justice Choudhury A 1. The issue in this appeal is whether s.26 (1) of the **Equality Act 2010** ("the 2010 Act") should be interpreted so as to impose liability on an employer for acts of harassment against its employees by third parties where the employer has failed to prevent and/or protect an employee against such harassment, and where such failure by the employer is not itself related to race. For the purposes of this judgment, I shall refer to such harassment as "third-party harassment". 2. The appeal is brought by the Claimant in the proceedings below. He is represented by Ms Monaghan QC and Mr Caiden. The Respondent NHS trust was not represented by Counsel at the hearing before me. Instead, the Respondent relied upon written submissions prepared by Ms Connolly of Counsel, who did appear on behalf of the Respondent before the Employment Tribunal ("the Tribunal"). ## E Factual Background 3. The Respondent provides mental health services including a secure, residential unit for adult men who are the subject of a treatment order under s.3 of the **Mental Health Act 1987**. The Claimant was employed by the Respondent at the unit as a registered mental health nurse. The Claimant is Black and African. 4. On 7 April 2017, the Claimant was subject to a serious assault by a patient ("Patient A"). Patient A threw about 8 punches at the Claimant and held a pen as a weapon. The assault was accompanied by racist abuse including Patient A saying, "You fucking black I'm going to stab you now". 5. Although the Claimant managed to fend Patient A off, he sustained significant facial swelling and redness and had to go to hospital. The assault was reported to the police and a record of the assault was made by the Trust. An incident report form about the assault was completed. It made no mention of the racist element of the assault. 6. Patient A, the Tribunal found, had a history of racist behaviour towards black members of staff. An incident on the night before the assault in question involved Patient A asking, "Why it was all black people working in the ward?". 7. The Claimant commenced proceedings in the Tribunal against the Respondent on 16 August 2017. He claimed direct race discrimination, indirect race discrimination and harassment. The direct discrimination complaint involved an allegation that the Respondent had failed to take steps to counter the threat posed by Patient A on 7 April 2017 and that the Claimant was exposed to racial abuse from patients without redress. The particular ways in which the Respondent was said to have failed to provide protection included failing to employ an adequate number of staff, failing to provide adequate training, and a failure to redeploy the Claimant to other roles. The claim of indirect discrimination involved three matters relied upon as provisions, criteria or practices ("PCPs") which were said to be discriminatory. The principal PCP for present purposes was that the Respondent had failed to ensure that all staff reported each and every incident of racial abuse by patients on an incident reporting form. This was described by the Tribunal as "the incident reporting failing". The claim of harassment was initially based on the failures on the part of the Respondent to take these steps relied upon in the claim of direct discrimination. However, at the hearing before the Tribunal, it was argued by the Claimant that the incident reporting failing should also be considered to be an act of harassment through inaction. The Tribunal accepted that argument. No point is taken against the Tribunal's approach in this regard. 8. The Claimant's claim of indirect race discrimination succeeded in relation to the incident reporting failing. As to this matter, the Tribunal made the following findings: "151. It was clear that the policy was that all incidents of racial abuse should be the subject of an incident report. So much was evident from the MVA training pack at page 540, from the evidence of Mr Heath, and from the definition of an incident at page 363 which included any incident which could have resulted in mental injury. The categories of incident reporting available via menus on the electronic form included "verbal abuse to staff" and a potential sub-cause was "racism". 152. Equally, it was clear that not every incident of racial abuse was reported using the incident report system. The grievance reached that conclusion (page 318). It was evident from staff interviews that there were more instances of racial abuse than were formally reported. The recommendations included that there be a review and that steps should be taken to ensure that all staff knew they should report such matters. C 153. Indeed, Mr Liffen accepted not only that staff were not reporting such matters but also that the comments made by patient A at the community meeting on 6 April 2017 ought to have been the subject of an incident report if the policy were applied strictly. 154. The Tribunal unanimously concluded that a perception had formed amongst many black staff that reporting every single racist incident was pointless. The consequence was that the incident report system fell into disrepute in that respect… D 155. Further, we concluded that there were steps which the Respondent should have taken to reinforce the message to staff that they should do an incident report after every such incident. The failure to take those steps contributed to the negative perception held by many black staff about the value of incident reporting…" 9. The Tribunal then went on to make findings as to the steps which should have been taken. These included ensuring that patients were made aware that racist incidents were unacceptable, reinforcing that message in various respects, completing an incident report every time a racist comment was made irrespective of how it came to their attention, providing clear feedback to F individuals once it was made, conducting a staff survey, and focusing on racist abuse in staff training. 10. In determining the effect of the failure to take such steps, the Tribunal held as follows: "156. Of course, the failure to take such steps to encourage incident reporting would be immaterial unless it contributed to the claimant's exposure to racial abuse and physical violence from patient A on 7 April 2017. The Respondent's case was that the gaps in the incident reporting system were not material because those incidents of racist abuse were recorded in other ways. They would go in the nursing notes and then be fed into the monthly CTM, and thereby form part of the patient risk assessment and any behaviour management plan. Further, the Respondent suggested that given the patient population, some level of racist comment was unavoidable. 157. Although we recognised that the absence of an incident report did not mean that racial abuse went unrecorded, we were satisfied unanimously that the failure to create a culture in which all such incidents were formally reported in that way contributed to an environment in which racial abuse from patients was more likely to occur. There was a perception among some staff that it was simply part of the job and had to be tolerated. That made it more likely that patients would not be challenged over racist comments and abuse. At a corporate level the absence of incident reports on every occasion meant that the risk of verbal racist abuse was under-appreciated and therefore not sufficiently prioritised as a risk to be addressed. At ward level the confidence of staff to challenge such behaviour was impaired by the perception that management were not taking the issue as seriously as they should…" 11. The Tribunal went on to consider whether a practice of universal reporting of racist incidents would have made any difference to the situation with which the Claimant was confronted on 7 April 2017. The Tribunal concluded that it would have done: see paragraph 159. At paragraph 162, the Tribunal concluded as follows: 162. For those reasons the Tribunal was unanimously satisfied that the Respondent had failed to take sufficient steps in relation to the proper reporting of racist abuse, and that this contributed significantly to the situation in which staff perceived themselves as unsupported in relation to such matters. A proper approach to this could have made a difference to the exposure of the claimant to the events of 7 April 2017. 12. Having made those findings, the Tribunal went on to consider whether the incident reporting failing give rise to any breach under **the 2010 Act**. The Tribunal considered the claim of harassment first. It found that the incident reporting failing represented unwanted conduct on the part of the Respondent. However, the Tribunal did not accept that such conduct (in the form of inaction) was "related to" race so as to bring it within the scope of s.26 (1) of **the 2010 Act**: ## Related To Race F 167. The Tribunal then considered whether the incident reporting failing related to race. It is clear (see Nailard paragraph 97) that the words "related to" were intended to effect a change to the previous formulation of "on the grounds of" race. The test is broader than the causation test for direct discrimination where the protected characteristic has to have a material influence on the mental processes of the person taking action or failing to take action. 168. However, equally it would be an error of law (unless Mr Caiden is correct in his contention about the direct effect of the Directive - see below) for the Tribunal to assume that conduct is related to race simply because the actions of the third parties (in this case, the patients) were themselves harassment related to race. That approach would have been permissible under the now-repealed third-party harassment provisions of the Equality Act but they were not in force at the time of this incident. 169. It appeared from [Unite the Union v Nailard [2017] ICR 121], however, that there is still a requirement that the employer's conduct/inaction is itself related to the protected characteristic, as per Conteh. The claimant's success in [Sheffield City Council v Norouzi [2011] IRLR 897] was a result of a concession by the Respondent about the meaning of the Directive (based on the EOC Case), a concession about which the EAT had its doubts. Nailard was the most recent authority and we preferred to follow it rather than the approach agreed by the parties in Norouzi. As a result we rejected Mr Caiden's argument that the Directive had direct effect so as to make the Respondent liable for racial harassment by patients. We therefore considered whether the incident reporting failure by the Respondent could be said to be related to race. ## A B 170. It seemed to us that to make that finding would be to distort the meaning of section 26, even recognising that it is a formulation wider than "because of" (or "on the grounds of" as in [Conteh v Parking Partners Ltd [2011] ICR 341]). We rejected the contention that this was treatment "because of race" (see below). Nevertheless in his written submission Mr Caiden invited us to conclude that "given the scale of the issue and the Respondent burying its head in the sand there must have been some relationship with the claimant's race". He based that on a suggestion that such a scale of sexual assaults, touching and language would have been addressed differently. We rejected that argument. It was merely supposition. There was nothing in the Respondent's failure to ensure universal reporting of racist incidents which was related to race other than the subject matter of the failure. On that basis the harassment complaint failed." 13. The claim of direct discrimination therefore failed because the Tribunal declined to draw the inference that the incident reporting failure was because of race, either consciously or subconsciously. It found that the fact that the abuse was racial in nature played no part in the mental processes of management in failing to ensure that such matters were properly reported on the incident reporting system. 14. As stated above, the claim of indirect discrimination did succeed. The Tribunal was satisfied that the incident reporting failure "was at least in part a consequence of the failure by the Respondent to take adequate steps to ensure that this was done." The Tribunal also found that non-white British members of staff are much more likely to be subjected to racial abuse than white British staff, and that the failure to ensure universal incident reporting helped to create an offensive and humiliating environment for non-white staff in which they felt unsupported and F racist behaviour by patients became more likely. That constituted a disadvantage for non-white staff and one which was suffered by the Claimant as well. On that basis the Tribunal found that the ingredients of s.19 of **the 2010 Act** were satisfied. The question of remedy was adjourned to a later date. ## G Legal Provisions 15. Section 26 of **the 2010 Act**, so far as relevant, provides: "(1) A person (A) harasses another (B) if - (a) A engages in unwanted conduct related to a relevant protected characteristic, and (b) the conduct has the purpose or effect of - (i) violating B's dignity, or (ii) creating an intimidating, hostile, degrading, humiliating or offensive environment for B. … (4) In deciding whether conduct has the effect referred to in subsection (1)(b), each of the following must be taken into account - (a) the perception of B; (b) the other circumstances of the case; (c) whether it is reasonable for the conduct to have that effect. (5) The relevant protected characteristics are - … race; …" 16. Section 40 of **the 2010 Act** deals with harassment against employees and applicants. It provides: "(1) An employer (A) must not, in relation to employment by A, harass a person (B)— (a) who is an employee of A's; (b) who has applied to A for employment." 17. That is the version of s.40 that has been in force since 1 October 2013. On that date, subsections (2), (3) and (4) of s.40 were repealed by the coming into force of the **Enterprise and** Regulatory Reform Act 2013 ("the 2013 Act"). Those subsections dealt with third-party harassment. It is relevant to note what those provisions said. I shall refer to them as "the old s.40 provisions": "(2) The circumstances in which A is to be treated as harassing B under subsection (1) include those where— (a) a third party harasses B in the course of B's employment, and (b) A failed to take such steps as would have been reasonably practicable to prevent the third party from doing so. (3) Subsection (2) does not apply unless A knows that B has been harassed in the course of B's employment on at least two other occasions by a third party; and it does not matter whether the third party is the same or a different person on each occasion. (4) A third party is a person other than— (a) A, or (b) an employee of A's" 18. The legislative history of these provisions is explained by the Court of Appeal in Unite the Union v Nailard [2018] EWCA Civ 1203. I set out the explanation in **Nailard** in full as Ms Monaghan seeks to argue, as will become apparent below, that the Court of Appeal in **Nailard** was wrong: "Section 26 53.In the earliest versions of the discrimination legislation there was no distinct proscription of harassment. Cases of what we would now regard as harassment were brought as cases of ordinary direct discrimination. The fit with the legislative language was awkward, and some difficult caselaw was generated. However, an amended version of the EU Equal Treatment Directive (EU/2002/73 EC), promulgated in 2002, required member states to proscribe "harassment", which was defined in the Directive as "where unwanted conduct related to the sex of a person occurs with the purpose or effect of violating the dignity of a person, and of creating an intimidating, hostile, degrading, humiliating or offensive environment [my emphasis]". 54.That requirement was sought to be implemented in 2005 by secondary legislation which inserted an express prohibition on harassment - section 4A - into the Sex Discrimination Act 1975. (Similar amendments were made to the legislation relating to other protected characteristics.) Section 4A essentially tracked the Directive, save that it used the formulation "on the ground of her sex" - that is, the same language as in the definition of direct discrimination - rather than "related to sex". 55.The Equal Opportunities Commission believed that the amendment legislation failed in that respect - and in several others - to conform to the requirements of the Directive. It brought judicial review proceedings. In Equal Opportunities Commission v Secretary of State for Trade & Industry [2007] EWHC 483 (Admin), [2007] ICR 1234, ("the EOC Case") Burton J upheld the Commission's challenge. We are only concerned with two of the grounds of challenge, which I take in turn. 56.First, the Commission argued, and Burton J accepted, that the Directive's formulation of "related to … sex" proscribed not only harassment which was "caused by" the claimant's sex but also harassment which was "associated with" it: see paras. 6-28 of his judgment. Burton J illustrated the distinction between the two types of case, at paras. 10-11 (p. 1242-3), by accepting three examples taken from the case-law by counsel for the Commission (Dinah Rose QC), namely: - where an RAF NCO had used offensive and obscene language in front of a group of male and female staff but which was peculiarly offensive to the women (Brumfitt v Ministry of Defence [2004] UKEAT 1004/03, [2005] IRLR 4); - where the claimant had been unfairly treated by a manager who was jealous of her sexual relationship with a colleague (B v A [2007] UKEAT 0450/06); - where a manager "barged into" a female toilet but would equally have barged into a male toilet (adapted from Kettle Produce Ltd v Ward [2006] UKEATS 0016/06/0811). Those were all cases where the harassment would be "associated" with the complainant's sex but not "caused by" it, in the sense of it forming any part of the actor's motivation. The Commission contended that that type of case was not caught by the formulation in section 4A "on the grounds of sex". Counsel for the Secretary of State (David Pannick QC) argued that it was, if necessary applying a Marleasing approach to construction. Burton J was doubtful about whether that was so, but he held that in any event it was important that the legislation was drafted in a way that put the matter beyond doubt: see paras. 59-63 of his judgment (pp. 1257-8). In the summary of the relevant part of his decision at para. 63 (i) he required section 4A to be "recast so as to eliminate the issue of causation". 57.Secondly, the Commission contended that the Directive required member states to provide for employers to be liable in cases where they failed to take reasonable steps to protect employees against harassment by third parties - labelled as "third party liability"[5]. However in her oral submissions Ms Rose retreated from that position. She is recorded by Burton J at para. 40 of his judgment (p. 1250H) as acknowledging that: "… there is nothing explicit, or even arguably implicit, in any of the Articles requiring a Member State to impose vicarious liability on an employer, or indeed liability for negligent failure to take steps, such as were expressly found by the House of Lords in Pearce not to exist in the present discrimination legislation". ## B C (The reference to Pearce is to the decision of the House of Lords which I consider at para. 88 below.) Her submissions proceeded on the basis that, even if there was no such requirement in the Directive, the Secretary of State himself had accepted that in some circumstances third party liability might be appropriate - see paras. 36 and 37 of the judgment (pp. 1249-50). Her argument was that the language of "on the grounds that" precluded such an outcome, but that the problem could be resolved by "adopting an associative rather than causative approach" which she was already contending for on other grounds. As I read his judgment, Burton J accepted that that was so, and the effect of his decision to require the adoption of "associative" language gave Ms Rose what she was asking for. But that was not in itself the reason for adopting that construction, and in para. 63 of his judgment, where he gives his final decision, he does not expressly refer to the third party liability point (see p. 1258B). 58.In response to the decision in the EOC Case the Secretary of State, exercising his powers under the European Communities Act 1972, made the Sex Discrimination (Amendment of Legislation) Regulations 2008, which took effect from 6 April 2008. So far as relevant for present purposes the Regulations did two things: (1) They amended the definition of harassment section 4A of the 1975 Act so as to substitute the "related to" formulation used in the Directive. That formulation was then, as we have seen, carried over into the 2010 Act. (2) They inserted into section 6, which proscribed discrimination and harassment in employment, a new sub-section (2B) dealing with third party liability. This was in substantially the same terms as section 40 (2)-(4) of the 2010 Act, which I set out at para. 59 below. ## E Section 40 59.As originally enacted, section 40 had three further sub-sections, as follows: "(2) The circumstances in which A is to be treated as harassing B under subsection (1) include those where— (a) a third party harasses B in the course of B's employment, and (b) A failed to take such steps as would have been reasonably practicable to prevent the third party from doing so. (3) Subsection (2) does not apply unless A knows that B has been harassed in the course of B's employment on at least two other occasions by a third party; and it does not matter whether the third party is the same or a different person on each occasion. (4) A third party is a person other than— (a) A, or (b) an employee of A's." As will be seen, those sub-sections were designed to impose liability on employers who had failed to take reasonable steps to prevent their employees being harassed by third parties. 60.However by section 65 of the Enterprise and Regulatory Reform Act 2013 sub-sections (2)-(4) were repealed, and there is now no explicit liability on an employer for failing to prevent third party harassment." 19. The following points, relevant to this appeal, may be drawn from that analysis: a. An express prohibition on harassment was introduced into domestic legislation in 2005 following the promulgation of the **Equal Treatment Directive 2002/73/EC** (OJ 2002 L269, p.15). b. The domestic provisions - s.4A of the **Sex Discrimination Act 1975** - in defining harassment, used the formulation of "on the grounds of" instead of "related to" as in the Directive; c. The failure to use the "related to" formulation was challenged in R (Equal Opportunities Commission) v Secretary of State for Trade and Industry [2007] ICR 1234 ("**the EOC Case**"); d. Burton J in **the EOC Case** decided that s.4A of the 1975 Act should be "recast" so as to eliminate the issue of causation. Thus, an act which was associated with a person's gender would be caught; e. Whilst the EOC had also argued that the Equal Treatment Directive required Member States to impose liability on employers for third-party harassment, it was accepted that there is "*nothing explicit, or even arguably implicit*" in that Directive requiring that; f. Liability for third-party harassment was not the reason that Burton J required s.4A of the 1975 Act to be recast; g. In response to the decision in **the EOC Case** the Secretary of State introduced amendments to the domestic legislation which defined harassment by reference to the "related to" formulation used in the Equal Treatment Directive and which inserted new provisions prohibiting third-party harassment h. Those third-party harassment provisions were carried over to **the 2010 Act** s.40(2), (3) and (4): i. However, those subsections were repealed by the coming into force of the 2013 Act with the effect that there is now no explicit liability on an employer for failing to prevent third-party harassment. 20. "Discrimination" for the purposes of **the 2010 Act** includes indirect discrimination: see s.28 to **the 2010 Act**. By s.39(2) of **the 2010 Act** an employer must not discriminate against an employee by subjecting the employee to a "detriment". Section 212(1) of **the 2010 Act** provides that, " "detriment" does not … include conduct which amounts to harassment". 21. Directive 2000/43/EC ("the **Race Directive**") provides, so far as relevant, as follows: "Article 2 Concept of discrimination 1 For the purposes of this Directive, the principle of equal treatment shall mean that there shall be no direct or indirect discrimination based on racial or ethnic origin. 2 For the purposes of paragraph 1: a. direct discrimination shall be taken to occur where one person is treated less favourably than another is has been more would be treated in a comparable situation on grounds of racial or ethnic origin. b. indirect discrimination shall be taken to occur where an apparently neutral provision, criterion or practice would put persons of racial or ethnic origin at a particular disadvantage compared with other persons, unless that provision, criterion or practice is objectively justified by a legitimate aim and the means of achieving that aim are appropriate and necessary. 3 Harassment shall be deemed to be discrimination within the meaning of paragraph 1, when an unwanted conduct related to racial or ethnic origin takes place with the purpose or effect of violating the dignity of a person and of creating an intimidating, hostile, degrading, humiliating or offensive environment. In this context, the concept of harassment may be defined in accordance with the national laws and practice the Member States. … Article 3 Scope 1 Within the limits of the powers conferred upon the Community, this directive shall apply to all persons, as regards both public and private sectors, including public bodies, in relation to: a. conditions for access to employment, … b. access to all types and to all levels of vocational guidance, vocational training, advanced vocational and retraining, including practical work experience; c. employment and working conditions, including dismissals and pay; d. membership of and involvement in an organisation of workers or employers, or any organisation whose members carry on a particular profession, including the benefits provided for by such organisations; e. social protection, including social security and healthcare; f. social advantages; g. education; h. access to and supply of goods and services which are available to the public, including housing 22. It can be seen from the provisions of Article 3 of the **Race Directive** that it is intended to apply in a wide range of situations and not just in the employment sphere. 23. Ms Monaghan also referred me to the Charter of Fundamental Rights of the European Union ("**the Charter**"). Article 21 of **the Charter** establishes non-discrimination as one of those rights. So far as relevant, it provides: "Article 21 Non-discrimination 1.Any discrimination based on any ground such as sex, race, colour, ethnic or social origin, genetic features, language, religion or belief, political or any other opinion, membership of a national minority, property, birth, disability, age or sexual orientation shall be prohibited…" 24. Article 31 of **the Charter** provides: "Every worker has the right to working conditions which respect his or her health, safety and dignity." 25. Finally, Article 47 of **the Charter** deals with the right to an effective remedy and to a fair trial. So far as relevant, it provides that: "Everyone whose rights and freedoms guaranteed by the law of the Union are violated has the right to an effective remedy before a Tribunal in compliance with the conditions laid down in this Article…" ## Grounds Of Appeal F 26. The Claimant lodged his appeal against the Tribunal's judgment on 24 August 2018. There are three grounds of appeal: a. Ground 1: The Tribunal misinterpreted s.26 (1) of **the 2010 Act** in requiring that the employer's conduct/inaction must itself be related to race in a complaint of third-party harassment. b. Ground 2: The Tribunal erred in concluding that the Claimant was not entitled to rely H directly on the Race **Directive**. c. Ground 3: The Tribunal erred in concluding that it was bound to follow and/or in deciding to follow the decision of the EAT in **Unite the Union v Nailard** [2017] ICR 121 ("**Nailard EAT**") 27. Permission to proceed with the appeal on all three grounds was granted on the sift by then President, Simler J (as she then was). The Respondent resists that appeal and cross-appeals on two grounds which arise only in the event that the Claimant succeeds in his appeal. The grounds of cross-appeal are that: a. Cross Appeal Ground 1: The Tribunal erred in law in finding that the relevant conduct of the Respondent had the proscribed effect described in s.26 (1) (b) of **the 2010 Act**. b. Cross Appeal Ground 2: If the appeal succeeds, by virtue of the definition of "detriment" in s.212 of **the 2010 Act**, the Tribunal's finding of indirect discrimination was erroneous in law and should be set aside. ## E The Issues In This Appeal 28. These have been succinctly summarised by Ms Monaghan in her skeleton argument as follows: a. Is the appeal on third-party harassment academic in light of the Tribunal's conclusion on the indirect discrimination claim? b. Does the **Race Directive** require Member States to outlaw third-party harassment where the harassment was foreseeable and preventable, without a requirement that the employer's failures were themselves "related to" race? c. If the **Race Directive** covers third-party harassment, can s.26 (1) **the 2010 Act** be interpreted to give effect to this? ## d. If s.26 (1) of **the 2010 Act** cannot be read and given effect to conform to the requirements of the **Race Directive**, does the relevant provision of the **Race Directive** have direct effect? e. Was the Tribunal, and now the EAT, bound by the decision of the Court of Appeal in Unite the Union v Nailard [2018] EWCA Civ 1203; [2019] ICR 28 ("**Nailard CA**")? f. If the Claimant succeeds in his appeal, does the Respondent's conduct have the proscribed effect in s.26 (1)(b) of **the 2010 Act**? g. If the Claimant succeeds in his appeal was the Tribunal's conclusion on indirect discrimination erroneous in law by reason of s.212 of **the 2010 Act** such that it should be set aside? 29. I shall deal with each issue in turn. ## Is The Appeal Academic? E Submissions 30. The Respondent submits that as the Claimant's success in his indirect discrimination claim would entitle him, in effect, to the same remedy to which he would have been entitled had he succeeded in his harassment claim, this appeal is rendered academic. The Respondent further submits that the Claimant has a declaration that he has been discriminated against and he can seek recommendations in respect of his indirect discrimination claim in the same way that he could for his claim of harassment had he succeeded in that. The Respondent acknowledges that whilst the absence of an intention to discriminate may lead to a different approach to the award of compensation in the indirect discrimination claim, the Tribunal is not precluded from making a compensation order, albeit that it must first consider whether to make a declaration and/or an appropriate recommendation. In this regard, the Respondent highlights the fact that it is not seeking to adduce any evidence on intention at the remedy hearing and states that it would not object to the Tribunal making a compensation order. In the circumstances, submits the Respondent, the outcome of the appeal as between the Claimant and the Respondent is academic. 31. Ms Monaghan submits that the appeal is not academic given that the level of compensation may differ depending on the heads of claim which succeed. The finding of harassment may be of real importance to the Claimant and others in his position since an individual subject to harassment might regard the declaratory relief that follows as a vindication of the position. The need to consider intention in the claim of indirect discrimination means that compensation might not be awarded at all for that claim. Ms Monaghan submits that even if the appeal were considered academic in respect of the potential remedy, the EAT should exercise its discretion to entertain academic appeals where they raise a point of general public importance and it is in the public interest to do so. She cites in support of that proposition the cases of Waterman v AIT group UKEAT/0358/05/DM at [5] and [11] and Rolls-Royce plc v Unite the Union [2010] ICR 1 at [49] to [58]. In this case, submits Ms Monaghan, the appeal does raise a point of general public importance as the EAT is being asked to construe a statutory provision derived from a Directive of widespread importance and affecting a large number of employees. ## Discussion F 32. In my judgment, this appeal is not academic. I say that for the following reasons: a. Although the Claimant has succeeded in his claim of indirect discrimination, the claim of harassment is a very different head of claim which might give rise to a different (and possibly greater) level of compensation, if successful, than under the claim of indirect discrimination. As Ms Monaghan submits, correctly in my view, the more serious nature of the claim of harassment - which involves the creation of a hostile working environment that could well give rise to losses in respect of injured feelings and aggravated damages - would not be the same as or achievable under a claim of indirect discrimination. The situation here is quite different from that in the case of IMI Yorkshire Imperial Ltd v Olender [1982] ICR 69, upon which the Respondent relied. In that case, it was established at the outset of the hearing that compensation had been paid to the employees bringing the appeal, that they had been reinstated and that whatever the outcome of the appeal they would not lose their jobs. In that situation the appeal was truly academic as all apparent issues between the parties had been resolved leaving nothing to be determined which could have an effect on the outcome. That is quite different from the situation in this case where the Claimant appeals in respect of a head of claim which could produce quite a different outcome in terms of remedy from the head of claim which did succeed; b. The key difference relevant to remedy in a claim of indirect discrimination is the need to consider intention. It is only if there is an intention to discriminate, albeit indirectly, that the Tribunal can move straight to a consideration of compensation: see s.124(2) of **the 2010 Act**. If, however, the Tribunal is satisfied that the PCP in question was not applied with the intention of discriminating against the Claimant, it must not make an order for compensation unless it first considers whether to make a declaration and/or make an appropriate recommendation within the meaning of s.124(2)(a) or (c) of **the 2010 Act**; see s.124(4) and (5) of **the 2010 Act**. By contrast, if a claim of harassment is made out the Tribunal is not required to consider whether such harassment was intentional before awarding compensation, and nor is it required to consider other remedies first. The Respondent's assurance that it does not seek to produce any evidence on intention does not obviate the need for the Tribunal to consider the point and to go through certain steps which are not required in the harassment claim. These seem to me to be material differences in approach and which mean that the claim of harassment possesses a sufficiently different character to render an appeal in respect of that head of claim substantial and not academic; c. Finally, I agree that the declaratory relief in respect of a claim of harassment may have a certain value for the Claimant in that it may provide a degree of vindication which would not arise in a claim of indirect discrimination. As Ms Monaghan puts it, the application of a "racially neutral PCP" is very different from, and arguably less culpable than, the creation of a hostile working environment. 33. Even if I am wrong about that and the appeal is considered to be academic, the EAT could, in the exercise of its discretion, proceed to hear the appeal. The Court of Appeal in Hamnett v Essex County Council [2017] 1 WLR 1155 (in the context of an appeal relating to traffic regulation orders) considered the scope of that discretion: "33. In a case involving a public authority and raising a question of public law, the court has a discretion to hear the appeal, even if by the time it is heard, there is no longer an issue to be decided which will directly affect the rights and obligations of the parties as between themselves: see R v Secretary of State for the Home Department, Ex p Salem [1999] 1 AC 450 , 456, per Lord Slynn of Hadley. However, as Lord Slynn went on to emphasise, at p 457, that discretion was to be exercised with caution: "and appeals which are academic … should not be heard unless there is a good reason in the public interest for doing so, as for example (but only by way of example) when a discrete point of statutory construction arises which does not involve detailed consideration of facts and where a large number of similar cases exist or are anticipated so that the issue will most likely need to be resolved in the near future." 34. Just how narrow this discretion is, was underlined in this court in Hutcheson v Popdog Ltd (News Group Newspapers Ltd, third party) (Practice Note) [2012] 1 WLR 782 . Lord Neuberger of Abbotsbury MR said, at para 12, that "the mere fact" that a projected appeal may raise a point or points of significance did not mean that "it should be allowed to proceed where are no longer real issues in the proceedings as between the parties." Lord Neuberger formulated the following propositions, at para 15: "Both the cases and general principle seem to suggest that, save in exceptional circumstances, three requirements have to be satisfied before an appeal, which is academic as between the parties, may (and I mean 'may') be allowed to proceed: (i) the court is satisfied that the appeal would raise a point of some general importance; (ii) the Respondent to the appeal agrees to it proceeding, or is at least completely indemnified on costs and is not otherwise inappropriately prejudiced; (iii) the court is satisfied that both sides of the argument will be fully and properly ventilated." Even taking into account that Hutcheson did not involve a public authority or a question of public law, the caution needed before exercising the discretion to proceed in a case which has become academic is readily apparent. (Emphasis Added) 34. Had I considered that the appeal was academic, the position as regards the three requirements identified above which must be satisfied before an academic appeal may proceed is, in my judgment, as follows: a. The issue in relation to third party harassment is one of some general importance. It affects the scope of an important protection under **the 2010 Act** and could potentially affect many employees and employers. The Respondent contends that the matters raised are not ones of general importance because relevant protection is already afforded by the provisions on indirect discrimination. For reasons set out above, I do not consider that, in the circumstances, the protection against indirect discrimination affords a sufficiently equivalent remedy. b. Although the Respondent does not consent to the appeal proceeding, it is not at any realistic risk on costs (given the limited costs jurisdiction in the Tribunal and the EAT); c. Whilst it is not ideal that the Respondent was unrepresented at the hearing before me, I did have the benefit of very full written submissions from Ms Connolly on each of the issues I have to consider. In these circumstances, I am satisfied that both sides of the argument were properly put. 35. Taking all of those matters into account, and approaching the matter with due caution, it seems to me that this is an appropriate matter to proceed to hearing. I should mention that in coming to this conclusion I have not relied upon the fact that permission to proceed was granted on the sift. The argument that the appeal was academic was not before the then President and it would not be appropriate simply to have adopted the then President's view that the matter was one of general public importance without considering the question afresh and in light of the Respondent's submissions. Does the Race Directive require Member States to outlaw third-party harassment where the harassment was foreseeable and preventable, without a requirement that the employer's failures were themselves "related to" race? 36. Ms Monaghan submits that the **Race Directive** and the other **EU Equality Directives** (2000/78/EC, **2006/54/EC** and **2004/113/EC**) require Member States to outlaw third-party harassment in certain circumstances; in particular where an employer has failed to protect or prevent his/her employee from foreseeable harassment by a third-party. She submits that the Race Directive does not require that the employer's inaction in such circumstances be related to any protected characteristic. 37. The first point made by Ms Monaghan in support of that submission is that Article 2(3) of the **Race Directive** treats harassment as discrimination when "unwanted conduct related to racial or ethnic origin takes place with the purpose or effect of violating the dignity of a person and of creating an intimidating, hostile, degrading, humiliating or offensive environment". Ms Monaghan submits that the underlined words indicate that there is no requirement that the employer itself engages in conduct "*related to*" race and that it is sufficient that such conduct, by a third party, merely 'takes place' or occurs. That interpretation is said to be supported by the terms of Article 3(1) which does not require that the acts of racial harassment are themselves done by the employer but requires only that the acts are done within the sphere of occupation and working conditions: Article 3(1)(a) and (c). 38. In my judgment there are several difficulties with Ms Monaghan's submission: a. It does not accord with the natural and ordinary meaning of the words used in Article 2(3) of the **Race Directive**. On a natural reading of that Article, the mischief to which it is directed is unwanted conduct relating to racial or ethnic origin. That is the conduct which is deemed by Article 2(3) to be discrimination within the meaning of Article 2(1). Conduct must be both unwanted and related to race before it can be deemed to amount to discrimination. There is nothing in the Article to suggest that some other act (or failure to act) that is either not unwanted or related to race, could also be deemed discriminatory. b. Whilst it is correct that Article 2(3) does not stipulate that the unwanted conduct related to racial or ethnic origin must be conduct by the employer, that is merely because this broadly applicable directive seeks to adopt a definition for harassment that can be applied in a number of contexts, only one of which is employment. As is made clear by Article 3, the **Race Directive** is intended to apply to "*all persons*" in relation to the various sectors and areas identified, the third of which is employment and working conditions. The absence, therefore, of a specific perpetrator in the definition is unsurprising, and does not, in my judgment, mean that the intention was that liability should arise whenever unwanted conduct related to racial or ethnic origin takes place or occurs (it being accepted by Ms Monaghan that "occurs" is a synonym for "takes place"). c. Indeed, if Ms Monaghan's submission were correct then there would be no reason to impose liability for third-party harassment only on employers. Similar liability would have to be imposed in respect of persons in the spheres of education, social security and access to the supply of goods and services, irrespective of whether they would be in any position to take preventative steps in respect of potential harassment. Insofar as it is said that liability for third-party harassment should only extend to situations where a person is in a position to prevent or take steps to prevent such conduct, there is nothing in the **Race Directive**, or indeed any of the other Directives, which provides ## any basis for drawing such a distinction between the different categories of persons falling within the scope of the measure. d. The fact that "occurs" is a synonym for "takes place" means that, if Ms Monaghan's argument is correct, then the same liability for acts of third parties would arise in respect of both direct and indirect discrimination. Article 2(2)(a) provides that direct discrimination "shall be taken to occur" when one person is treated less favourably than another. As with the definition of harassment, the definition of direct discrimination does not identify a specific perpetrator of the less favourable treatment. In particular, it does not say that direct discrimination shall be taken to occur where one person is treated "by the employer" less favourably another. It cannot realistically be suggested that the intended effect of the **Race Directive** was to impose liability on employers and other persons for acts of direct discrimination by third parties. Ms Monaghan argues that the necessary causal relationship between the less favourable treatment and the protected characteristic dictated by the use of the formulation "on grounds of" in Article 2(2)(a) means that such liability could not arise in those circumstances, and that it is the broader "related to" formulation in Article 2(3) which permits of the liability for which Ms Monaghan contends. In my judgment, it is difficult to see why, on the one hand, the causative relationship means that the innocent employer is excluded from liability for the acts of a third party, whereas the associative relationship under Article 2(3) on the other means that he is not; in both Article 2(2) and Article 2(3), it would be sufficient, if Ms Monaghan is correct, for liability to arise simply because the act of discrimination or harassment has occurred or taken place. In neither case would it matter whether any associative or causative relationship between the conduct and the employer exists. There is nothing in any of the case law to which I was taken to suggest that such a broad interpretation of this Directive is apt. e. The result of Ms Monaghan's submission, if correct, would be to create a situation of strict liability for employers whereby they would be liable for acts of third-party harassment irrespective of any motivational element relating to race on its part. Ms Monaghan contends that the foreseeability of unwanted conduct would put the employer on notice of the potential for harassment to take place and that this would place some limit on the scope of the liability. However, even if that were not the case, and the position is one of strict liability, Ms Monaghan submits that the right under Article 31 of **the Charter** to working conditions that respect health, safety and dignity means that a position of strict liability is justified. I do not accept that submission. As I have already said above, Article 2(3) of the **Race Directive** seeks to prohibit unwanted conduct that is related to race; it does not have the effect of imposing liability when there is no such relationship between the conduct in question (in this case, by a failure to act or take steps) and race. If the intention had been to impose strict liability then one might have expected to see some explicit reference to such an aim in the preamble to, or elsewhere in, the **Race Directive**. However, there is no such reference. 39. I agree, therefore, with the Respondent's submission that the Claimant seeks to place far more weight on the phrase "takes place" than it can bear. 40. Ms Monaghan sought to derive support for her broad interpretation of Article 2(3) of the Race Directive by reference to several other EU provisions and international instruments, chief amongst which was **the Charter**. Reliance is placed, in particular, upon Article 31 of **the Charter** which provides that: ## A "Every worker has the right to working conditions which respect his or her health, safety and dignity" 41. In my judgment, the right to fair and just working conditions under Article 31 of the Charter cannot be read as requiring Member States to impose liability on employers for third- B party harassment. Article 21 of **the Charter** deals specifically with "non-discrimination" and prohibits discrimination "based on" any ground such as sex, race etc. It seems clear therefore that insofar as it deals with non-discrimination, **the Charter**, in using the formulation of "based on", which is narrower in scope than the "related to" formulation, was not seeking to impose liability C for discrimination where there is no link between the act complained of and the relevant protected characteristic. The right in respect of working conditions under Article 31 of **the Charter** is a distinct right which cannot, in my judgment, be relied upon to expand the scope of another right D dealt with under an entirely separate provision of **the Charter**. It follows that there is nothing in the Charter which justifies the imposition on employers of strict liability for third-party harassment. E 42. Directive 2006/54 on the implementation of the principle of equal opportunities and equal treatment of men and women in matters of employment and occupation (recast) ("the Recast F Directive") upon which the Claimant also relies does not take the position further. Article 2(1) of the **Recast Directive** defines harassment as "where unwanted conduct related to the sex of a person occurs with the purpose or effect of violating the dignity of a person, and of creating an G intimidating, hostile, degrading, humiliating or offensive environment." Recitals (6) and (7) of the Recast Directive provide: H "(6) Harassment and sexual harassment are contrary to the principle of equal treatment between men and women and constitute discrimination on grounds of sex for the purposes of this Directive. These forms of discrimination occur not only in the workplace, but also in the context of access to employment, vocational training and promotion. They should therefore be prohibited and should be subject to effective, proportionate and dissuasive penalties. ## A (7) In this context, employers and those responsible for vocational training should be encouraged to take measures to combat all forms of discrimination on grounds of sex and, in particular, to take preventive measures against harassment and sexual harassment in the workplace and in access to employment, vocational training and promotion, in accordance with national law and practice." 43. The Claimant submits that these recitals reinforce his contention that the **Race Directive**, which is to be read consistently with the other directives dealing with discriminatory conduct, does not require that the employer itself engages in conduct "related to race" in order to be liable for harassment. It is said that the requirement to take preventative action makes it plain that liability for third-party harassment is intended also to be imposed on employers. I do not agree C that the recitals can be construed as having that effect. These recitals appear to me to be directed to the encouragement of the taking of preventative measures by employers, but do not indicate that liability is to be imposed for the failure to take such measures (unless of course such failure is in itself such as to amount to unwanted conduct *relating to* the protected characteristic in D question). 44. I was also referred to the International Labour Organisation's Convention 190 ("the ILO Convention") "on violence and harassment", which was adopted 21 June 2019, but (as at E the date of the hearing) was yet to be ratified by the UK or any other country. Article 4 of the ILO Convention provides that States must adopt: F "…an inclusive, integrated and gender-responsive approach for the prevention and elimination of violence and harassment in the world of work. Such an approach should take into account violence and harassment involving third parties, where applicable, and includes… (c) adopting a comprehensive strategy in order to implement measures to prevent and combat violence and harassment". (Emphasis Added) 45. This express reference to third-party harassment appears to be unique amongst the various G international instruments to which I was referred. Although it has not yet been ratified, Ms Monaghan submits that the contents of **the ILO Convention** form part of the international context to be taken into account by Member States in implementing and applying Directives and indicate that the prevention of third-party harassment is a common aim. I do not agree that this H yet-to-be ratified Convention can legitimately inform the meaning to be given to provisions of the Directives. Until it is ratified, there seems to me to be no particular obligation on any country, or upon the UK in particular, to give the **ILO Convention** any significant weight in construing other instruments. In any event, the terms of Article 4 of **the ILO Convention** merely "*encourage"* the taking of an approach to deal with harassment that "*takes into account"* harassment involving third parties "*where applicable"* and the adoption of a "comprehensive strategy" to implement measures to prevent harassment. It cannot properly be read as imposing or seeking to impose liability on employers where there is a failure to implement such measures as being an act of harassment in itself. 46. I have not so far dealt with the final sentence of Article 2(3) of the **Race Directive**. This provides that "the concept of harassment may be defined in accordance with the national laws and practice of the Member States.". The Respondent contends that the Claimant's interpretation of Article 2(3) ignores this part which gives Member States a degree of flexibility as to how harassment is defined. That flexibility enabled Parliament to adopt a definition of harassment which could in certain circumstances cover third-party harassment (i.e. where an employer's conduct in failing to take steps to prevent harassment by a third party was itself related to race) and that it was not bound to impose liability on the employer where such conduct is unrelated to race. 47. On this aspect I am in agreement with Ms Monaghan that if the **Race Directive**, properly construed, did impose liability on employers for third-party harassment irrespective of any relationship between the employer's conduct and race, the flexibility afforded by the final sentence of Article 2 (3) would not entitle the UK to dilute that liability so as to amount to something different. I have found, however, that the Article 2 (3) of the **Race Directive** does not have the effect contended for by the Claimant. Therefore, any flexibility afforded by that Article H in defining the concept of harassment does not need to be invoked; there is no requirement to ## impose liability on an employer for third-party harassment where the employer's conduct or inaction is unrelated to race. 48. I turn therefore to the next limb of Ms Monaghan's argument which is that the history of the enactment of provisions addressing third-party harassment demonstrates that Parliament intended to outlaw third-party harassment and did so because it considered that it was required to do so by EU law. Considerable reliance is placed here on the decision of Burton J in the EOC Case. The issue of third-party liability is dealt with at paragraphs 36 to 40 of **the EOC Case**: "36. Again the difference between the parties narrowed in the course of the hearing. The Defendant's position was made clear, in a Fact Sheet on harassment published by the Women and Equality Unit of the new Department of Communities and Local Government, in paragraphs 37 and 38 of the Defendant's Summary Grounds and in Mr Pannick's skeleton argument. In the Fact Sheet, published in October 2006, it was stated at page 4: "Nevertheless, it might be argued, on appropriate facts, that an employer should take steps to protect an employee from third-party actions, which provide an offensive working environment for employees, in respect of which the employer might have some degree of control, and in such a case liability might arise if an employer fails to do so. So, on appropriate facts, the harassment provisions in the [1975 Act] might be interpreted so that where an employer knowingly fails to protect an employee from, for example, repetitive harassment by a customer or a supplier, the employer is "subjecting the employee to harassment"." 37. Similar points are made in paragraph 70 of Mr Pannick's skeleton: "Adopting this approach does not necessarily exclude the possibility that an employer could be held liable on appropriate facts for the conduct of, for example, a supplier or customer (or, more accurately, held liable for the violation of dignity or unwelcome working environment brought about by such conduct). It might be the case that an employer could be held liable for failing to take action where there is a continuing course of offensive conduct, which the employer knows of but does nothing to safeguard against. The employer could be responsible for failing to act, albeit not responsible for the third party's actions in themselves. By contrast, fixing an employer with liability arising from a single act by a third party could go too far." 38. Miss Rose's primary submission was that the 1975 Act failed to implement the Directive by imposing third party liability. She accepted however the difficulty of such a submission. She referred, in regard to its general reference to the workplace, to Recital 8 of the Directive, which I have already cited in full at paragraph 16 above, and also to Recital (9): "In this context, employers and those responsible for vocational training should be encouraged to take measures to combat all forms of sexual discrimination and, in particular, to take preventive measures against harassment and sexual harassment in the workplace, in accordance with national legislation and practice." 39. There is an exhortatory Article 1.2.5: "Member States shall encourage, in accordance with national law, collective agreements or practice, employers and those responsible for access to vocational training to take measures to prevent all forms of discrimination on grounds of sex, in particular harassment and sexual harassment at the workplace." 40. She accepted however that there is nothing explicit, or even arguably implicit, in any of the Articles requiring a Member State to impose vicarious liability on an employer, or indeed liability for negligent failure to take steps, such as were expressly found by the House of Lords in Pearce not to exist in the present discrimination legislation. It became apparent in the course of her submissions ## A B C that her real best position was that which she soon adopted, namely that, whereas the position taken by the Defendant, by reference to the passages in the Fact Sheet and the skeleton referred to above, would, at any rate from her point of view arguably, constitute adequate compliance with the Directive, yet on the face of paragraph 4A, as it stands, it is impossible to see how such a result could be achieved. This once again returns me to consideration of the respective arguments under the first aspect above. So long as s4A is to be framed in terms of unwanted conduct engaged in on the ground of her sex by the employer, it seems difficult, if not impossible, to see how an employer could be held liable simply for even knowing failure to take steps to prevent harassment by others. If, by reference to the disapproved authority of De Vere Hotels, it could have been shown that the employers knew of continuing and/or regular objectionable conduct by Mr Manning, and failed to take any steps to prevent it, it could be said that they were thereby themselves indulging in unwanted conduct (including omission) in relation to sex, with the consequent upsetting effect on the claimant waitress. However, it would seem very difficult to be able to say that such knowing failure on their part would amount to unwanted conduct by the employers *on the ground of her sex*. However, the result of adopting the associative rather than causative approach to harassment, either by a purposive and transliterative construction such as is urged by Mr Pannick or by its replacement by wording more compatible with Article 1.2.2, as urged by Miss Rose, would resolve the problem. Hence once again the issue, so far as it survives in the abbreviated form which alone Miss Rose now pursues, is bound up with my conclusion on the first aspect." ## 49. Ms Monaghan submitted that it is clear from the Government's argument in the EOC Case, as set out in paragraph 36 therein, that its position was that some cases of third-party harassment may be made out even where the causative test of "*on the grounds of*" was applicable. It was further submitted that the EOC's concession, set out at paragraph 40 of **the EOC Case**, in which Counsel for the EOC accepted that, "there is nothing explicit, or even arguably implicit, in any of the Articles requiring a Member State to impose vicarious liability on an employer or indeed liability for negligent failure to take steps…", was made in the context of the Government having effectively already conceded that the "*on the grounds of*" formulation was wide enough to encompass third-party harassment. In these circumstances, when the old s.40 provisions were enacted following the decision in **the EOC Case**, that must, submits Ms Monaghan, have been on the basis that that was what EU law already required. 50. I do not accept that submission. As the careful analysis of Underhill LJ in **Nailard CA** demonstrates, the decision in **the EOC Case** was not to the effect that there was any obligation under EU law to change the statutory language in order to provide for third-party liability: see H paragraphs 18 and 19 above. Instead, the introduction of the old s.40 provisions was a matter of Government policy at that time. My conclusions above as to the meaning and effect of Article 2(3) of the **Race Directive**, are to the same effect: there is no obligation to impose liability for third-party harassment on an employer. The fact that the Government chose to impose such liability for the years during which the old s.40 provisions were in force does not mean that the Government was obliged to do so. Furthermore, the fact that the old s.40 provisions were enacted under s.2 of the European Communities Act 1972 act does not assist the Claimant. As provided for by Article 6 of the **Race Directive**: "Member States may introduce or maintain provisions which are more favourable to the protection of the principle of equal treatment than those laid down in the directive." 51. For all of those reasons, the answer to this issue must be that the **Race Directive** does require that an employer's conduct/inaction be itself related to race in order to give rise to any liability for third-party harassment. If the Race Directive covers third-party harassment, can s.26 (1) the 2010 Act be interpreted to give effect to this? 52. Given my conclusions above as to the scope of the **Race Directive**, this question does not arise. However, even if it did, it would have been my view that s.26 of **the 2010 Act** is not susceptible to an interpretative exercise that would encompass liability for third-party harassment. As set out by Underhill LJ in **Nailard CA**, the "negligent failure to prevent another's discriminatory acts is a very different kind of animal from liability for one's own: it requires careful definition, and I would expect it to be covered by explicit provision." To extend the scope of s.26 through an interpretative exercise conducted by the Court would, in my judgment, lead to uncertainty and/or exceed the constraints on such an exercise: see Vodafone 2 v Revenue and Customs Commissioners [2009] EWCA Civ 446, [2010] Ch 77: A equipped to evaluate: see the Ghaidan case, per Lord Nicholls, at para 33; per Lord Rodger, at para 115; per Arden LJ in the IDT Card Services case, at para 113". 53. Where liability for third-party conduct is to be introduced, there would need to be careful consideration of the precise circumstances in which such liability should arise: for example, questions as to the kind of conduct that could give rise to such liability, the number of instances of such conduct, whether or not the employer needs to be aware of such conduct and the kind of steps that the employer would be expected to take to prevent such conduct, may need to be addressed in designing an appropriate scheme of liability. In this regard, it is noteworthy that the C old s.40 provisions did address some of these questions. In particular, they provided that liability could not be imposed unless the employer "knows that the woman has been subject to harassment in the course of her employment on at least two other occasions by a third party": see subsection (2)(c) of the old s.40 provisions. The strict liability scheme contended for by Ms Monaghan would go considerably further even than the careful scheme previously devised by the Government as it would impose liability for the first incident of harassment by a third party. I see no reasonable basis on which any Court could deploy an interpretative exercise to develop such a scheme. Such a scheme would, in any event, also be contrary to the "*grain*" of the legislative scheme as it would seek to impose liability on persons whose thought processes contained no motivational element F relating to race. It is well-established that liability for discrimination will depend on the reason why an employer has acted in the way that it did, and that that will generally involve an analysis of the mental processes of the relevant decision maker: see **CLFIS (UK) Ltd v Reynolds** [2015] EWCA Civ 439. 54. It was also submitted by the Claimant that the "related to" formulation can be read sufficiently broadly to capture third-party harassment. However, s.26 provides that "A person (A) harasses another (B) if A engages in unwanted conduct related to a relevant protected characteristic…" That means that unwanted conduct unrelated to a protected characteristic will not amount to harassment. It is difficult to see how even a broad construction of this provision could impose liability on an employer whose actions are found not to have been related to a protected characteristic (as was the case here). ## B If S.26(1) Of The 2010 Act Cannot Be Read And Given Effect To Conform To The Requirements Of The Race Directive, Does The Relevant Provision Of The Race Directive Have Direct Effect? 55. In light of the conclusion that the **Race Directive** does not impose the liability contended for by the Claimant, its direct effect does not assist him as there is no such liability for him to directly enforce against any emanation of the state. ## D Was The Tribunal, And Now The Eat, Bound By The Decision Of The Court Of Appeal In Nailard Ca? 56. The answer to this question is clearly, "Yes". For the reasons set out above, there is nothing in **Nailard CA** which can be said to be inconsistent with, or that amounts to a failure to apply, EU Law. ## F Conclusion G 57. Liability for third-party harassment in certain circumstances has much to commend it. However, desirable as such liability might be, in the absence, as I have found, of any obligation under EU law to impose such liability, it cannot be said that the Tribunal erred in law in concluding as it did. 58. For all of the reasons set out above, the Claimant's grounds of appeal do not succeed and this appeal is dismissed. In the circumstances, the Respondent's Conditional Grounds of Cross- Appeal (and therefore issues (f) and (g) in paragraph 28 above) do not need to be considered. ## B Leap-Frog Certificate 59. The Claimant seeks a leapfrog certificate under s.37ZA, of the Employment Tribunals Act 1996 so that the matter can proceed directly to the Supreme Court. 60. Section 37ZA of the 1996 Act, so far as relevant, provides: "(1) If the Appeal Tribunal is satisfied that - (2) The conditions in subsection (4) or (5) are fulfilled in relation to the Appeal Tribunals decision or order in any proceedings, and (3) As regards that decision or order, a sufficient case for an appeal to the Supreme Court has been made out to justify an application under section 37ZB, the appeal Tribunal may grant a certificate to that effect. … (4) The conditions in this subsection are that a point of law of general public importance is involved in the decision or order of the Appeal Tribunal and that point of law is - a. A point of law that - i. relates wholly or mainly to the construction of an enactment or statutory instrument, and ii. has been fully argued in the proceedings and fully considered in the judgment of the Appeal Tribunal in the proceedings, or b. a point of law - i. in respect of which the Appeal Tribunal is bound by a decision of the Court of appeal or the Sabine code in previous proceedings, and ii. was fully considered in the judgements given by the Court of Appeal or, as the case may be, the Supreme Court in those previous proceedings. …" 61. Section 37ZC provides for certain exclusions to s.37ZA. The relevant one for present purposes is that contained in subsection (3): "(3) Where no appeal would lie to the Court of Appeal from the decision or order of the Appeal Tribunal except with the leave or permission of the Appeal Tribunal or the Court of Appeal, no certificate may be granted under section 37ZA in respect of a decision or order of the Appeal ## A Tribunal Unless It Appears To The Appeal Tribunal That It Would Be A Proper Case For Granting Leave Or Permission To Appeal To The Court Of Appeal. 62. It is not contended that the decision in this case relates to a matter of national importance within the meaning of s.37ZA(5). Therefore, the issue is whether the conditions in s.37ZA(4) are satisfied, whether a sufficient case has been made out for an appeal to the Supreme Court and whether any of the exclusions under s.37ZC apply. 63. As to s.37ZA(4), there are two alternative conditions that may be satisfied. The first is C that a point of law of general public importance is involved, that point of law relates wholly or mainly to the construction of an enactment or statutory instrument and the point is one which has been fully argued in proceedings and fully considered in the judgment of the EAT. As to this condition, I have already found, under issue one above, that the appeal does involve a point of law of general public importance. Furthermore, the point of law is one that is mainly related to the construction of an enactment - namely the **Race Directive** - and it has been fully argued before me (albeit by way of written submissions on the part of the Respondent). However, I am not satisfied that a sufficient case has been made out to justify an appeal to the Supreme Court. The Claimant's principal argument is based on a construction of the words "take place" in Article 2(3) of the **Race Directive**. I have rejected the Claimant's interpretation of that phrase for the F reasons set out above. I do not consider that the Claimant's construction would have any real prospect of success if it were to be considered by a higher court. That alone is sufficient to regard this appeal as not satisfying the requirements of s.37ZA(1)(b). The discretion to grant a certificate does not therefore arise. I also note that the argument based on the words "takes place" was not G one considered by the Court of Appeal in **Nailard CA (**or by the High Court in the **EOC case)**. Accordingly, although I am bound by **Nailard CA**, it cannot be said that the point as it emerged before me has been fully argued before the Court of Appeal so as to dispense with the need for any further consideration of the point before going to the Supreme Court. It seems to me that, if ## the point had any real prospect of success, it is one that ought to be considered more fully by the Court of Appeal before going to the Supreme Court. 64. In any event, given my view as to the prospects of success of any appeal, this is a case where the exclusion under s.37ZC(3) applies. It is not a proper case for granting permission to appeal to the Court of Appeal. Any permission would have to be sought directly from the Court of Appeal. 65. The request for a leapfrog certificate is therefore refused. 66. Finally, I would wish to record my gratitude to Ms Monaghan for her expert and evenhanded oral submissions and to Ms Connolly for her extremely helpful written submissions. ## D E F G H
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## Hm Revenue & Customs Hospitality Register Senior Official (SCS2 and above) Date Person or organisation that offered hospitality Type of hospitality received Mary Aiston Director of Wealthy and Mid-sized Business Compliance 05 July 2017 Chartered Institute of Taxation Drinks and canapes No Gill Aitken General Counsel and Solicitor Nil return Jon Ashton Director of Security and Information Nil return Rebekah Ayres Director, People and Organisation Development Nil return Mike Baker Director Personal Tax Operations Nil return Joanna Baldwin Non-Executive Director Nil return Mary Barber Director of Compliance for the Future Nil return Elaine Benn Director Central Customer Nil return Alison Bexfield Director of Internal Audit Nil return Steven Boyd Director of Estates Nil return Carol Bristow Individuals Policy Director Nil return Dorothy Brown Director Benefits and Credits Nil return David Bunting Director Border Co-ordination Nil return Sam Caughey Director of Finance, Strategy and Performance Nil return Ravi Chand Director Workforce Management Nil return Emma Churchill Director Process Design and Excellence Nil return Penny Ciniewicz Director General Customer Compliance Group Nil return Simon Claydon Director HR Operations Nil return Denise Dourado IT Programme Director Nil return Tim East Columbus Programme Director 01 August 2017 Lifecycle Dinner No Tim East Columbus Programme Director 22 August 2017 Millbank Lawyers Breakfast No Tim East Columbus Programme Director 22 August 2017 Bain Dinner No Kevin Fletcher Director Knowledge, Analysis & Intelligence Nil return Kevin Franklin Director Customs Transformation Nil return Tracy Gale Head of Operational Litigation Nil return Sarah Goom Director of Litigation Nil return Peter Grant Estates Director of Transformation Nil return Nigel Green Director IT Delivery 20 September 2017 Protegrity Drinks No Jim Harra Director General Customer Strategy and Tax Design Nil return John Harrison Director of Benefits Transformation Nil return Justin Holliday Chief Finance Officer 28 September 2017 PwC Dinner No Vicky Homsy Director Risk and Intelligence Nil return Derek Hughes Director Customer Services Debt Management Nil return Nick Lodge Director General Transformation Nil return Angela MacDonald Director General Customer Services (from 7 August 2017) Nil return Alice Maynard Non-Executive Director Nil return Brigid McBride Director of Digital Transformation 21 September 2017 The Corporate IT Forum Lunch No Rachel McLean Director General Customer Services (to 6 August 2017) Nil return Theresa Middleton Director, Making Tax Digital for Business Programme Nil return Sinead Murray Director Solicitors - Personal Tax, Benefits & Credits & Corporate Services Nil return Patrick Nolan Commercial Director 19 September 2017 Microsoft Lunch No Hitesh Patel Director Customer Service Change Nil return Lucy Pink Director EU Transition Unit Nil return Mike Potter Chief Digital Information Officer Nil return David Richardson Director of Counter Avoidance Nil return Accompanied by spouse, family member(s) or friend? Simon Ricketts Non-Executive Director Nil return Paul Riley Director of Tax Strategy and Professionalism Nil return Joanna Rowland Director of Making Tax Digital for Individuals Nil return Pete Schofield Director of Development, Testing and Operations Nil return Jon Sherman Director for Business, Assets and International 05 July 2017 Chartered Institute of Taxation Drinks and canapes No Mike Shipp Director of Change, Assurance and Investment Nil return Heather Smith Finance and Planning Director Customer Compliance Nil return Tom Smith Director of Flexible Policy Development Nil return Kerrie Spendiff Business Customer and Strategy Director Nil return Ruth Stanier Director of Customs and Indirect Tax Nil return Poli Stuart-Lacey Director of Corporate Communications Nil return Melissa Tatton Director Individuals & Small Business Compliance Nil return Jane Taylor CDIO Finance Director Nil return Jon Thompson Chief Executive Nil return Steve Timewell Director Individuals & Small Business Compliance Nil return Edward Troup Executive Chair 14 September 2017 Institute of Chartered Accountants in England and Wales Buffet supper No Edward Troup Executive Chair 26-29 September 2017 Forum on Tax Administration (Plenary meeting in Oslo) Two dinners (FTA Bureau and FTA Official dinners) No Jo Wakeman Director of Large Business 05 July 2017 Chartered Institute of Taxation Drinks and canapes No Mervyn Walker Lead Non-Executive Nil return Esther Wallington Chief People Officer 14 September 2017 McKinsey Dinner No Steve Walters Chief Technology Officer Nil return Hannah Watson HR Director for Chief Digital and Information Officer Group Nil return Karen Wheeler Director General for Border Co-ordination Nil return John Whiting Non-Executive Director Nil return Jane Whittaker Director Finance Planning and Performance Nil return Patrick Whittome Director Finance Operations Nil return Mark Wilson Director Solicitors' Office Nil return Simon York Director Fraud Investigation Service Nil return Applies to all at SCS2 and above. Does not include functions hosted by the government or Royal Household, diplomatic functions hosted by overseas governments or organisations, minor refreshments at meetings, receptions, conferences, seminars, or offers that were declined.
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Disclosure ref: 30 Sent: 2nd June 2020 ## Freedom Of Information Act 2000 Request To Establish The Amount Of Abuse Cases The Cps Have Called In Other Government Departments To Assist In Prosecution Cases Request (in bold and in italics) - responses appear below: 1. The main reason for the request is to establish how many cases of abuse your organisation has called in Government Departments and associated organisations such as OFSTED and ISI as witnesses in prosecution cases for abuse cases in the UK courts over the past 10 years for Independent Schools? The Crown Prosecution Service (CPS) has interpreted your question as referring to child sexual abuse occurring in a school environment. It should be noted that the CPS cannot disaggregate from our data cases where the abuse against a child or children took place in a school nor can we identify if witnesses were from Government Departments (OGDs) other than manually reviewing CPS case files. As a guide of the work which would need to be undertaken, in the most recently available period year ending December 2019 the CPS completed prosecutions in respect of 4,354 case files flagged as child sexual abuse. Section 12(1) of the FOI Act means public authorities are not obliged to comply with a request for information if it estimates the cost of complying would exceed the appropriate limit. The appropriate limit for central government is set at £600. This represents the estimated cost of one person spending 3.5 working days determining whether the department holds the information, and locating, retrieving and extracting the information. We believe that the cost of manually reviewing 4,354 case files would exceed the appropriate limit. Consequently, we are not obliged to comply with your request. If you are able to answer the below questions I would be grateful. 2. I would like to ask whether the CPS collate and keep a list of abuse incidents where staff have had to leave a school and for parents and others to access a list when checking schools suitability for their children's education? ## Crown Prosecution Service, Information Access Team, Floor 8, 102 Petty France, London SW1H 9AJ United Kingdom www.cps.gov.uk The CPS does not collate or keep a record of abuse incidents where staff have had to leave a school and for parents and others to access a list when checking schools suitability for their children's education. This is maintained and kept by the Department of Education. Please refer to them via the address below: Freedom of information (FOI) requests Department for Education (DFE) Piccadilly Gate Store Street Manchester M1 2WD United Kingdom 3. I would also like to know how you categorise Independent school abuse cases. A number of agencies struggle to answer the question when asked about cases such as these, especially those that are categorised as 'Historic' or 'Non Recent'. How many years and or months have to pass for them to be listed as such when you articulate cases with the police and the courts? The CPS does not maintain separate category of independent abuse cases. The legal guidance chapter on Non - Recent cases on the CPS website can be a further assistance. Please see the link below: https://www.cps.gov.uk/legal-guidance/non-recent-casesand-nominal-penalties 4. It is still a mystery for many that abuse cases are regarded as Historic or non-recent!? I have never heard anyone talk about 'Non recent' or 'Historic' GBH, Murder, Fraud or Theft. Maybe the CPS has? This is not a valid request under the FOI Act. Please note that whilst the FOI Act allows the public to request information held by a public authority subject to any exemptions found in the Act, this must be information held by the public authority in recorded form. The authority is not obliged to create new information or find the answer to a question where the information is not already in recorded format. For guidance on how to structure a valid FOI request please refer to the ICO website on the link below: http://ico.org.uk/for_the_public/official_information We would therefore be grateful if you could clarify precisely what recorded information you seek for disclosure from the Crown Prosecution Service (CPS). We would then be happy to take forward your clarified request as a new request under the FOI Act. 5. Is there a level of seriousness of reporting where you as an agency prosecute the management of a School? Please see the latter part of this mail which raises a concern about legislation that doesn't seem to cover some reports and concerns that could easily fall through the net. My recent reporting of a Governor is on hold until the ISI do their next Inspection. In response to question five, please refer to the DFE via the address provided in our response to question two as they may be able to assist with your request. ## 6. Are You Aware Of Any Summing Up Information By Judges That Could Be Useful Where Safeguarding Governance And Management Advice Has Been Given To Schools Moving Forward? The CPS has interpreted this request to asking for legal advice. Please note that the role of the CPS is not to provide legal advice, therefore we are not obliged to provide a response to your question. Under section 16 of the FOI Act we have an obligation to advise what, if any, information may assist you with your request; in reference to question one, you may find it helpful to see the CPS quarterly data on Violence Against Women and Girls (VAWG) Report publically available on the CPS website which include information on the number and outcome of child sexual abuse prosecutions within the past ten years (2009 to 2019). Please see links below: https://www.cps.gov.uk/violence-against-women-and-girls-data Child sexual offences: completed prosecutions by outcome 2009-2019 Information Management Unit 020 3357 0788 IMU@cps.gov.uk
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## A Year In Archives 2018. Trust. Democracy And Society Are Strengthened By Scrutiny Of The Archival Record, Holding Institutions And Individuals To Account. Gloucestershire Archives have completed an 18-month project to appraise and catalogue the records of Gloucestershire County Council, focusing on records created by the Social Services and Education departments. The project developed against the national background of historic abuse enquiries, and the council seeking reassurance that they were responding appropriately to these investigations. Following a voluntary examination of the councils record-keeping practices relating to the safeguarding of children and the handling of historic abuse allegations, Gloucestershire Archives was able to secure additional corporate funding towards cataloguing these records. Two of the services most experienced archivists worked in tandem on the project for 18 months, utilising their extensive experience of Gloucestershires corporate structure, and surveying over 5,000 files. Records relating to the care of children were prioritised and catalogued, while existing catalogue descriptions were enhanced, and new descriptions were created for previously uncatalogued material. This cataloguing framework can now be utilised across the councils corporate record collections, allowing for future efficiency and accuracy when describing these records. Consistent closure periods were also established and applied across the collections. The project helped to establish exactly what Social Service and Education records have survived, and has highlighted gaps in collections. In the future, knowledge of these gaps will help to inform the ongoing development of collections. Because of the project, full catalogue descriptions are now available and comprehensive administrative histories compiled for institutions, organisations and services. This has enabled the council to demonstrate the extent of their historic administrative responsibilities, identifying those institutions that were, and were not, responsible for in the past. Gloucestershire County Council now have a comprehensive and accurate resource that they can use effectively when responding to historic abuse enquiries. The project has enabled Gloucestershire County Council to speak with authority as to their childrens care records. ## Enrichment. Archives Enhance And Enrich Our Society Intellectually, Culturally And Economically. As part of ongoing collections development work, Cheshire Archives and Local Studies realised that their collections did not sufficiently capture and document the lives of ordinary people across the county from the 1950s onwards. This was particularly true of records documenting lesbian, gay, bisexual and transgender (LGBT) lives. For example, although the Chester section of the Campaign for Homosexual Equality was one of the most active, and despite the groups origins in North West England, relatively few of these records have survived locally. As well as a public appeal for documents reflecting LGBT histories to address gaps in collections, the service has been involved in a Heritage Lottery funded project From Prejudice to Pride led by Body Positive Cheshire and North Wales, a charity working for and with people who want to improve their sexual health, sexuality or those living with HIV. From Prejudice to Pride resulted in the organisation depositing their records with the service, a research guide and an exhibition at Weaver Hall Museum, the first time that archives had been used to celebrate LGBT lives locally. The project also involved knowledge exchange with Silver Rainbows, Body Positives network for the older LGBT community. Following oral history training, the group interviewed one another to collect testimonies that will help the service to include voices that were previously missing from the stories told by Cheshires collections. The annual Take Pride in Ageing conference for health and social care service providers across the North West celebrated the achievements of the project and archive staff were on hand to promote the value of archives. They were able to suggest records that could remind the community of past LGBT venues and spaces in Chester for reminiscence work, allowing future health and social care initiatives to be more inclusive and reflective of different life experiences. From Prejudice to Pride has helped to unlock a treasure trove of stories and hidden histories, highlighting an incredible past of activism and celebrating Cheshires LGBT communities. ## Openness. Archives Cultivate An Open Approach To Knowledge And Are Accessible To All. Tower Hamlets Local History Library and Archives developed the Womens Hall project in partnership with four organisations: Four Corners, Alternative Arts, The East End Womens Museum and Numbi Arts. Named after the East London Federation of Suffragettes (ELFS) former headquarters in Bow, the Womens Hall went beyond the famous individuals of the movement by exploring lesser-known suffrage stories from East London. The project featured two exhibitions and a series of weekly events based on the inclusive and proactive work of the suffragettes. Events included banner-making activities, a workshop on delivering activist speeches and a talk about Indian suffragettes, which provided a different perspective and resonated with new audiences. The events were supported by 95 volunteers and were free of charge to ensure that everyone could participate. The community spirit and support demonstrated by the suffragettes was central to the Womens Hall and so collaborating organisations created events inspired by the federations welfare initiatives. While fighting for working womens rights during the First World War, the East London suffragettes had opened a toy factory with a creche so that working-class mothers could earn a living. In honour of this, Four Corners funded childcare for women to attend a photography skills workshop and to share their stories. Tower Hamlets Archives replicated a suffragette cost-price restaurant by opening a pay-what-you-can cafe and serving over 500 meals. Run in collaboration with Fare Share, a food redistribution charity, the cafe drew attention to the ongoing issue of food poverty in East London and fostered a welcoming atmosphere. Before visiting the cafe, many new visitors toured the services exhibition about ELFS and discovered that the service kept records of their ancestors, encouraging new relationships with the collections to grow. It has been such a joy to honour the memory of the East London Federation of Suffragettes with our own activism. Some people living in modern day East London still struggle to afford food and childcare or find work, and we have provided opportunities on all scores. Lauren Sweeney, Volunteer Manager, The Womens Hall, Tower Hamlets Local History Library & Archives. ## Digital. Creating And Sustaining Archives In The Digital Age. As the worlds largest human rights organisation, with more than 700 staff across 20 international offices, Amnesty International has been at the forefront of the fight against human rights abuses worldwide since 1961. The organisations activities range from observing the 1962 trial of Nelson Mandela to its current work advocating for justice on behalf of the Rohingya in Myanmar. The archive of Amnestys International Secretariat provides a service to staff regardless of their location or time zone, but despite their global focus, the service faces similar challenges to many others, in responding to changing digital technologies and increasing amounts digital data. For Amnesty, digital evidence collected by its researchers and campaigners comes in many different forms, from snippets of YouTube videos to tweets and satellite footage. Protecting, preserving and ensuring the authenticity and integrity of these records is of the utmost importance, as it allows Amnesty to hold governments and organisations accountable for their actions, while supporting communities and individuals affected by human rights violations. The service was already using Axiells Calm software and SharePoint to manage and catalogue records but required a solution that would integrate these platforms into a full digital preservation solution. Responding to this challenge, archivist Bryony Hooper is building a global digital repository, using Preservicas Enterprise Private Cloud platform. This repository will allow Amnesty to retain and ingest content of enduring value, allowing staff worldwide to access records that they need in order to present evidence to international bodies and human rights stakeholders, and to contribute to campaigning activities. Metadata enrichment will improve the efficiency of searching across collections, opening up access to Amnestys digitised and born-digital archives, and allowing staff the opportunity to learn more about the organisations history and how it can be used to further the cause of human rights for all. Digital evidence can come in all shapes and sizes. By providing a search platform, we can enable staff to discover relevant resources while maintaining appropriate access rights to sensitive data. Bryony Hooper, Archivist, Amnesty International. ## Resilience. Evaluating Different Service Delivery Models For Archives And Fostering Innovative Approaches. Wolverhampton City Archives (WCA) partnered with Black Country Visual Arts (BCVA) to collect, digitise, and provide access to more than 2000 photographs of Wolverhamptons Sikh community as part of the Apna Heritage Archive, supported by the Heritage Lottery Fund. BCVA brought together family photographs and memorabilia relating to Punjabi migration to Wolverhampton between 1960 and 1989, leading to the development of a community archive space at the Guru Teg Bahadur Gurdwara in Wolverhampton, where the collections are stored and made available. WCA supported the project from the outset, providing advice on preservation and digitisation of the original material, leading to the deposit of the digitised material. Children from a primary school, where around 50 percent of the school population is of Punjabi origin, visited WCA, and created their own school archive, developing heritage research skills. This enabled WCA to document and establish strong links with a large, yet previously under-represented, community in their collections: the Punjabi community are around 15 percent of Wolverhamptons population, totalling some 40,000 people, the second largest population of Punjabis in the country. The project culminated in an exhibition at Wolverhampton Art Gallery, which proved so popular that it was extended by two weeks. Since participating in the project, BCVA have used their experience to advocate and offer advice to a wide range of community groups on the practicalities and benefits of working with archive services, encouraging community engagement with collections. The interest generated by the project enabled them to strengthen their advisory board, recruiting local stakeholders and academics who now play an active role in widening engagement and developing future projects. As well as generating opportunities for further art-focused projects, BCVA was recently awarded funds by the British Council for a threeweek tour of India, talking about the project at universities and photographic festivals. I went to the City Archives and stood in front of 30,000 images of Wolverhampton. I asked how many were from the South Asian community, and there were none. Anand Chhabra, Director, Black Country Visual Arts. ## Impact. Ensuring The Full Value Of Archives Is Recognised. The National Fairground and Circus Archive (NFCA) holds more than 150,000 images and thousands more items relating to travelling entertainment. Following the donation of the Circus Friends Association Archive in 2016, the NFCA began looking for new ways to introduce these collections to the public, with the 250th anniversary of the modern circus in 2018 providing the perfect opportunity. The service developed a broad programme of events, including the exhibition Circus Performers, Extraordinary Feats from Ordinary People at the services home at the University of Sheffield Library. The NFCA also participated in the universitys Festival of the Mind, where the public were invited to an aerial performance inspired by research into female body image and the archive collections. Expanding the reach of the collections, the service worked closely with Museums Sheffield, Tyne and Wear Archives & Museums, and Norfolk Museum Service to conserve and loan material for three exhibitions, Circus! Show of Shows. The different exhibition spaces used records from the service to explore the histories of black and female circus artists, the changing attitudes towards animal performances, and the enduring impact of the circus in global culture. The NFCA also collaborated with the childrens charity Artfelt by hanging colourful circus posters in the local paediatric hospital. This offered a new audience the chance to enjoy archive collections while brightening their environment. Recognising the value of engaging broad audiences, the service has also brought collections out to other communities at Weston Park and Sheffield Fayres, sparking conversations with people unfamiliar with the NFCAs work and leading to an increase in visitors to the service. The NFCA plans to continue exploring opportunities like these in the future, developing new audiences to recognise the impact of archives. We have been delighted to share our unique collections with new audiences this year and build networks that mean we can continue to expand our reach. ## A Year In Archives 2018 Brings Together Stories From Organisations Across The Country, Celebrating The Innovative And Exciting Work Happening In The Sector. 2018 was another successful year for the archives sector, and notable for the ways in which the sector has embraced and delivered on the themes of the strategic vision, Archives Unlocked. The ambition of Archives Unlocked is to release the full potential of archives, demonstrating how archives can inspire trust, enrich our lives and be open to all. These stories reflect these ambitions, illustrating how our vibrant sector is embracing current challenges and opportunities, from building digital capacity and resilience to demonstrating impact, driving forward the many benefits of archives to different audiences. As we continue to build the platform for future success, A Year in Archives demonstrates that the archives sector continues to work hard in demonstrating the importance of archives through innovative ways of collecting and making collections accessible, preserving our past for the future. Dr Valerie Johnson Director of Research and Collections, The National Archives. I am always inspired by the range of activity across the sector which demonstrates how the impact of archives is felt right across society, underpinning academic research, fuelling the digital economy and inspiring innovation and creativity. In short: archives matter!
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## Norovirus About norovirus and how to reduce the risk of spreading the virus. Norovirus is commonly known as the winter vomiting bug. It causes an estimated three million cases of diarrhoea and vomiting each year. Although the symptoms of norovirus can be unpleasant, it is considered a mild infection. This is because it is usually short-lived and most people get better without medical treatment. You are most likely to catch norovirus by coming into contact with an infected person but it can also be spread by contaminated food. Norovirus is one of the most common causes of foodborne illness in the UK. Our research published in 2020 estimated that it was responsible for around 380,000 cases of food poisoning in the UK. ## Foodborne Disease Estimates For The United Kingdom In 2018. Fsa Explains Viruses Viruses are tiny, often highly contagious pathogenic agents which cause disease. Viruses can be spread between hosts in different ways such as through: bodily fluids - for example, HIV the air - for example, influenza ingestion - for example, norovirus Unlike bacteria, viruses are not technically considered living organisms. Norovirus can survive and remain infectious in foods and the environment for prolonged periods of time and can often survive under harsher conditions than bacteria. ## How Norovirus Spreads Norovirus can contaminate food and water and enters the body by being ingested and inhaled through the mouth or nose. Norovirus causes infection once it has reached the gut. It can also spread through contact with the faeces or vomit of an infected person. Norovirus can remain infectious in the environment for several months. To prevent you from passing norovirus on to your family and friends via the food you're preparing, it's vital that you follow good personal hygiene practices. It's also essential that you are careful about cleaning and avoiding cross-contamination when transporting, preparing and storing food. To stop norovirus spreading: wash your hands with soap and water after using the toilet and before preparing or eating food handle food carefully in your kitchen wash chopping boards and utensils clean surfaces properly Viruses such as norovirus cannot multiply in food, but they can survive there for long periods of time. Outbreaks of norovirus have been caused by food handlers, contaminated oysters and fresh produce such as berries and salad. Evaluating the effectiveness of depuration in removing norovirus from oysters Food handlers and norovirus transmission: Social science insights View Norovirus surveillance report as PDF (1.69 MB) View Sewage variation report as PDF (295.92 KB)
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| Transaction Reference Number | Posting Date Merchant Name | Final Transaction Amount | |--------------------------------|-----------------------------------------------|----------------------------------------------------------| | 150874929323 | 14/08/2013 Travres | 755.82 Attendance at Development Bank Conference, Canada | | 040974745103 | 03/09/2013 Institute of Chartered Accountants | 600 Professional Membership | | 240974056573 | 23/09/2013 George Hotel, Hope Valley | 1424.06 Accommodation for Strategy Development Meeting | | 071174745093 | 06/11/2013 Viglen Ltd | 552 IT Consumables | | 090174916774 | 07/01/2014 Institute of Chartered Accountants | 790.8 Professional Membership |
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## have been considered by the Chief Executive in his capacity as Accounting Officer; and the requests for consultancy below £20,000 have been considered by the Director of Corporate Operations. ## | Summary of application | Decision | Approval | |------------------------------|--------------|------------------------------| | date | | | | Ref: No. & | | | | Directorate | | | | Approved | | | | 22/05/2015 | 58C RME | Assessment on competing | | open access applications, | | | | £10,000 | | | | Approved | | | | 22/05/2015 | 59C RME | Advising ORR on its approach | | to the overall management of | | | | the PR18 programme, | | | | £100,000 | | | ##
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## Proposal For A London-Wide Approach To Ensuring Full Implementation Of The Unique Learner Number For All London'S Young Residents Aged 14 (And Over) Proposing Organisation London Councils London Councils represents all 32 London boroughs, the City of London, the Metropolitan Police Authority and the London Fire and Emergency Planning Authority. London Councils is committed to fighting for more resources for London and getting the best possible deal for London's 33 councils. We develop policy, lobby government and others, and run a range of services designed to make life better for Londoners. This proposal has been prepared byYoung People's Education and Skills, which provides pan-London leadership for 14-19 education and training provision in relation to the current and future needs of learners and employers supports local authorities in undertaking their statutory functions, and assists other stakeholders in planning, policy and provision. This work is further supported by our Data Advisory Group (a constitutional group that reports to our Board) and the groups Chair, Rob Atkins (Children's Services, Islington Council). ## Aim Of Proposal The aim of this proposal is to develop a London-wide interface between the Learning Records Service and London local authority Client Caseload information Systems (CCIS) to: - enrich personal education information held on local CCIS to assist local authorities in discharging their statutory duties to: o encourage, enable and assist young people to participate in education or training; o promote young people's participation in education and training up to the age of 17 by 2013 and 18 by 2015; o support vulnerable young people; o provide early intervention for those at risk of disengagement; o monitor and record young people's activity and non-activity (participation, Not Engaged in Education, Employment or Training (NEET) and activity not known for 16 to 18 year olds). - More effectively implement the Unique Learner Number (ULN) for all London's young residents aged 14 (and over) following the Department for Education (DfE) Schools Star Chamber approval for mandatory use of the ULN. - Support the January 2013 'soft start' collection of the ULN within the school census (and the consequent mandatory rollout from January 2014). - Enable more effective sharing of learner data, including Awarding Body qualification data. To implement a London-wide interface with the Learning Records Service we will register as a Developer and explore the necessary options to create the interface. In the meantime and to ensure that London can support the January 2013 'soft start' we propose an initial phase of activity to test out sharing of data with a local authority whilst the interface work is undertaken. ## Phase 1 - Testing A Local Authority-Wide Approach To Obtaining Ulns For All Young People Educated In Islington 4,960 young people aged between 16 and 19 currently live in Islington, and roughly 1,600 young people complete Key Stage 4 in Islington's schools every year. These young people attend a very wide range of post-16 education and training providers (almost 200 different providers in total in 2011). In line with the transfer of Information, Advice and Guidance responsibility to schools, Islington's in-house Information, Advice and Guidance Team has been reduced significantly over the past 2 years. It is therefore essential to find a more efficient means of tracking the participation of young people than the current system which relies on Islington Council staff pursuing information from individual providers. The process is made particularly challenging by the lack of consistent identifying information. Using the Unique Learner Number (ULN) to confirm participation would provide a solution, however this option is not currently available as Islington's schools only request ULNs for a small minority of young people aged below 16 (those attending programmes where the ULN is a requirement). London Councils and Islington Council propose that, in partnership with Islington's schools, a trial should take place testing a local authority-wide approach to obtaining ULNs for all young people educated in Islington. In 2013, batch upload of Islington pupil data will provide all 4,827 young people currently in academic years 9 to 11 with a ULN. This will have the following advantages: - a minimal increase in bureaucracy for schools, whilst still allowing all pupils to benefit from the Unique Learner Number (schools will still be required to participate in exception handling). - The opportunity for the Local Authority to guarantee that all young people in the Local Authority have been issued a Unique Learner Number, including those young people in Special Schools, the Pupil Referral Unit and other alternative education provision. - A decrease in bureaucracy for local colleges and training providers, who will be made aware that there will not be a need to obtain a ULN for young people progressing from Islington schools, and who will be able to access qualification details via the Personal Learning Record for all Islington applicants. - An improvement in the accuracy of progression information and increased efficiency in obtaining and processing progression data, particularly as it will be possible to share a full set of ULN data with the Central London sub-regional IAG unit (Central London Connexions) who retain responsibility for processing CCIS participation data on behalf of Central London Local Authorities. - If the pilot year is successful, data for all Year 9 pupils educated in Islington (currently roughly 1,600 pupils per year) will be uploaded and processed annually to allocate a ULN, with clear requirements and processes in place for schools to obtain ULNs for new joiners after the Year 9 January school census return. The exact process to be undertaken during the pilot will be confirmed with colleagues at the Learning Records Service; however the following is suggested as an outline example: All Islington schools return census data, via COLLECT, to Islington's Information & Performance Team Data required to obtain ULNs is compiled into a single file Single pupil data file is uploaded to LRS site for batch processing ULN data is retrieved by I&P team (any errors that may be immediately corrected using data held by the I&P team are corrected centrally; any outstanding errors are distributed to schools for correction) ## Phase 2 - Local Authority Access To The Personal Learner Record Service Through the Data Advisory Group we will identify a Task and Finish Group of local authoritiesto register for access to the PLR to explore how access to this datacan support authorities to discharge their statutory duties, and support the work of the Learning Records Service. We propose that this trial is managed through the Data Advisory Group as its governance arrangements will ensure appropriate safeguards in respect of access to and sharing of personal data and robust evaluation of the trail to support the development of a London-wide interface. To ensure the Learning Records Service remains fully advised of this work we are keen to include colleagues from the Service onto the Task and Finish Group. ## Next Steps Should the Learning Records Service wish to accept our proposals and work with us we would welcome the attendance of colleagues from the Service at our next Data Advisory Group meeting on 12 December to meet Group members and discuss the proposals in more detail. Yolande Burgess Strategy Director,Young People's Education and Skills London Councils Rob Atkins Analyst and Systems Officer Islington Council Chair, Data Advisory Group
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Our ref: 8677 ## S17 Notice Under The Freedom Of Information Act 2000 Withholding Information Section 21(1) - Information accessible to applicant by other means. (1) Information which is reasonably accessible to the applicant otherwise than under section 21 is exempt information. (2) For the purposes of subsection (1)— (a) information may be reasonably accessible to the applicant even though it is accessible only on payment, and (b) information is to be taken to be reasonably accessible to the applicant if it is information which the public authority or any other person is obliged by or under any enactment to communicate (otherwise than by making the information available for inspection) to members of the public on request, whether free of charge or on payment. (3) For the purposes of subsection (1), information which is held by a public authority and does not fall within subsection (2)(b) is not to be regarded as reasonably accessible to the applicant merely because the information is available from the public authority itself on request, unless the information is made available in accordance with the authority's publication scheme and any payment required is specified in, or determined in accordance with, the scheme. ## Section 21 Is An Absolute Exemption Which Means There Is No Requirement To Carry Out A Public Interest Test If The Requested Information Is Exempt. Section 31(1)(C) - Information Which Is Not Exempt Information By Virtue Of Section 30 Is Exempt Information If Its Disclosure Under This Act Would, Or Would Be Likely To, Prejudice The Administration Of Justice The Disclosure Of Internal Process Documents Such As This Could Inhibit The Ability Of The Cps To Conduct Proceedings Fairly. This is a qualified exemption which means that the decision to disclose the requested material is subject to the public interest test. It may assist you to understand the decision if the public interest factors taken into account in this case is explained: Public interest factors for disclosure: To increase public understanding of the CPS decision making and prosecuting process Public interest factors against disclosure: The CPS publishes its policy guidance relating to Feedback and Complaints on its website in order to be transparent and increase the public understanding of our complaints handling procedure. However, some information needs to be withheld to protect those involved with the complaints handling process. The CPS' internal Feedback and Complaints guidance is there to support those involved in the handling of complaints. Disclosure to the world at large would impede the work of those working in this process. It is in the public interest that CPS is confident in its ability to handle complaints effectively, sensitively, fairly and thoroughly without prejudice to its processes. On balance, I consider the public interest favours maintaining the exemption.
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# Uk Commission'S Employer Skills Survey 2011: Wales Results Evidence Report 62 November 2012 Uk Commission'S Employer Skills Survey 2011: Wales Results Ben Davies, Katie Gore, Briony Gunstone, Jan Shury, David Vivian, Mark Winterbotham IFF Research Dr Susannah Constable and Ken Manson Project Managers UK Commission for Employment and Skills November 2012 ## Foreword I Am Keenly Aware Of How Crucial The Skills Of Staff Are To The Success Of Business. Our company isn't just a brewer, it's also the home of hundreds of hospitality retailers who operate across Wales and the west of England. Our pubs, bars and coffee shops rely on the skill and tenacity of managers and landlords who know their staff and know their local markets. This kind of detailed knowledge and understanding underlies the work of the UK Commission for Employment and Skills to study and report on the labour market in Wales and across the UK. To tackle an issue successfully, you first have to understand it. By understanding more about the labour market, business and government alike can understand where there are problems but also opportunities. Along with the UK, the Welsh economy is growing only very slowly. Much pain remains: for people out of work; for businesses struggling to survive. In my view, this makes it more important, not less, to build on the understanding we have of our teams and to work to improve them. At Brains - as in all businesses - the people we work with are the most important part of the company. Putting their skills to the best use is not a separate agenda to growing Welsh business. It is at the centre of that effort. The UK Commission's Employer Skills Survey is a vital source of evidence and analysis of business vacancies, skills shortages, and training regimes in Wales and across the UK. This means that what you are reading is not just a report; it is a resource you can use to understand and to act upon. If you are in business, I urge you to look at what it tells you about your industry, and think about the skills of your employees and how you approach the challenge of staff development. And if you are a teacher, trainer, or you work for a college, I urge you to use its results to target your offer to meet the needs that businesses across Wales have told the UK Commission they require. The training and development picture is complex, and different regions, industries, and occupations have their own stories. One of the benefits of this report is that, for the first time, we are able to compare directly between Wales and other parts of the UK. This is due to the cooperation of the Welsh Government with its partners in Northern Ireland, Scotland and England. These comparisons show that we have much to be proud of, and in many areas we are ahead of our partner nations. But there is no room for complacency, and there are also measures that show where Wales is falling behind. Here we need to take responsibility together and use this insight to plan how to respond. I would like to thank the 6,000 businesses across Wales who gave their valuable time to answer the survey, helping to inform the UK Commission's most comprehensive report yet into the challenges and opportunities available to Welsh business. Scott Waddington Commissioner and Chief Executive, SA Brain & Co Ltd. ## Acknowledgements Many individuals and organisations have been involved in the design and execution of the UK Commission's Employer Skills Survey 2011 and the Wales Results. Particular thanks are given to the 6,000 businesses who gave their time to speak to us. As the lead contractor, we have been supported by the research agencies who conducted much of the fieldwork: BMG Research and Ipsos MORI. The project was sponsored by the four UK governments who came together to ensure the delivery of this first UK employer skills survey was possible. A steering group was established to guide the direction of the project. Members attending this group were: Mark Langdon, Department for Business, Innovation and Skills (BIS); Dominic Rice, BIS; Kathy Murphy, BIS; Euan Dick, Scottish Government; Sarah Munro, Scottish Government; Joanne Corke, Welsh Government; Graeme Belshaw; Department for Employment and Learning Northern Ireland (DELNI); Linda Bradley, DELNI; Tim Devine, DELNI; Mauricio Armellini, Department for Work and Pensions (DWP); Jacqui Hansbro, DWP; Alasdair Yeo, DWP; Anthony Clarke, Department for Education (DFE); Muriel Bankhead, Alliance of Sector Skills Councils; Sally Walters, Alliance of Sector Skills Councils; Helen Lindsay, Alliance of Sector Skills Councils and Mark Spilsbury of the UK Commission for Employment and Skills. The report was completed with the assistance of Rachel Stephens and James Carey at the Welsh Government. Thanks are due to staff at the UK Commission who supported the preparation of this report, including Allan Noy, Carol Stanfield, and Dr Vicki Belt. Ken Manson worked on the survey throughout and managed the Wales Results from September 2012. Special thanks are due to the UK Commission project manager throughout the course of the survey, Dr Susannah Constable. ## Jan Shury Joint Managing Director, Iff Research Ltd. Appendix I: Bibliography ................................................................................. 144 ## Table Of Graphs And Charts Table 1.1 Survey response rates ................................................................................................ 10 Figure 2.1 Size distribution of establishments and employees .............................................. 12 Figure 2.2 Sectoral distribution of establishments and employment ..................................... 13 Figure 2.3 Establishments and employment by Private, Public and Third sector ................ 14 Figure 2.4 Establishments and employment by Region ........................................................... 15 Figure 2.5 Size distribution within Region ................................................................................. 16 Table 2.1 Sector distribution within Region .............................................................................. 17 Figure 2.6 Single or Multi site organisation ............................................................................... 18 Figure 2.7 Product Market Strategy positions ........................................................................... 19 Figure 2.8 Product Market Strategy positions ........................................................................... 20 Table 2.2 Product Market Strategy by Size ................................................................................ 21 Table 2.3 Product Market Strategy by ESF Region ................................................................... 21 Figure 2.9 Proportion of staff qualified to Level 3 and Level 4 ................................................ 22 Figure 2.10 Skills level by Product Market Strategy ................................................................. 23 Table 3.1 Incidence of recruitment from education in last 2-3 years ...................................... 27 Figure 3.1 Perceived work-readiness of education leavers in the last 2-3 years .................. 28 Figure 3.2 Perceived work-readiness of education leavers in the last 2-3 years by region . 29 Table 4.1 Incidence, volume and density of vacancies ............................................................ 35 Table 4.2 Incidence and density of vacancies by occupation ................................................. 36 Table 4.3 Incidence, volume and density of hard-to-fill vacancies: 2011 ............................... 38 Table 4.4 Incidence, volume and density of hard-to-fill vacancies: by occupation .............. 39 Figure 4.1 Causes of hard-to-fill vacancies ................................................................................ 41 Table 4.5 Causes of hard-to-fill vacancies (unprompted) ........................................................ 43 Figure 4.2 Impact of hard-to-fill vacancies ................................................................................. 44 Table 4.6 Impacts of hard-to-fill vacancies (unprompted) ....................................................... 45 Figure 4.3 Measures taken to address hard-to-fill vacancies ................................................... 47 Figure 4.4 Skill-shortage vacancies route map ......................................................................... 48 Table 4.7 Incidence, volume and density skill-shortage vacancies ........................................ 50 Table 4.8 Incidence, volume and density of skill-shortage vacancies: by occupation ......... 51 Table 5.1 Incidence, volume and density of skills gaps ........................................................... 57 Table 5.2 Incidence, volume and density of skills gaps: by occupation ................................ 58 Figure 5.1 Causes of skills gaps .................................................................................................. 60 Table 5.3 Causes of skills gaps .................................................................................................. 61 Figure 5.2 Impact of skills gaps ................................................................................................... 62 Table 5.4 Impact of skills gaps .................................................................................................... 64 Table 5.5 Skills that need improving in occupations with skills gaps ..................................... 65 Table 5.7 Combined skill deficiencies (internal and external) ................................................. 68 Figure 5.3 Establishments with skill deficiencies: by size ....................................................... 69 Figure 5.4 Establishments with skill deficiencies: by sector ................................................... 70 Figure 5.5 Establishments with skill deficiencies: by region ................................................... 70 Figure 5.6 Difficulties retaining staff by establishment size, sector and region ................... 72 Figure 5.7 Reasons for retention difficulties .............................................................................. 75 | Figure 5.8 Impact of retention difficulties | 76 | |-------------------------------------------------------------------------------------------|-------| | | | | Figure 5.9 Measures taken to overcome retention difficulties 77 | | | | | | Table 5.9 Proportion of staff that are under-used | 79 | | | | | Figure 6.1 Incidence of training activity by size | 84 | | | | | Figure 6.2 Incidence of training activity by sector | 85 | | | | | Figure 6.3 Incidence of training by region | 86 | | | | | Table 6.1 Incidence and volume of training: by ESF region 86 | | | | | | Figure 6.4 Incidence of training and further development by establishment size 88 | | | | | | Figure 6.5 Incidence of training and further development by establishment sector 89 | | | | | | Figure 6.6 Incidence of training and further development by establishment region 90 | | | | | | Table 6.2 Volume of training 92 | | | | | | Figure 6.7 Distribution of training by occupation 93 | | | | | | Table 6.3 Training plans and training budgets: by size 94 | | | | | | Figure 6.8 Types of training funded or arranged by employers | 95 | | | | | Table 6.5 Training expenditure (in absolute terms) over the previous 12 months and the | | | components of training expenditure | 98 | | | | | Table 6.6 Training investment by region 100 | | | | | | Table 6.7 Training expenditure per capita and per trainee 100 | | | | | | Table 6.8 Training expenditure per capita and per trainee by region | 102 | | | | | Table 6.9 Investors in People Standard 103 | | | | | | Figure 6.9 Proportion of establishments that formally assess the impact of training | 104 | | | | | Figure 6.10 Reasons for not providing training 105 | | | | | | Figure 7.2 Use of performance related pay and incentive schemes | 112 | | | | | Figure 7.3 Involvement of employees in decision making | 113 | | | | | Figure 7.4 Communication and sharing of information in the workplace | 114 | | | | | Figure 7.5 | | | | | | Amounts of variety, flexibility and discretion employers provide to workers | | | | 115 | | | | | Table A.1 Incidence of vacancies in Wales: time series 123 | | | | | | Table A.2 Incidence of vacancies in Wales: time series by size 123 | | | | | | Table A.3 Incidence of vacancies in Wales: time series by sector 124 | | | | | | Table A.4 Incidence of vacancies in Wales: time series by region 126 | | | | | | Table A.5 Incidence of skills gaps in Wales: time series 127 | | | | | | Table A.6 Incidence of off-the-job training in Wales: time series 128 | | | | | ## Glossary This glossary gives a short guide to the key terms used in this report: The overall number of people employed. Employment A single location of an organisation with people working at it. Establishment (also referred to as workplace, business, employer, site) ESF European Structural Fund. For the purposes of European Union ESF programmes, Wales is divided into two regions, East Wales and West Wales and the Valleys. Hard-to-fill vacancies Vacancies which are proving difficult to fill, as defined by the establishment (from question: "Are any of these vacancies proving hard to fill?"). The number of hard-to-fill vacancies as a proportion of all vacancies. Hard-to-fill vacancy density Occupations For definitions of the occupational groups used in this report please refer to Appendix E. Sector For definitions of the different sector groupings used in this report please refer to Appendix D. Skill-shortage vacancies (SSVs) Vacancies which are proving difficult to fill due to the establishment not being able to find applicants with the appropriate skills, qualifications or experience. The number of skill-shortage vacancies as a proportion of all vacancies Skill-shortage vacancy density Skills gaps A "skills gap" is where an employee is not fully proficient, i.e. is not able to do their job to the required level. See Appendix B. Skills gap density The number of staff reported as being not fully proficient as a proportion of all employment. Vacancy density The number of vacancies as a proportion of all employment. Working proprietors An owner or part-owner of the organisation who also acts as a member of staff. ## Executive Summary The UK Commission's Employer Skills Survey 2011 is the key UK data source on employer demand for and investment in skills. It is the first UK-wide employer skills survey, and is one of the largest employer skills surveys undertaken in the world, involving over 87,500 interviews with employers. In Wales 6,012 interviews were completed across all sectors and covering all sizes of employer. The survey covered topics such as skill related recruitment difficulties, skills gaps, training investment and the work-readiness of education leavers. Headline findings on these and other topics are provided below. ## Work-Readiness Of Education Leavers In Wales around a quarter of establishments (24 per cent) had recruited at least one person straight from education in the two to three years prior to the survey, in line with the proportions seen across the UK. As in the UK as a whole, employers mostly found these education leavers to be well prepared for work; the proportion saying this increased with the recruit's age and / or educational level (from 56 per cent recruiting 16 year-old school leavers up to 80 per cent of those recruiting from Higher Education). Interestingly 17-18 year olds leaving FE College were reported to be better prepared for work than their 17- 18 year-old peers leaving school; suggested reasons for this include college students being more likely to be studying vocational courses which are more relevant to working life, and college students also being more likely to combine work and learning and therefore to have amassed more work-relevant experience. Where education leavers were found to be poorly prepared for work this was most commonly put down to a lack of experience of the working world, life experience or maturity. ## Employers, Recruitment And Skill Shortages At the time of the survey (March to July 2011) 11 per cent of establishments in Wales had a vacancy, totalling 25,500 vacancies across Wales. As a proportion of the workforce in each occupation demand was highest for Associate Professionals, with 5.7 vacancies for every hundred current employees in this area. Establishments in the Education, Health and Social Work and Manufacturing sectors were most likely to have a current vacancy at the time of the survey, but the highest vacancy density was seen in Electricity, Gas and Water (4.5 vacancies for every 100 employees). The labour market is largely able to meet the recruitment requirements of most establishments; however four per cent of establishments reported having a vacancy they were finding it difficult to fill (a "hard-to-fill vacancy"). Overall 8,500 hard-to-fill vacancies were reported, equating to a third of all vacancies. Of these, 5,700 are proving hard to fill due to a difficulty in finding applicants with the skills, qualifications and experience required for the role; this equates to over a fifth of all vacancies and is an issue reported by three per cent of establishments. It is amongst Associate Professional and Machine Operative roles where employers experience the greatest difficulties in meeting their demand for skills from the available labour market. Skill-shortage vacancies were most common among establishments in the Manufacturing and Electricity, Gas and Water sectors, and most prevalent (i.e. made up the highest proportion of all vacancies) in the Business Services sector. Whilst the proportion of establishments experiencing hard-to-fill vacancies and skillshortage vacancies was similar to that in the UK as a whole, the total proportion of vacancies that were classed as hard-to-fill vacancies and the total classed as skillshortage vacancies was higher in Wales than the UK. This suggests the problem is more acute in Wales. These differences were almost entirely driven by establishments in Mid Wales, where the proportion of vacancies proving problematic was far higher than in the other regions of Wales. Whilst these recruitment difficulties may not be common in terms of the proportion of establishments experiencing them, where they do exist their impact can be significant. Almost all establishments with hard-to-fill vacancies said they were having an impact on the establishment, most commonly on the workload of existing staff which will risk knockon effects on morale and retention, but also a more direct impact on performance such as meeting customer service objectives, delaying the development of new products and services, and even causing the establishment to lose business to competitors. ## Internal Skills Mismatch Internal skills mismatch considers the proficiency of existing staff: whether they have the skills they need to do their job and whether their skills are being fully utilised in their current role. It also looks at retention of employees, as retention issues can cause skills to be lost from the workforce. The majority of employers report their workforce are all proficient in their current job role, however 13 per cent report having one or more employee who is not fully proficient at their job, i.e. they have a "skills gap". Overall 53,700 employees were reported as having skills gaps, equating to five per cent of the workforce in Wales. This is similar to the levels of proficiency seen in the UK as a whole. Skills gaps were most common amongst staff working in Machine Operative roles. Establishments in the Hotels and Restaurants sector were among those most likely to have a skills gap, and also had the highest proportion of their staff experiencing gaps; this sector was also most likely to suffer retention difficulties so their skills gaps were likely to be caused by new staff. Establishments from the Public Administration sector on the other hand were also among the most likely to have a skills gap, but had among the lowest proportions of the workforce with a gap suggesting that the high incidence here is driven by better systems to identify skills lacking. Where gaps exist their impact can be significant, and as with hard-to-fill vacancies the impact is most commonly felt by an increased workload for other employees of the establishment. However far fewer employers with gaps than employers with hard-to-fill vacancies reported that they had an impact on the establishment; indeed around two-infive employers with skills gaps reported they did not have any tangible impact on the performance of the establishment. This may be related to skills gaps being caused in some instances by new staff having been taken on, in which circumstance the skills gaps will often be both anticipated and temporary (in support of this, the most common causes of skills gaps were training only being partially completed, and the employee in question being new to the role). The finding that employees being new to the role is often a cause of skills gaps is of concern to establishments who have difficulties retaining staff, as these establishments will regularly be taking on new employees and potentially experiencing skills gaps as the new staff become familiar with their roles. Overall across Wales six per cent of establishments reported they had difficulties retaining staff, most commonly among Skilled Trades occupations and Elementary staff. Most commonly these difficulties were attributed to a lack of interest in the work in question, a factor in three-fifths of all establishments with retention difficulties. As with hard-to-fill vacancies and skills gaps, the impact is largely felt by other employees of the establishment. Almost half (45 per cent) of establishments in Wales reported having at least one employee with both qualifications and skills that are more advanced than required for their current job role, amounting to 14 per cent of the total workforce in Wales. These findings resulted from an experimental question asked for the first time in this survey. This enables us to get an employer perspective on a measure that has traditionally been asked of individuals. ## Employer Investment In Training And Workforce Development Three-fifths (59 per cent) of establishments had provided on- or off-the-job training for some or all of their staff in the 12 months preceding the survey; this is the same level as seen across the UK as a whole. During this period employers had arranged or funded training for approximately 650,000 staff, equivalent to 56 per cent of the total workforce in Wales at the time of the survey, and provided five million days of training (equivalent to 4.2 days per employee per annum and 7.5 days per person trained). Employees in Professional roles and in Caring, Leisure and Other services roles were most likely to have received training; conversely Administrative and Clerical staff, Elementary occupations and Managers were least likely. This is similar to findings from the UK as a whole. Employer expenditure on training over these 12 months was £1.72 billion, which is equivalent to £1,450 per employee and £2,600 per person trained. Whilst overall volume of training is equivalent to that seen in the UK as a whole, this per trainee spend is lower in Wales than it is in the UK. This could be related to there being lower wages in Wales than across the UK as a whole. Another possibility is that it results from the *specific types* of training undertaken in Wales (i.e. the average cost of these is lower than across the UK more widely). Furthermore, the fact that a slightly higher proportion of staff in Wales are trained than across the UK as a whole may also explain why the difference widens between the per capita and per trainee expenditure. Half of total expenditure covers the cost of paying staff while they are being trained, whilst just eight per cent is accounted for by fees to external providers. The extent to which establishments plan their training varied, with fewer than half (44 per cent) having either a training plan (38 per cent) or a budget for training expenditure (26 per cent). Many workplaces undertake training on an *ad hoc* basis, with over half of those providing training saying they did not have a formal training plan in place. The most common reason for not training is that employers consider their staff to be fully proficient and / or that their staff did not need training (mentioned spontaneously by 65 per cent of non-trainers). Few point to failures in training supply as a reason for not training. ## High Performance Working "High Performance Working Practices" are those designed to increase employee discretion over their work and effectively use and develop skills that employees possess. Most establishments in Wales were engaging in practices that could be considered "high performance working practices", most commonly through providing a varied, flexible working environment where employees have discretion to do their work.1 Communication with employees was also widespread, most commonly via scheduled team meetings. In terms of people management, around two-thirds of establishments gave formal job descriptions to at least some of their employees and a half of establishments had annual performance reviews for at least some staff. However fewer used pay and incentive schemes to motivate staff: the most common scheme was to award bonuses based on overall company performance, used by 23 per cent of establishments. Larger establishments and those in South East Wales were most likely to have high performance working practices in place. ## 1 Introduction The UK Commission's Employer Skills Survey 2011 is the key UK data source on employer demand for and investment in skills. It is the first UK-wide employer skills survey and is also one of the largest employer skills surveys undertaken in the world with over 87,500 achieved interviews across the UK and over 6,000 in Wales among large and small businesses in every sector. The full UK report is published on the UK Commission website.2 This report focuses on the findings from the interviews in Wales in 2011, and how this compares to the overall UK population. A skills survey was carried out in Wales in 2005, Future Skills Wales. The approach to sampling and weighting paired with the differences in the question wording mean the data from that study is not directly comparable with the 2011 survey, therefore results from this 2005 survey are not referenced in this report. Appendix A shows data tables comparing equivalent populations in the 2011 and 2005 surveys where the questionnaire has been similar enough to allow such a comparison. This report delves into the rich data provided by the survey to set out the extent of employer demand for skills; experiences of skill deficiencies and approaches to workforce development, and how this varies among different groups of employers. Viewing this information, alongside evidence of the product strategies used by business units, enables us to look at the extent of employer ambition, and to start to explore what impact this might have on training patterns and the emergence of skill deficiencies. ## 1.1 Methodological Overview The UK Commission's Employer Skills Survey 2011 was a telephone-based survey. It was conducted in three parts: a core population survey of UK workplaces, and a (smaller) follow-up survey of workplaces which had provided training for some of their employees in the 12 months preceding the survey, looking at employers' investment in training ("Investment in Training Survey"), Below we briefly summarise the key features of the methodology adopted across the surveys. Further details can be found in Appendix C and the separate Technical Report. ## 1.2 Sampling The sample analysed in this report comprises establishments (i.e. individual sites of an organisation) that have one or more people working at them, excluding sole traders (where a site has one worker and this person also owns part or all of the business). It encompasses establishments across the full geographical spread of Wales, in all sectors of the economy (across the commercial, public and charitable spheres). It should be noted that the presence of establishments from multi-site organisations in the survey means that in some instances interviews will have been completed with more than one site of an organisation. A stratified random approach was taken to sampling the core survey, using population statistics from the Office for National Statistics' (ONS) Inter-Departmental Business Register (IDBR), and setting quotas for establishment size crossed by sector within each region. A stratified random approach was also taken for the Investment in Training survey, with targets set based on country, size, sector and the type of training establishments reported arranging for employees during the core survey. All of the employers interviewed for the follow-up surveys had previously been interviewed as part of the core survey (and had given their permission to be contacted for further research). ## 1.3 Questionnaire The core survey questionnaire was designed in several stages, with the co-operation of the four constituent nations of the UK. There were considerable pressures on the questionnaire both in terms of balancing the need for consistency across the UK with the need for continuity with legacy questionnaires; and also in terms of the drive to cover a wide range of issues without over-burdening employers and creating a lengthy questionnaire. The questionnaire was extensively piloted in May 2010 and again in February 2011, an exercise which included 10 follow-up cognitive interviews. The questionnaire used for the 2011 Investment in Training follow-up exercise was the same as that used in the "Cost of Training Survey" in England in 2009. The questionnaire used for the survey can be found on the UK Commission website and within the Technical Report. ## 1.4 Fieldwork Fieldwork for the core survey was undertaken between March and July 2011, involving interviews averaging around 24 minutes in length. Fieldwork for the follow-up survey of training expenditure was undertaken in May to July 2011, and involved more than 11,000 interviews across the UK (around 1,500 in Wales) with employers who had taken part in the first survey. Table 1.1 shows the total number of interviews in Wales in each of the two facets of the survey, along with the respective response rate for each. | | Total interviews | |----------------------------------|---------------------| | Core survey | | | | | | 6,012 | 55% | | Investment in Training follow up | | | | | | 1,501 | 69% | Response rates are shown as a proportion of all completed contacts (completes, refusals and stopped interviews). ## 1.5 Data Weighting Findings from the core survey have been weighted and grossed up to reflect the total population of establishments in Wales with one or more people working there, excluding sole traders. The weighting was designed and undertaken on an interlocking size and sector basis separately for each country. Separate weights have been generated which allow findings to be presented (a) based on the number of workplaces reporting a particular experience, and (b) based on the number of employees and/or job roles affected by different challenges. Findings from the Investment in Training Survey have been weighted and grossed up to reflect the population of training employers as defined by the weighted core survey findings. ## 1.6 Reporting Conventions The survey was carried out at an establishment level; the terms "establishment", "employer", "workplace" and "business unit" are used for this interchangeably throughout this report to avoid excessive repetition and to aid reading. The scale and scope of data collected by the UK Commission's Employer Skills Survey 2011 means that it is a valuable research resource supporting detailed and complex statistical analysis of the inter-relationships between employer characteristics, and their practices and experiences. The findings presented in this report have been produced through a more descriptive exploration of the data. The large base sizes on which most of the findings are based mean that we can have a good degree of confidence in the patterns described in the text; the document should not be read as a statistical report, however. A table showing confidence intervals is shown in Appendix F to give some indicative guidance as to what can be considered a "significant" difference at sub-group level. Throughout the report unweighted base figures are shown on tables and charts to give an indication of the statistical reliability of the figures. These figures are always based on the number of *establishments* answering a question, as this is the information required to determine statistical reliability. Therefore, for example, where percentages are based on "all vacancies", the base figure quoted is the number of establishments with vacancies. As a general convention throughout the report, figures with a base size of fewer than 25 establishments are not reported (with a double asterisk, "**", displayed instead), and figures with a base size of 25 to 49 are italicised with a note of caution. In tables, "zero" is denoted as a dash "-" and an asterisk "*" is used if the figure is larger than zero but smaller than 0.5. For more detail on the survey methodology, sampling and weighting, questionnaire design and analysis, refer to the UK Commission's Employer Skills Survey 2011: Technical Report. ## 2 Nature Of Welsh Establishments In order to give some context to the findings that are presented in this report, and to facilitate understanding of the differences in employers' experiences and practices, this section describes some of the key characteristics of the business establishments in Wales. These include their size and sector distribution; and the geographical spread of establishments across the nation. ONS figures show there were around 100,000 "in-scope" establishments in Wales in March 2010, with around 1.2 million people working in them.3 ## 2.1 Size IDBR data shows us that the majority of Welsh establishments (62 per cent) were small, employing fewer than five people. Sites employing 250 or more staff represent only one per cent of all establishments but account for one-quarter (26 per cent) of overall employment (see Figure 2.1). Distribution of establishment and employment by size is similar in Wales to the rest of the UK. | 1 to 4 | 5 to 24 | 25 to 99 | 100-249 | 250+ | |-----------------|-----------|------------|-----------|--------| | Number of | | | | | | establishments: | | | | | | 61,200 | | | | | | 29,900 | 6,200 | | | | | 1,100 | | | | | | 500 | | | | | | Employment: | | | | | | 133k | 295k | 283k | 163k | 309k | Source: IDBR March 2010 ## 2.2 Sector Sectoral analysis in this report is defined by a 14 sector split, based on the establishment's Standard Industrial Classification (SIC) 2007 code.4 IDBR statistics show that Wholesale and Retail and Business Services (this sector includes, among other things, real estate activities, consultancy, advertising and employment agencies) are the two largest sectors in terms of the number of establishments. Together, these two sectors account for more than a third (37 per cent) of establishments in Wales. When measured in terms of people working in the sector, however, the two largest sectors are Wholesale and Retail and Health and Social Work, each of which employ 16 per cent of the workforce in Wales The sector profile of Wales differs from that of the rest of the UK. The most striking difference is in the proportion of establishments in the Agriculture sector, at 10 per cent in Wales but just four per cent in the UK as a whole (with two and one per cent of all employment falling into this sector respectively). Conversely the proportion operating in Business Services is just 17 per cent in Wales compared to 24 per cent in the UK as a whole, where it is the largest sector, and 11 per cent of the workforce is employed in this sector in Wales compared to 17 per cent of the UK workforce as a whole. The Health and Social Work, Public Administration and Education sectors have a higher proportion of large establishments and employ a disproportionately high percentage of workers compared to the percentage of establishments in their sectors. For example, Education has only three per cent of all establishments, but 10 per cent of employment. The Manufacturing sector also represents a higher than average proportion of larger establishments that employ a relatively large proportion of the workforce: Manufacturing has five per cent of the enterprises in Wales, but 12 per cent of the workforce. Conversely, the Agricultural sector comprises 10 per cent of establishments, but employs only two per cent of the workforce in Wales, meaning that establishments in this sector are likely to be smaller. Most establishments in Wales (85 per cent) described themselves in the survey as operating in a commercial sphere, with small minorities operating in the public sector (seven per cent) and in the third sector (eight per cent). Establishments in the private sector tend to be relatively small, accounting for 85 per cent of total establishments, but only 68 per cent of employment. Conversely, establishments in the public sector tend to be larger than those in the private sector; these account for only seven per cent of establishments in Wales, but employ one-quarter (25 per cent) of the workforce. ## 2.3 Region As shown in Figure 2.4, South East Wales has the largest number of both establishments and employees. This region is the most built-up of the four and contains the cities of Cardiff and Newport; it accounts for over two-fifths (41 per cent) of establishments, and half (50 per cent) of the workforce in Wales. Mid Wales is the smallest region with only 11 per cent of establishments, employing seven per cent of the workforce; this might be expected as the region is predominantly rural. North Wales and South West Wales are of similar size, both holding around a fifth to a quarter of both establishments and employees. The size distribution of establishments is not uniform between regions; establishments in Mid Wales are more likely to be smaller whilst those in South East Wales and North Wales are more likely to fall into one of the larger sizebands. Throughout this report size will be highlighted as a main driver of difference for a lot of the measures; therefore understanding the different size profiles of the regions will aid the interpretation of any differences seen between the regions. Similarly, there is some difference in the sector distribution of establishments between the different regions. Mid Wales has a far higher proportion of Agriculture establishments, with over a quarter of establishments in this region falling into this sector compared to 10 per cent in Wales as a whole. In turn, it has far fewer establishments than the other regions in Construction and Wholesale and Retail. South West Wales on the other hand has a higher prevalence of Wholesale and Retail compared with the Wales average (see Table 2.1). Along with size, sectoral differences account for much of the differences seen between regions. | South | South | |--------------------------------|----------| | Mid | | | West | East | | | | | Wales | | | | | | North | | | Wales | | | | | | Wales | | | | | | Wales | | | | | | Wales | | | | | | Total number of establishments | 98,950 | | | | | % | % | | Agriculture | 10 | | Mining and Quarrying | * | | Manufacturing | 5 | | Electricity, Gas and Water | 1 | | Construction | 10 | | Wholesale and Retail | 20 | | Hotels and Restaurants | 9 | | Transport and Communications | 7 | | Financial Services | 2 | | Business Services | 17 | | Public Administration | 2 | | Education | 3 | | Health and Social Work | 7 | | Community, Social and Personal | | | Services activities | | | 7 | 7 | Source: ONS IDBR March 2010 ## 2.4 The Structure Of Establishments The size of an establishment is important in that it determines both the skills and employment challenges employers face and the ways in which they react to these challenges. However, establishments can be part of wider organisations, and this can bring a different dimension to their experience and practice. The size of an establishment does not necessarily tell a complete story about, for example, its access to skills or other resources when the establishment is part of a larger, multi-establishment (and potentially multi-firm) organisation. A third of all establishments (32 per cent) report that they are part of a larger organisation; this is broadly in line with the UK average of 36 per cent. The likelihood of an establishment being part of a larger organisation varies with size, with over four-fifths (83 per cent) of establishments with more than 250 employees reporting they are part of a larger organisation compared to just over one-fifth (23 per cent) of establishments with 1-4 employees. The survey confirms that decisions about recruitment and training are most commonly taken at site level (and this is the natural level to discuss these issues in subsequent sections of the report). The majority of establishments in Wales are single site organisations (68 per cent) and therefore have full responsibility and autonomy when it comes to decisions about recruitment and training; a further five per cent are the Head Offices of multi-site organisations, and as such we can assume that they too have full autonomy in these areas. This leaves just over one-quarter of employers which are sites within larger organisations, most of whom, nevertheless, have substantial or even complete autonomy of these issues (just 12 per cent of establishments have no input into recruitment and training decisions). ## 2.5 Business Strategies The UK Commission's Employer Skills Survey 2011 included a series of questions which asked establishments how they compared to others in their industry on a range of indicators including innovation, quality of product, price dependency and customisation. Together these indicators can be seen to give a sense of the overall type of 'product market strategy' (PMS) being adopted by the establishment. Private sector employers were asked to rate their establishments, compared to others in their industry, in terms of: - the extent to which success of products/services was dependent on price; - the extent to which they perceive their establishment to lead the way in their sector in terms of developing new products, services or techniques; - whether they compete in a market for standard/basic or premium quality products or services; - and whether they offered a standard range of goods or services, or customised products/services with substantial differences according to customer requirements. Figure 2.7 shows overall responses to each of these individual position statements; these are similar to the responses seen in the UK for the same questions. Responses to these individual product market positions were then aggregated to derive a composite product market score5 on a scale from "very low" to "very high" as illustrated in Figure 2.8. The distribution of product market strategy scores was very similar in Wales to that seen in the UK as a whole. Overall establishments were more likely to score a high level product market strategy position than a low one. A third of establishments (32 per cent) describe a product market strategy which places them in the middle of their sector, with a similar number (32 per cent) categorised as having a high or very high product strategy. A fifth of establishments scored 'low' or 'very low'; the remainder could not be classified as they had not given answers to all of the necessary questions. Base: All establishments in Wales in the private sector : 4,743 unweighted Note: 14 per cent of private sector establishments could not be classified into a PMS score as they answered "don't know" at one or more of the questions that make up the composite measure. Source: UKCESS 2011 survey Table 2.2 shows where there are differences in each sizeband; smaller establishments are more likely to have a "low" or "very low" score on the PMS scale than larger ones; these larger establishments are more likely to fall into the group with a "high" score. Wales Total 1-4 5-24 25-99 100+ Unweighted base 4,740 1,050 2,771 759 163 Column % % % % % % Very Low 5 5 4 2 1 Low 18 20 15 10 6 Medium 32 31 33 34 36 High 24 22 26 33 33 Very High 9 8 10 11 14 Base: All establishments in the private sector NB 100-249 and 250+ groups have been combined in this table to give a more robust base size Source: UKCESS 2011 There was little difference in product market strategy score between the four regions. Table 2.3 sets out the differences in the levels of product market strategy between the two designated ESF regions: West Wales and the Valleys and East Wales. There were few differences between the two regions, however, East Wales was more likely to be scored high or very high (36 per cent) than West Wales and the Valleys (30 per cent). At the low end of the scale the variation was smaller: 23 per cent were scored low or very low in West Wales and the Valleys, compared with 20 per cent in East Wales. West Wales and the Valleys East Wales Wales Total Unweighted base 2,934 1,806 4,740 Column % % % % Very Low 5 3 5 Low 18 17 18 Medium 31 33 32 High 22 27 24 Very High 8 9 9 Base: All establishments in the private sector Source: UKCESS 2011 ## 2.6 Product Market Strategy And Workforce Skill Level The business strategy adopted by an establishment will affect the skill levels it requires staff to have. The UK Commission's Employer Skills Survey uses workforce qualification levels as a means of identifying employers with high level skills requirements. For the purposes of this report workforce qualification levels are based on the distribution of Level 4 qualifications and group employers into three bands: those where fewer than 20 per cent of the workforce hold a Level 4 qualification ("Low"); those where between 20 and 80 per cent hold a Level 4 qualification ("Medium") and those where more than 80 per cent of the population hold a Level 4 qualification ("High"). Figure 2.9 shows how establishments in Wales split by these three groups, and also shows how the proportion of staff with Level 3 qualifications or above is distributed. For example, it shows that in 41 per cent of establishments, fewer than 20 per cent of the workforce hold Level 4 or above qualifications, but that in 17 per cent of establishments 80 per cent or more of the workforce hold Level 4 qualifications or above and in 33 per cent of establishments 80 per cent or more of the workforce hold Level 3 qualifications or above. Establishments in Wales reported slightly lower proportions of their workforces as qualified to Level 3 than the UK as a whole, where 41 per cent had at least 80 per cent of their staff qualified to Level 3. The difference between Wales and the UK at Level 4 was slightly less pronounced with 23 per cent of establishments across the UK having at least 80 per cent of their workforce qualified to that level. Establishments most likely to have a 'highly skilled' workforce using this definition (80 per cent or more of staff hold at least a Level 4 qualification) are most likely to be: - small establishments (23 per cent of establishments with 1-4 staff had a highly skilled workforce, compared to nine per cent of those with 5-24 staff, six per cent of those with 25-99 staff and five per cent of those with 100 or more staff), - in Business Services (31 per cent), Community, Social and Personal Services activities (22 per cent) or Transport and Storage (21 per cent), - in the East Wales ESF region (21 per cent, compared to 15 per cent in West Wales and the Valleys). Establishments who score highly in the product market strategy measure also tend to have a higher level of skills among their staff (defined as the proportion qualified to at least Level 4, see Figure 2.9). In the UK as a whole we see there is a pattern that as the product market strategy score increases the proportion of establishments with a highly skilled workforce also increases (and conversely the proportion with low skilled workforce decreases). The same holds for Wales except for the "very high" PMS score group, which drops back down to just 14 per cent with a highly skilled workforce compared to 21 per cent in the "high" PMS score group. Having set out the key characteristics of establishments in Wales, the remainder of this report now presents findings from the survey. ## 2.7 Structure Of This Report The characteristics described in this chapter will be used to analyse the UK Commission's Employer Skills Survey 2011 data for Wales in the following areas: - the work-readiness of leavers from education, which explores the incidence of recruiting education leavers and how well prepared they are for the working world; - recruitment and skill shortages, which looks at employer recruitment activity and measures the extent and causes of labour market shortages, focusing particularly on skill shortages, and identifying the impact that such labour market failure has on establishments; - internal skills mismatch, which explores the proficiency levels of establishments' existing workforce, measuring and describing skills gaps in detail, and retention issues. The survey also takes a preliminary look at the under-use of skills, where establishments report that employees have more skills and qualifications than required for their current job role; - the extent and nature of employer training and workforce development, including the investment made in training. ## 3 Work-Readiness Of Education Leavers Chapter Summary In Wales around a quarter of establishments (24 per cent) had recruited at least one education leaver in the two to three years previous to the survey. The majority of these employers found their recruits to be well prepared for work; the minority that did not most commonly put this down to a lack of experience of the working world, life experience or maturity, or to poor attitude, personality or a lack of motivation. The proportion of employers finding education leavers to be well prepared for work increased with age / educational level: - 56 per cent among those recruiting 16 year-old school leavers found them well prepared; - 65 per cent of those recruiting 17-18 year-olds from school; - 75 per cent of those recruiting 17-18 year-olds from Further Education; - 80 per cent of those recruiting from Higher Education institutions. ## 3.1 Introduction Before considering recruitment activity and skills levels more broadly (in Chapters Four and Five), this chapter looks at the recruitment and skill levels of education leavers. More specifically, it looks at the proportion of employers that have recruited anybody into their first job on leaving education in the past two to three years, before then exploring employers' perceptions of these recruits in terms of their readiness for work and their skills. Employers in Wales were asked about four groups of leavers: 16 year-olds from school, 17-18 year-old school leavers, 17-18 year-old FE college leavers, and those entering employment straight from Higher Education. Higher Education leavers could be of any age as long as they were entering their first job on leaving education. ## 3.2 Incidence Of Recruitment Of School, College And He Leavers In the last two to three years, just under one-quarter of establishments in Wales (24 per cent) had recruited at least one education leaver to their first job on leaving education. There was no variation in this proportion between Wales and the UK as a whole. More specifically, between eight and 10 per cent of establishments had taken on education leavers from each of the four groups (see Table 3.1). The larger the establishment, the more likely they were to have taken on each type of recruit from education. In part, this is simply a product of larger establishments being more likely to recruit *per se* (current recruitment activity is discussed in Chapter Four), and is a trend that holds for all levels of education leaver. There were some differences in recruitment of education leavers by sector. Establishments in Education were considerably more likely to have taken on any education leavers (45 per cent), and they were more than three times as likely as the average to have taken on leavers from university or Higher Education (37 per cent, compared with 10 per cent of all establishments). Recruitment from education was also particularly common in the Health and Social Work sector (32 per cent), Hotels and Restaurants (29 per cent) and Community, Social and Personal Service Activities (29 per cent). Establishments in the industries of Agriculture (11 per cent) and Transport and Communications (14 per cent) were the least likely to have taken on any education leavers. There was some variation between different regions in Wales. Establishments in South East Wales were most likely to have recruited education leavers (26 per cent), while only a fifth (20 per cent) in Mid Wales had recruited staff of this kind. Although the proportion of establishments who had recruited education leavers was equal between ESF regions, establishments in East Wales were more likely to have recruited university or HE leavers. This ties in with the finding presented in Chapter 2 that establishments in this region were more likely to have a highly skilled workforce. Table 3.1 shows these figures in full. Any 16 year olds recruited to first job from school 17 or 18 year olds recruited to first job from school 17 or 18 year olds recruited to first job from FE College Recruited to their first job from University or other Higher Education institution Unwtd base % % % % % Wales Total 6,012 24 8 8 10 10 UK total 87,572 24 7 9 8 10 Size 1-4 1,216 12 4 3 4 4 5-24 3,474 38 12 14 15 15 25-99 1,074 59 18 28 29 37 100-249 151 69 21 33 33 53 250+ 97 73 32 53 55 61 Sector Agriculture 102 11 2 2 3 4 Mining and Quarrying 22 ** ** ** ** ** Manufacturing 468 27 9 13 10 8 Electricity, Gas and Water 111 25 6 10 6 9 Construction 503 23 13 6 8 4 Wholesale and Retail 1,069 26 11 12 14 8 Hotels and Restaurants 675 29 12 15 14 12 Transport and Communications 439 14 4 3 4 7 Financial Services 173 22 5 7 7 15 Business Services 791 21 5 5 7 13 Public Administration 130 20 2 9 10 17 Education 391 45 4 7 13 37 Health and Social Work 580 32 4 9 14 17 Community, Social and Personal Services activities 558 29 9 10 13 9 Region North Wales 1,431 24 8 8 9 11 Mid Wales 798 20 5 7 8 8 South West Wales 1,389 22 8 8 10 8 South East Wales 2,394 26 8 9 11 12 ESF Region West Wales and the Valleys 3,732 24 8 9 10 9 East Wales 2,276 24 7 8 9 12 Base: All establishments '**' denotes base size under 25: too low to report. ## 3.3 Perceived Work-Readiness Of Education Leavers In order to gauge the perceived work-readiness of recruits that had been taken on in the last two to three years straight from education, employers who had taken any on were asked whether they considered these recruits to be very well prepared, well prepared, poorly prepared or very poorly prepared for work. Employers were more likely to feel that recruits from education were well prepared for work than poorly prepared, and the perceived level of work-readiness increases with the amount of time recruits have spent in education (see Figure 3.1). Four-fifths (80 per cent) thought that university or HE leavers were well prepared, compared with only 56 per cent who thought the same of 16 year old school leavers. This is similar to the pattern seen across the UK. There are a number of possible reasons why recruits from Higher Education may be seen as better prepared for work than younger recruits: it could be because of the additional time graduates have spent in education or because employers may invest more resources in graduate recruitment and therefore be likely to find more suitable individuals. It may also simply be because graduates are older and therefore more mature generally. There are also various hypotheses that could explain why 17-18 year-old FE recruits are seen as being more work-ready than contemporaries recruited from schools. These include college students being more likely to be studying vocational courses, and college students also being more likely to combine work and learning and therefore to have amassed more work-relevant experience. Establishments in South East Wales were less likely to see their university leavers as well prepared for work; just 74 per cent did so compared to 80 per cent in Wales as a whole. Those in Mid Wales were least likely to see 16 year-old school leavers as well prepared, with 49 per cent saying they were compared to 56 per cent across Wales as a whole. Establishments in North Wales were most likely to find university leavers well prepared or very well prepared for work (88 per cent found them so). Figure 3.2 shows perceived work-readiness by region. ## 3.4 Skills And Attributes Lacking Among Education Leavers Those employers who reported that the education leavers they had recruited were poorlyprepared for work were asked to indicate what skills or attributes they were lacking. The key findings are as follows (see Table 3.2): - a lack of working world or life experience or maturity was the reason most commonly stated among all groups. This was a particular issue in relation to younger recruits (21 per cent of establishments recruiting 16 year-olds from school), and was more likely to be cited in relation to 17-18 year-old school leavers than for FE college leavers of the same age (18 per cent compared with 10 per cent); - poor attitude, personality or a lack of motivation was commonly reported by employers recruiting 16 to 18 year-olds. This was an issue for approaching one-in-five (19 per cent) of employers taking on 16 year-old school leavers, and 14 per cent of those recruiting 17-18 year-old school leavers. This lessens as the recruits get older: nine per cent of those recruiting 17-18 year-old FE college leavers and just four per cent taking on graduates felt they had a poor attitude, personality or a lack of motivation; - slightly under one-in-ten establishments taking on each type of education leaver felt they lacked specific skills or competencies, such as technical or job-specific skills; - among each of the groups, only a small proportion of employers cited a lack of literacy / numeracy skills (i.e. basic skills). 16 year olds recruited to first job from school 17 or 18 year olds recruited to first job from school 17 or 18 year olds recruited to first job from FE College Recruited to their first job from University or other Higher Education institution Column % % % % % Skills Base (unwtd) 808 1,011 1,084 1,172 Lack of working world / life experience 21 18 10 7 Poor attitude / personality or lack of motivation 19 14 9 4 Lack required skills or competencies 9 8 8 7 Lack of common sense 6 4 1 3 Literacy/numeracy skills 3 4 3 2 Poor education 6 4 1 1 Base: Establishments who have recruited education leavers from each type in the last 2-3 years ## 3.5 Conclusion For those employers in Wales who recruit education leavers, the majority find them well prepared for work. Only a minority of employers find their recruits from education to be poorly prepared for work. In Wales 24 per cent of employers had recruited someone straight from education in the 2 to 3 years prior to the survey, in line with the proportion also seen across the UK as a whole. Employers' views of the preparedness of such recruits increases both with age of recruit and time spent in education: 56 per cent of establishments that had taken on 16 year-old school leavers found them to be well prepared, rising to 65 per cent that had taken on 17-18 year-old school leavers, 75 per cent that had taken on Further Education leavers and 80 per cent that had taken on Higher Education leavers. There may be several reasons why employers see recruits from Higher Education as better prepared for work than younger recruits. It may be as a result of the additional time graduates have spent in education or it may be related to employers investing more resource in graduate recruitment, so that they are more likely to find more suitable individuals, or simply because graduates are older and therefore more experienced and mature generally. In Wales (as in the rest of the UK) there is a difference between employer views on 17-18 year-old FE college leavers and 17-18 year-old school leavers, with the former found to be better prepared. There could be a number of reasons for this, including FE college students being more likely to be studying vocational courses. FE college students may also be more likely to combine work and learning than their counterparts at school, and therefore have more work experience, which appeals to employers. In Mid Wales establishments were less likely to recruit school leavers, whether in the 16 year-old or 17-18 year-old categories, but those that did were more likely to say the 16 year-old school leavers they have recruited were poorly prepared for work. Education leavers of this age might be expected to seek employment locally on leaving school, perhaps more so than their elder contemporaries, so this could be an indicator that the pre-16 schooling in the region is not well matched to the employment available in the region or an indicator of the of work-readiness by employers. For the small minority of employers who find education leavers poorly prepared the main reason is a lack of working world experience, life experience or maturity. Again this was most common for younger recruits (21 per cent of those who recruited 16 year-olds compared to just seven per cent of Higher Education leavers). This raises questions about how to improve the opportunities for pupils to gain experience in a workplace to help prepare them for their first job. Following this, concerns about attitudes and motivation were also important, whereas concerns about education or literacy and numeracy skills are cited by a very small number of employers, illustrating that they are seen to be less of a problem by employers. ## 4 Employers, Recruitment And Skill Shortages Chapter Summary At the time of interview, 11 per cent of establishments had a vacancy; this equates to around 25,500 vacancies across Wales. The labour market is largely able to meet the requirements of most establishments, however four per cent of establishments had a vacancy they considered to be "hard-to-fill". This equates to 8,500 hard-to-fill vacancies, a third of all vacancies. Three per cent of establishments reported having vacancies at the time of the survey that they had difficulties filling due to a lack of skills, qualifications or experience in applicants for the role (a "skill-shortage vacancy"). This equates to 5,700 skill-shortage vacancies across Wales; 22 per cent of all vacancies. It is amongst Associate Professional and Machine Operative roles where employers experience the greatest difficulties in meeting their demand for skills from the available labour market, far more so than in the UK as a whole. While skill-shortage vacancies may not be common, where they do exist their impact can be significant; almost all establishments with hard-to-fill vacancies (97 per cent) reported they were having an impact on the establishment. The impact that they have on the workload of existing staff risks knock-on effects on morale and retention, and was reported by 86 per cent of establishments with hard-to-fill vacancies. More direct impacts on performance were also commonly cited (50 per cent say they struggle to meet customer service objectives, 48 per cent have had to delay developing new products or services, 41 per cent have lost business to competitors and 41 per cent have seen an increase in operating costs). ## 4.1 Introduction This chapter discusses the demand for and availability of recruits from the labour market. Specifically it explores current vacancies across Wales at the time of research; the ability of the market to meet employer demand for new staff and the level of hard-to-fill vacancies. It then looks at the causes of recruitment difficulties focusing particularly on those vacancies that are hard-to-fill specifically as a result of a lack of skills, qualifications or experience (skill-shortage vacancies) and the impact of hard-to-fill vacancies on establishments experiencing them. ## 4.2 What Is The Level Of Demand For New Staff? Overall, one-in-ten establishments (11 per cent) in Wales had a current vacancy at the time they were interviewed. This is in line with the UK average (12 per cent). In total there were 25,500 vacancies across Wales at the time of the survey equating to 2.2 vacancies per 100 employees. The incidence of vacancies increases in line with establishment size, with almost twothirds (65 per cent) of establishments with 250+ staff, and half of establishments with 100-249 staff, having a current vacancy, compared with only seven per cent of the smallest establishments. This is logical given that larger employers will have more jobs which have the potential to be vacant at any one time. However, vacancy density (the number of vacancies per 100 employees) showed the opposite pattern, with the smallest establishments showing the highest vacancy density. This mirrors the pattern seen across the UK as a whole as well. There was also some variation in the proportion of establishments reporting vacancies and in vacancy density according to sector. The Education (19 per cent), Health and Social Work (17 per cent), and Manufacturing (17 per cent) sectors were most likely to report at least one vacancy at the time of the survey. The sectors least likely to have current vacancies were Agriculture (two per cent) and Construction (five per cent). The highest density of vacancies was in the Electricity, Gas and Water (4.5 per 100 employees), Community, Social and Personal Services activities (3.9 per 100 employees), and Business Services (3.4 per 100 employees) sectors. This is similar to the sectoral patterns seen in the UK as a whole. The exception is the Electricity, Gas and Water sector which has the highest vacancy density in Wales. In contrast, at the UK level, the sector has a vacancy density similar to the UK average for all sectors. There was not much variation between regions in incidence of vacancies, however the vacancy density was significantly higher than the average in Mid Wales (4.5). This could in part be driven by the higher prevalence of smaller establishments in Mid Wales. % of Number of Vacancy establishments vacancies density with a vacancy Unwtd base % Rounded to nearest 100 % Wales total 6,012 11 25,500 2.2 UK total 87,572 12 635,900 2.3 Size 1-4 1,216 7 7,500 5.7 5-24 3,474 14 6,600 2.2 25-99 1,074 28 5,800 2.1 100-249 151 50 2,500 1.5 250+ 97 65 3,200 1.0 Sector Agriculture 102 2 500 1.9 Mining and Quarrying 22 ** ** ** Manufacturing 468 17 2,100 1.5 Electricity, Gas and Water 111 14 700 4.5 Construction 503 5 1,000 1.6 Wholesale and Retail 1,069 12 3,500 1.8 Hotels and Restaurants 675 14 2,500 3.1 Transport and Communications 439 11 1,900 3.0 Financial Services 173 11 500 1.6 Business Services 791 11 4,500 3.4 Public Administration 130 16 2,000 2.3 Education 391 19 1,600 1.3 Health and Social Work 580 17 2,800 1.5 Community, Social and Personal Services activities 558 16 1,900 3.9 Region North Wales 1,431 10 4,400 1.7 Mid Wales 798 11 3,600 4.5 South West Wales 1,389 11 5,300 2.1 South East Wales 2,394 12 12,300 2.1 ESF Region West Wales and the Valleys 3,732 11 14,700 2.1 East Wales 2,276 13 10,900 2.3 Base: All establishments. Percentages in Column 3 are based on all employment, percentages therefore represent the number of vacancies as a proportion of all employment. Number of vacancies rounded to nearest 100. '**' denotes base size under 25: too low to report. As was seen in the UK as a whole, establishments that are leading the way in their industries in terms of innovation, quality and customisation are more active in the recruitment market: the likelihood of establishments having a vacancy increases with their Product Market Strategy (PMS) rating,6 from five per cent among those with a "Very Low" PMS rating to 13 per cent among those with a "Very High" PMS rating. Establishments with vacancies in the "Very Low" group also had fewer vacancies per establishment, with a mean of 1.3 vacancies compared to the Wales average of 2.3. The level of vacancies varied slightly according to occupational type.7 The level of vacancies was highest for Sales and Customer Service roles, Associate Professional, and Elementary occupations. Together, these three groups made up 45 per cent of all vacancies in Wales. However, this might relate to the numbers employed in those occupations, which is illustrated by a much higher vacancy density amongst the Associate Professional group of 5.7 per cent. The level of vacancies was lowest for managers: this occupation accounted for only three per cent of all vacancies in Wales and had a vacancy density of 0.4 per cent (see Table 4.2). | % of all | Number of | Vacancy | |------------------------------------|--------------|------------| | vacancies | | | | | | | | vacancies | | | | | | | | density | | | | | | | | Column % | | | | Occupation | | | | | | | | % | | | | Rounded to nearest | | | | 100 | | | | | | | | % | | | | | | | | Base: | 1,100 | 6,012 | | Managers | | | | | | | | 3 | | | | | | | | 800 | | | | | | | | 0.4 | | | | | | | | Professionals | | | | | | | | 11 | | | | | | | | 2,800 | | | | | | | | 2.2 | | | | | | | | Associate Professionals | | | | | | | | 15 | | | | | | | | 3,700 | | | | | | | | 5.7 | | | | | | | | Admin / Clerical | | | | | | | | 11 | | | | | | | | 2,800 | | | | | | | | 1.8 | | | | | | | | Skilled Trades | | | | | | | | 10 | | | | | | | | 2,700 | | | | | | | | 2.4 | | | | | | | | Caring, Leisure and Other services | | | | | | | | 14 | | | | | | | | 3,500 | | | | | | | | 3.0 | | | | | | | | Sales / Customer services | | | | | | | | 15 | | | | | | | | 3,900 | | | | | | | | 2.9 | | | | | | | | Machine Operatives | | | | | | | | 6 | | | | | | | | 1,500 | | | | | | | | 1.6 | | | | | | | | Elementary | | | | | | | | 14 | | | | | | | | 3,700 | | | | | | | | 2.2 | | | | | | | Base: Column 1: all vacancies in up to six occupational groups followed up, column 2 and 3: all establishments "Figures are based on all employment, percentages in column 1 therefore represent the proportion of vacancies accounted for by each occupation and column 3 the number of vacancies as a proportion of all employment in that occupation. Number of vacancies rounded to nearest 100 ## 4.3 The Ability Of The Market To Meet Employer Demand For New Staff Four per cent of establishments in Wales reported having at least one hard-to-fill vacancy at the time of research; this figure matches the UK average (also four per cent). This equates to a total of 8,500 hard-to-fill vacancies, representing a third (33 per cent) of all vacancies across Wales (see Table 4.3). This is higher than the proportion of hard-to-fill vacancies in the UK as a whole, where just under a quarter (23 per cent) of vacancies were deemed "hard to fill". As seen with vacancies in general, the proportion of establishments reporting a hard-to-fill vacancy increased in line with size of establishment: larger businesses were more likely to find a vacancy hard to fill. Only three per cent of the smallest establishments reported a hard-to-fill vacancy, compared with nine, 12 and nine per cent for the three largest size categories. However, the *proportion* of vacancies considered hard-to-fill decreased as the size of the establishment increased. Among the smallest establishments, almost half of all vacancies (47 per cent) were considered hard-to-fill, while for establishments with 250+ staff this proportion was only two per cent. Establishments in the Electricity, Gas and Water (nine per cent), Manufacturing (eight per cent) and Hotel and Restaurant (eight per cent) sectors were most likely to have at least one hard-to-fill vacancy; this is similar to the sectoral pattern seen in the UK as a whole, with the exception of Electricity, Gas and Water. This sector also had a higher vacancy density in Wales than in the rest of the UK (see previous section). The incidence of hardto-fill vacancies in Wales was lowest in the Agriculture, Public Administration and Education sectors (all two per cent). The proportion of vacancies considered hard-to-fill was highest in Public Administration (49 per cent, although the small base size for this sector means figures need to be treated with caution), Hotels and Restaurants (44 per cent) and Business Services (40 per cent). There was limited variation between regions in the proportion of establishments reporting any hard-to-fill vacancies (ranging from three per cent to six per cent). However, twothirds (65 per cent) of all vacancies in Mid Wales were hard-to-fill, suggesting a shortage of suitable applicants in this particular area. In other regions, between a quarter and a third of vacancies were hard to fill. % of % of establishment vacancies Number of hard-to-fill s with a hardthat are hard vacancies to-fill vacancy to fill Unwtd Unwtd base % base % Rounded to nearest 100 Wales total 6,012 4 8,500 1,100 33 UK 87,572 4 143,600 17,166 23 Size 1-4 1,216 3 3,600 95 47 5-24 3,474 5 2,300 567 36 25-99 1,074 9 2,100 304 36 100-249 151 12 400 74 18 250+ 97 9 100 60 2 Sector Agriculture 102 2 500 4 ** Mining and Quarrying 22 ** ** 3 ** Manufacturing 468 8 600 85 30 Electricity, Gas and Water 111 9 200 16 ** Construction 503 3 400 39 37 Wholesale and Retail 1,069 3 800 187 23 Hotels and Restaurants 675 8 1,100 152 44 Transport and Communications 439 6 700 89 39 Financial Services 173 3 100 22 ** Business Services 791 4 1,800 138 40 Public Administration 130 2 1,000 25 49 Education 391 2 100 94 6 Health and Social Work 580 5 500 126 19 Community, Social and Personal Services activities 558 5 600 120 33 Region North Wales 1,431 3 1,200 246 28 Mid Wales 798 6 2,300 153 65 South West Wales 1,389 5 1,800 255 33 South East Wales 2,394 4 3,200 446 26 ESF Region West Wales and the Valleys 3,732 4 4,900 668 33 East Wales 2,276 4 3,700 432 34 Base: Columns 1 and 2: all establishments; Column 3: all establishments with vacancies. Percentages in Column 3 are based on all vacancies, rather than all establishments with vacancies; figures therefore show the percentage of vacancies which are hard-to-fill. Number of hard-to-fill vacancies rounded to nearest 100. '**' denotes base size under 25: too low to report. Figures in italics denote base size <50: treat figures with caution. The proportion of vacancies that are hard to fill is lowest in the Administrative and Clerical occupations8 (nine per cent of all vacancies for this occupation type) and lowest in absolute terms among Managers (which account for only one per cent of all hard-to-fill vacancies in Wales). By contrast, 71 per cent of vacancies for Machine Operatives are hard to fill, along with 51 per cent of vacancies for Associate Professionals. This is much higher than in the UK, where 22 and 23 per cent of vacancies in these occupations respectively are deemed hard-to-fill. In the UK it is Skilled Trades vacancies that are most commonly hard to fill; however the proportion of vacancies in Skilled Trades that are hard to fill is the same in Wales and in the UK (41 per cent). It was reported at the beginning of this section that the proportion of vacancies that are hard to fill in Wales is higher than the UK average; Table 4.4 suggests that this is primarily in Machine Operatives, Associate Professionals, Caring, Leisure and Other Services and Elementary occupations, all of which are higher than the UK average. | Number of hard-to- | |------------------------------------| | fill vacancies | | | | that are hard to fill | | | | Column % | | Unwtd | | Base: | | % | | | | Occupation | | | | Rounded to | | nearest 100 | | | | Managers | | | | 100 | | | | 69 | | 11 | | | | Professionals | | | | 700 | | | | 179 | | 24 | | | | Associate Professionals | | | | 1,900 | | | | 150 | | 51 | | | | Admin / Clerical | | | | 200 | | | | 174 | | 9 | | | | Skilled Trades | | | | 1,100 | | | | 164 | | 41 | | | | Caring, Leisure and Other services | | | | 1,600 | | | | 152 | | 45 | | | | Sales / Customer services | | | | 600 | | | | 164 | | 15 | | | | Machine Operatives | | | | 1,000 | | | | 86 | | 71 | | | | Elementary | | | | 1,300 | | | | 211 | | 36 | | | Base: Columns 1 and 2 all establishments; Column 3 all establishments with vacancies in each occupation. Percentages in Column 3 are based on all vacancies, rather than all establishments with vacancies; figures therefore show the percentage of vacancies which are hard-to-fill. Number of hard-to-fill vacancies rounded to nearest 100. '*' denotes a figure larger than zero but smaller than 0.5. ## 4.4 Causes Of Hard-To-Fill Vacancies Understanding the causes of hard-to-fill vacancies is clearly a prerequisite to introducing effective measures aimed at easing recruitment difficulties and improving the effectiveness of the labour market. Most importantly, it can identify where there are issues finding applicants with the requisite skills to fill the role. The causes can be broadly split into three areas: issues with the quality of applicants, the quantity of applicants, and contextual factors such as issues with the role, organisation or the establishment's recruitment systems. The main causes of hard-to-fill vacancies tend to be related to the quality of the applicants, i.e. a lack of skills, qualifications, experience or the attitude of applicants, with these factors cited as a cause of 60 per cent of hard-to-fill vacancies. This is similar overall to the UK (where such factors were cited for 62 per cent of vacancies), however employers in Wales are much less likely than the UK average to say applicants lack experience or have a poor attitude. The quantity of applicants is also an issue, cited as a problem in 44 per cent of hard-to-fill vacancies. Quantity of applicants was only an issue for a third of hard-to-fill vacancies in the UK as a whole, in particular "not enough people interested in doing this type of job", which was a cause in 33 per cent of hard-to-fill vacancies in Wales compared to just 22 per cent in the UK as a whole. Contextual factors were slightly more likely to be a factor in Wales (40 per cent) than the UK (36 per cent); the main difference was in "remote location / poor public transport" which was an issue in 12 per cent of hard-to-fill vacancies in Wales compared to just seven per cent in the UK as a whole. Reasons mentioned by five per cent or more of the base shown. Note: Summed percentages exceed 100 per cent because of multiple responses. The perceived causes of hard-to-fill vacancies vary according to sector. Notable differences include: - More than three-quarters (77 per cent) of hard-to-fill vacancies in the Business Services sector are caused by a lack of applicants with the required skills, and just under two-thirds (64 per cent) by a lack of interest in the type of work offered. - Shift work and unsociable working patterns were more likely to cause hard-to-fill vacancies in the Hotels and Restaurants sector (21 per cent compared to seven per cent across all sectors. - Poor terms and conditions were particularly likely to cause hard-to-fill vacancies in the Hotels and Restaurants (41 per cent) and Transport and Communications (26 per cent) sectors. By region, a general lack of interest in the job role was a particular issue in Mid Wales (75 per cent compared with 33 per cent across Wales as a whole), as was a lack of applicants with the required skills (61 per cent compared with 36 per cent overall). Hard to fill vacancies in South East Wales were more likely to be caused by a low number of applicants generally (28 per cent compared with 15 per cent overall), while the main factor in South West Wales was the remote location and lack of public transport (33 per cent compared with 12 per cent overall). Hard-to-fill vacancies in North Wales were less likely to be due to difficulties finding people with the required qualifications (five per cent) but slightly more likely than average to be down to a lack of applicants with the required attitude, motivation or personality. There were few differences between the ESF regions. The differences present suggest some problems with supply in West Wales and the Valleys, with 39 per cent of establishments with hard-to-fill vacancies saying that there were not enough people interested in doing the type of job vacant, and 25 per cent saying that they found a lack of qualifications the company demands. The respective figures for East Wales were 22 per cent and 17 per cent. Low number of applicants with the required skills Not enough people interested in doing this type of job Lack of qualifications the company demands Low number of applicants generally Poor terms and conditions (e.g. pay) offered for post Remote location/poor public transport Lack of work experience the company demands Low number of applicants with the required attitude, motivation or personality Job entails shift work/unsociable hours Poor recruitment channels / mechanisms Base (unwtd) % % % % % % % % % % Wales total 377 36 33 19 15 13 12 10 9 7 5 UK total 5,160 38 22 14 15 13 7 19 16 8 2 Size 1-4 43 48 56 22 9 18 3 6 2 4 - 5-24 219 35 17 9 13 11 11 17 19 12 * 25-99 90 15 12 26 31 9 29 9 8 7 21 100-249 17 ** ** ** ** ** ** ** ** ** ** 250+ 8 ** ** ** ** ** ** ** ** ** ** Sector Agriculture 2 ** ** ** ** ** ** ** ** ** ** Mining and Quarrying 3 ** ** ** ** ** ** ** ** ** ** Manufacturing 31 62 12 22 4 14 3 8 19 3 - Electricity, Gas and Water 8 ** ** ** ** ** ** ** ** ** ** Construction 19 ** ** ** ** ** ** ** ** ** ** Wholesale and Retail 46 13 38 2 33 5 3 14 15 12 - Hotels and Restaurants 72 22 15 1 13 41 13 14 11 21 1 Transport and Communications 45 44 18 12 14 26 6 8 8 3 - Financial Services 6 ** ** ** ** ** ** ** ** ** ** Business Services 51 77 64 9 4 3 6 18 4 2 - Public Administration 4 ** ** ** ** ** ** ** ** ** ** Education 10 ** ** ** ** ** ** ** ** ** ** Health and Social Work 41 35 20 11 11 19 13 6 13 15 - 39 20 26 17 16 14 11 4 22 8 1 Community, Social and Personal Services activities Region North Wales 92 26 17 5 14 12 10 9 19 14 - Mid Wales 59 61 75 25 3 9 8 4 2 4 * South West Wales 95 27 17 13 9 11 33 15 7 8 - South East Wales 131 27 17 22 28 17 5 13 11 6 14 ESF Region West Wales and the Valleys 250 39 39 25 16 13 9 16 12 9 1 East Wales 127 35 22 17 8 21 9 14 9 7 ** Base: All establishments reporting hard-to-fill vacancies Results are based on hard-to-fill vacancies rather than establishments with hard-to-fill vacancies; the figures therefore show the proportion of hard-to-fill vacancies caused by each factor reported by employers. '-' denotes a figure of zero; '*' denotes a figure larger than zero but smaller than 0.5. '**' denotes base size under 25: too low to report. Figures in italics denote base size <50: treat figures with caution. ## 4.5 Impact Of Hard-To-Fill Vacancies Having established the perceived causes of hard-to-fill vacancies, this section focuses on the impact of all hard-to-fill vacancies on employers. The vast majority (97 per cent) of establishments with hard-to-fill vacancies reported that they had an impact on the establishment; just three per cent had seen no impact. This is a slightly higher level of establishments seeing an impact than was seen in the UK as a whole, where 94 per cent of establishments reported their hard-to-fill vacancies were having an impact. The vast majority of establishments with hard to fill vacancies (86 per cent) reported that they increase the workload and demand on existing staff. Half (50 per cent) reported that they caused difficulties meeting customer service objectives and similar proportions experienced delays to the development of new products or services (48 per cent), business lost to competitors (41 per cent), or increased operating costs (41 per cent). This is similar to the impacts seen in the UK. Increase workload for other staff Have difficulties meeting customer services objectives Delay developing new products or services Lose business or orders to competitors Experience increased operating costs Have difficulties introducing new working practices Withdraw from offering certain products or services altogether Have difficulties introducing technological change Outsource work Have difficulties meeting quality standards No impact Base (unwtd) % % % % % % % % % % % Wales total 377 86 50 48 41 41 36 33 29 28 27 3 UK total 5,160 83 45 41 42 39 32 26 22 26 34 6 Size 1-4 43 84 57 59 51 30 33 44 36 32 57 2 5-24 219 89 47 42 37 48 39 27 24 22 47 5 25-99 90 91 33 34 24 54 35 20 21 27 27 5 100-249 17 ** ** ** ** ** ** ** ** ** ** ** 250+ 8 ** ** ** ** ** ** ** ** ** ** ** Sector Agriculture 2 ** ** ** ** ** ** ** ** ** ** ** Mining and Quarrying 3 ** ** ** ** ** ** ** ** ** ** ** Manufacturing 31 90 72 72 61 27 37 41 63 68 12 1 Electricity, Gas and Water 8 ** ** ** ** ** ** ** ** ** ** ** Construction 19 ** ** ** ** ** ** ** ** ** ** ** Wholesale and Retail 46 93 68 54 58 47 41 32 32 9 35 5 Hotels and Restaurants 72 85 46 43 46 42 19 35 10 15 43 3 Transport and Communications 45 74 54 58 50 54 53 63 23 44 23 - Financial Services 6 ** ** ** ** ** ** ** ** ** ** ** Business Services 51 89 46 29 19 58 21 29 34 21 20 5 Public Administration 4 ** ** ** ** ** ** ** ** ** ** ** Education 10 ** ** ** ** ** ** ** ** ** ** ** Health and Social Work 41 84 30 36 14 42 44 30 22 24 24 6 39 95 58 56 48 18 56 19 26 33 54 4 Community, Social and Personal Services activities Region North Wales 92 81 37 51 39 42 37 27 23 26 27 4 Mid Wales 59 98 50 56 38 25 36 54 35 25 14 1 South West Wales 95 83 41 33 31 48 17 22 23 36 17 3 South East Wales 131 86 62 54 50 43 49 34 34 25 39 4 ESF Region West Wales and the Valleys 250 84 46 45 43 42 34 27 27 32 22 4 East Wales 127 91 57 55 39 38 41 44 33 20 37 2 Base: All establishments reporting hard-to-fill vacancies '-' denotes a figure of zero; '*' denotes a figure larger than zero but smaller than 0.5. '**' denotes base size under 25: too low to report. Figures in italics denote base size <50: treat figures with caution. By ESF region some differences emerge in the types of impacts felt by each group. Establishments in East Wales are more likely to have suffered impacts on their establishment's outputs and ability to perform its role. They are more likely to say their current outputs are affected, with 57 per cent (compared to 46 per cent in West Wales and the Valleys) saying it caused difficulties in meeting customer service objectives, 37 per cent (compared to 22 per cent) difficulties in meeting quality standards and 44 per cent (compared to 27 per cent) have had to withdraw certain product and service offerings altogether. To a lesser extent establishments in East Wales are more likely to say the hard-to-fill vacancies are causing difficulties or delays in developing new products and services (55 per cent compared to 45 per cent), introducing new working practices (41 per cent compared to 34 per cent) and introducing technological change (33 per cent compared to 27). Conversely establishments in West Wales and the Valleys were more likely to have lost out on business orders (43 per cent compared to 39 per cent), experienced increased operating costs (42 per cent compared to 38), or dealt with it by outsourcing work (32 per cent compared to 20 per cent). This suggests that establishments in East Wales are more likely to be coping by holding back on quality and innovation, whereas those in West Wales and the Valleys are more likely to be "taking the hit" financially to maintain performance. ## 4.6 Measures Taken To Address Hard-To-Fill Vacancies The survey explored the measures that employers take to fill their hard-to-fill vacancies. Figure 4.3 shows that the vast majority (80 per cent) do take specific measures to address this issue, while a fifth (20 per cent) reported that they do not do anything. Given that most said that their hard-to-fill vacancies were having an impact, there are clearly some establishments who are suffering but are not taking any action to rectify this. Reasons for this might be that the employer does not have the knowledge or resource to take action, or possibly that hard-to-fill vacancies have persisted long enough in the sector that employers are simply used to working around them. Most often, employers try to address the issue of hard-to-fill vacancies by using new recruitment methods and/or channels (28 per cent) or by increasing expenditure on advertising or recruitment (27 per cent). Smaller amounts look for internal solutions such as redefining existing jobs (15 per cent), or increasing training provided to the existing workforce (seven per cent). ## 4.7 Skill-Shortage Vacancies As discussed above, recruitment difficulties are commonly caused by issues relating to the applicants, be it quality or quantity. Hard-to-fill vacancies caused specifically by a lack of skills, qualifications or **experience** among applicants are known as "skill-shortage vacancies."9 Where there is an issue with the attitude, personality or motivation of applicants, these are not skill-shortage vacancies. Figure 4.4 shows a "map" of how skillshortage vacancies (SSVs) are defined. ## 4.8 The Incidence, Volume, Density And Distribution Of Skill-Shortage Vacancies For the vast majority of establishments, demand for skills is met through successful recruitment (or through their current workforce, as will be explored in the next chapter). Three per cent of establishments reported having vacancies at the time of the survey that they were having difficulties filling due to a lack of skills, qualifications or experience in applicants for the role (a "skill-shortage vacancy"), the same as the proportion reporting skill-shortage vacancies in the UK as a whole. In absolute terms this equates to 5,700 vacancies resulting from skill-shortages. The proportion of all vacancies in Wales that are caused by skill shortages is 22 per cent, as shown in Table 4.7. This is slightly higher than the UK average, where 16 per cent of all vacancies had skill shortages as a contributing factor. The incidence of hard-to-fill and skill-shortage vacancies is driven by size: larger establishments are more likely to have vacancies as well as being more likely to find those vacancies hard-to-fill due to skill shortage. However, as a proportion of vacancies, the picture is reversed: smaller establishments, although less likely to have any vacancies, are more likely to find them hard-to-fill due to skill shortage. Skill-shortage vacancies in establishments with fewer than 25 employees accounted for over two-thirds (79 per cent) of all skill-shortage vacancies in Wales at the time of the research (over 4,400 positions). The sectors most likely to report a skill-shortage vacancy were Manufacturing and Electricity, Gas and Water (both seven per cent of establishments). However, the highest proportion of skill-shortage vacancies was seen in the Business Services sector, where two-fifths (39 per cent) of all vacancies were skill-shortage vacancies. The area most affected by a high density of skill-shortage vacancies is Mid Wales, where almost three-fifths (59 per cent) of vacancies were skill-shortage vacancies (compared with 15 per cent to 18 per cent in other regions). This region has significantly higher skillshortage vacancy density compared to the UK average, while the other three regions cluster around the UK average of 16 per cent. This shows that it is this region driving the difference between Wales and the rest of the UK. Regarding ESF regions, skill-shortage vacancies were more prevalent in East Wales (28 per cent) than in West Wales and the Valleys (17 per cent). % of Number of % of vacancies establishments SSVs that are SSVs with an SSV Unwtd Unwtd base % base % Rounded to nearest 100 Wales total 6,012 3 5,700 1,100 22 UK 87,572 3 103,500 17,116 16 Size 1-4 1,216 3 2,800 95 38 5-24 3,474 4 1,600 567 25 25-99 1,074 6 800 304 13 100-249 151 10 400 74 15 250+ 97 8 * 60 2 Sector Agriculture 102 2 500 4 ** Mining and Quarrying 22 ** ** 3 ** Manufacturing 468 7 600 85 27 Electricity, Gas and Water 111 7 100 16 ** Construction 503 2 300 39 28 Wholesale and Retail 1,069 2 400 187 12 Hotels and Restaurants 675 5 500 152 21 Transport and Communications 439 5 500 89 25 Financial Services 173 3 100 22 ** Business Services 791 4 1,800 138 39 Public Administration 130 1 100 25 4 Education 391 2 100 94 5 Health and Social Work 580 3 400 126 13 Community, Social and Personal Services activities 558 3 300 120 18 Region North Wales 1,431 2 800 246 17 Mid Wales 798 5 2,100 153 59 South West Wales 1,389 4 900 255 18 South East Wales 2,394 3 1,800 446 15 ESF Region West Wales and the Valleys 3,732 3 2,600 668 17 East Wales 2,276 3 3,100 432 28 Base: Columns 1 and 2: all establishments; Column 3: all establishments with vacancies. Percentages in Column 3 are based on all vacancies, rather than all establishments with vacancies; figures therefore show the percentage of vacancies which are hard to fill due to skillshortages. Number of hard-to-fill vacancies rounded to nearest 100. '**' denotes base size under 25: too low to report. Figures in italics denote base size <50: treat figures with caution. '*' denotes a figure larger than zero but smaller than 0.5. The greatest volume of skill-shortage vacancies were reported in Associate Professional, Skilled Trades and Elementary occupations. Together these accounted for three-fifths (61 per cent) of all skill-shortage vacancies in Wales at the time of the survey. In addition to having the greatest volume of skill-shortage vacancies, Associate Professional occupations also showed the greatest density: over two-fifths (43 per cent) of vacancies for Associate Professionals were in this category. Two-fifths of vacancies for Machine Operatives were also skill-shortage vacancies, as shown in Table 4.8. % of vacancies that Number of skillare skill-shortage shortage vacancies vacs Column % Occupation Rounded to nearest 100 Unwtd Base: % Managers 100 69 10 Professionals 500 179 17 Associate Professionals 1,600 150 43 Admin / Clerical 200 174 7 Skilled Trades 900 164 34 Caring, Leisure and Other services 400 152 13 Sales / Customer services 400 164 11 Machine Operatives 600 86 40 Elementary 900 211 25 Base: Column 1 all establishments (6,012 unweighted); Column 2 all establishments with vacancies in each occupation. Percentages in Column 2 are based on all vacancies, rather than all establishments with vacancies; figures therefore show the percentage of vacancies which are hard to fill due to skill shortages. Number of skill-shortage vacancies rounded to nearest 100. ## 4.9 Skills Lacking From Applicants Where vacancies were difficult to fill due to a lack of skills, qualifications or experience among applicants, it tended to be job specific skills that were lacking. Almost four-fifths (78 per cent) of skill-shortage vacancies were caused by inadequate job specific skills, while three-fifths (59 per cent) were due to a lack of team working skills. In half of cases (53 per cent), a lack of customer handling skills was cited as a reason. Of note is the fact that both basic and advanced IT skills were more likely to be cited in Wales than in the UK as a whole. On average, around six skill areas were cited per vacancy, showing that, when applicants lack required skills, this tends to be across multiple areas; this is also the case UK-wide and demonstrates the expectations of employers regarding the range of skills they expect applicants to bring to the table when applying for jobs. Written (28 per cent) and oral (30 per cent) Welsh language skills were cited in relation to around three in ten skill-shortage vacancies, and in particular relating to Associate Professional roles (it is worth noting that this is the occupational group that includes translators). Wales Total UK Total Column % % % Skills Base: 274 Base: 3,973 Job specific skills 78 66 Technical or practical skills 45 46 Basic computer literacy / using IT 35 16 Advanced IT or software skills 35 21 Oral communication skills 35 38 Written communication skills 24 33 Customer handling skills 53 40 Team working skills 59 33 Written Welsh language skills 28 n/a Oral Welsh language skills 30 n/a Foreign language skills 7 16 Problem solving skills 39 37 Planning and Organisation skills 42 41 Strategic Management skills 28 29 Numeracy skills 20 26 Literacy skills 44 29 Office admin skills 14 17 Base: Establishments with skill-shortage vacancies. Results are based on skill-shortage vacancies rather than establishments with skill-shortage vacancies; the figures therefore show the proportion of skill-shortage vacancies caused by a lack of each skill. 'n/a' denotes Welsh language skills; these questions were only asked in Wales and as such there is no comparable UK-wide figure. ## 4.10 Conclusion Overall, 11 per cent of employers in Wales had a vacancy at the time of the survey; similar to the incidence of vacancies seen in the UK as a whole (12 per cent) and equating to around 25,500 vacancies across Wales. Whilst the proportion of employers reporting that some or all of the vacancies they had were proving to be hard to fill was the same as in the UK as a whole (four per cent), the proportion of actual vacancies proving hard to fill was higher in Wales (33 per cent) than in the rest of the UK (22 per cent), and the proportion that were hard-to-fill due to skills shortages shows the same pattern (22 per cent compared to 16 per cent in the UK) suggesting that where problems do exist, they are more acute in Wales than the rest of the UK. This is borne out by the finding that more employers in Wales who had hard-to-fill vacancies said these were having an impact on their establishment than in the rest of the UK. The data shows that there are pockets of shortages which threaten future economic growth. Workforce skill deficiencies are not spread evenly across the economy, with vacancies in the Business Services sector the most likely to be difficult to fill due to skill shortages. Mid Wales is particularly strongly affected by skill-shortage vacancies, with three-fifths of vacancies here hard to fill due to difficulties finding skilled applicants compared to fewer than one-fifth in each of the other three regions. This indicates there could be real issues in this region in filling vacant jobs, and is likely to be a factor holding back economic progress in this region in particular. By occupation the data suggests that employers in Wales find it far harder to find skilled staff to fill vacancies in Associate Professional and Machine Operative roles than employers in the rest of the UK. Two in every five vacancies in these roles were unfilled due to skill shortages. There was also some difficulty in recruiting staff to Skilled Trades roles, as there was in the rest of the UK, with around a third of vacancies affected by skill shortages. The skills which are missing when a hard-to-fill vacancy is caused by a skill shortage are many, with multiple skills lacking for each individual vacancy. This indicates the high expectations employers have of applicants, and the range of skills they demand. Most commonly cited were job specific skills, team working skills, and customer handling skills (78, 59 and 53 per cent respectively) but also worthy of note is that both basic and advanced IT skills were far more likely to be cited as an issue in Wales than in the UK as a whole. Foreign language skills were seen as less of an issue in Wales compared to the UK. Whilst only a small proportion of employers report having vacancies that are hard to fill, where they do exist they have a significant impact on business performance. In total, 97 per cent of employers with a hard-to-fill vacancy said it was having an impact on their business. The main impact felt by businesses was on the workload of existing staff, which has the potential to cause knock-on effects on morale and retention. Other impacts on business performance cited by significant numbers of employers included difficulties in meeting customer service objectives, loss of business or orders to competitors, delays developing new products or services, and increased operating costs. ## 5 Internal Skills Mismatch Chapter Summary Around 53,700 employees (five per cent of the workforce in Wales) were reported as being not fully proficient at their job (i.e. they have a "skills gap"); 13 per cent of employers reported having at least one employee who had a skills gap. Skills gaps were most common amongst staff working in Machine Operative roles. Where skills gaps exist their impact can be significant, most commonly on the workload of other staff (reported by half of employers with skills gaps) and increased operating costs (31 per cent). However around two-in-five employers reported that the skills gaps among their staff did not have any tangible impact on the performance of the establishment, reflecting the often transient nature of skills gaps when they are caused by staff not having completed their training, for example. Across Wales six per cent of establishments reported they had difficulties retaining staff; this was most commonly among Skilled Trades occupations and Elementary staff. The survey introduced an experimental question to look at how employers perceived potential under-use of skills in the workplace. This single question indicated almost half of all establishments (45 per cent) reported they had at least one member of staff who had both qualifications and skills exceeding the level required for their current job role. In volume terms this amounts to 14 per cent of the total workforce in Wales. ## 5.1 Introduction Skills gaps occur when the skills of staff are not adequate to perform their job role, and can have an impact on the efficient functioning of establishments. This chapter will explore their incidence, volume, profile and causes, before reviewing the impact of skills gaps and the actions employers take in an attempt to combat them. It will also look at skills gaps alongside skill-shortage vacancies to see the overall prevalence of skill deficiencies faced by businesses. The chapter will then turn to examine the extent to which employers face retention issues, including the factors underlying any retention issues and the impacts of and responses taken by employers in the face of such challenges. Finally, the chapter will briefly look at under-use of skills in the workplace, where employees have both skills and qualifications which are more advanced than those required for their current job role. The UK Commission's Employer Skills Survey 2011 trialled for the first time a question which was designed to pick up a sense of whether employers felt there were people working for them that were not having their skills fully used. In other studies this type of question is usually asked to individuals in employment rather than their employer. Under-use of skills is an important issue: if an establishment is not making full use of its human resources, it may not be optimising its productivity or stretching its product strategy and innovating. ## 5.2 The Incidence, Volume, Density And Distribution Of Skills Gaps For the majority of establishments (87 per cent) in Wales, the entire workforce is regarded as being fully proficient at their job roles. However, one in eight (13 per cent) report having at least one member of staff that is not fully proficient (a 'skills gap'). In total 53,700 workers were considered to have skills gaps, equivalent to five per cent of the total workforce in Wales. This matches the UK average for incidence and proportion of the workforce. The proportion of establishments reporting at least one skills gap was related to the size of the establishment. Establishments with 1-4 staff were far less likely to report having a skills gap than the average (just six per cent did so), incidence then increased with size from 21 per cent of those with 5-24 staff to 41 per cent of establishments with 100 or more staff. The *proportion* of staff described as having a skills gap was again much lower in the 1-4 sizeband (three per cent), then increased across the remaining sizes of establishment before dropping down to three per cent again in the largest establishments (those with 250+ staff, see Table 5.1). Hotels and Restaurants and Public Administration (both 18 per cent) were the sectors with the highest incidence of skills gaps. Hotels and Restaurants was also one of the sectors with the highest proportion of staff described as having a skills gap, along with Electricity, Gas and Water (both seven per cent). Conversely despite the high incidence of establishments experiencing skills gaps, staff working in the Public Administration sector were among the least likely to have a skills gap at just two per cent of the workforce. Skills gaps were least prevalent in the Agriculture sector; only three per cent of establishments reported a skills gap, and only two per cent of staff were considered to have a skills gap. This is similar to sectoral patterns seen in the UK. There was limited variation between different regions. Establishments in Mid Wales were slightly less likely to have any skills gaps (10 per cent compared with 15 per cent in South East Wales), but the proportion of the workforce considered to have a skills gap was similar across all regions (between four and six per cent). There was no difference in incidence or density for the ESF regions. % of % of Number of establishments workforce with skills skills gaps with a skills gap gaps Unwtd base % Rounded to nearest 100 % Wales total 6,012 13 53,700 5 UK total 87,572 13 1.49m 5 Size 1-4 1,216 6 4,400 3 5-24 3,474 21 15,100 5 25-99 1,074 32 13,400 5 100-249 151 41 11,500 7 250+ 97 41 9,400 3 Sector Agriculture 102 3 600 2 Mining and Quarrying 22 ** ** ** Manufacturing 468 17 8,500 6 Electricity, Gas and Water 111 15 1,000 7 Construction 503 11 2,200 3 Wholesale and Retail 1,069 17 10,300 5 Hotels and Restaurants 675 18 5,900 7 Transport and Communications 439 14 2,400 4 Financial Services 173 15 1,100 4 Business Services 791 9 6,200 5 Public Administration 130 18 1,600 2 Education 391 17 4,000 3 Health and Social Work 580 16 7,700 4 Community, Social and Personal Services activities 558 12 2,200 5 Region North Wales 1,431 13 12,900 5 Mid Wales 798 10 4,600 6 South West Wales 1,389 12 10,400 4 South East Wales 2,394 15 25,800 4 ESF Region West Wales and the Valleys 3,732 13 31,700 5 East Wales 2,276 13 22,000 5 Base: All establishments Percentages in column 3 are based on all employment rather than all establishments; proportions therefore show the percentage of employees with a skills gap. Number of gaps rounded to nearest 100. Establishments in the higher Product Market Strategy (PMS) groups10 are characterised by being innovative and producing high quality, customised services and goods; Chapter 4 of this report demonstrated they were more likely to be active in the recruitment market than those with a lower PMS rating. It takes time to train new staff to full proficiency, and this is one possible reason why establishments in the higher PMS groups were more likely to have skills gaps than those in the lower PMS groups, with 16 per cent of the "High" and "Very High" groups reporting having gaps compared to 10-12 per cent of the remaining groups. As shown in Table 5.2, in terms of occupation, skills gaps tend to be most concentrated among Machine Operatives;11 seven per cent of the workforce in this occupation are perceived to be not fully proficient. Additionally, six per cent of staff in Skilled Trades, Sales and Elementary occupations are considered to have a skills gap. As in the UK as a whole, with the exception of Skilled Trades it is the traditionally less skilled roles that are seen as more likely to have a skills gaps than the roles that might require higher qualifications such as managers, professional groups and Associate Professionals. | Number of skills | |------------------------------------| | gaps | | | | skills gaps | | | | Column % | | Rounded to nearest 100 | | Occupation | | | | Base: 6,012 | | | | Base: | | % | | | | Managers | | | | 5,100 | | | | 5,699 | | 2 | | | | Professionals | | | | 2,300 | | | | 1,162 | | 2 | | | | Associate Professionals | | | | 2,600 | | | | 773 | | 4 | | | | Admin / Clerical | | | | 6,100 | | | | 3,490 | | 4 | | | | Skilled Trades | | | | 6,100 | | | | 1,550 | | 6 | | | | Caring, Leisure and Other services | | | | 6,200 | | | | 969 | | 5 | | | | Sales / Customer services | | | | 8,300 | | | | 1,618 | | 6 | | | | Machine Operatives | | | | 6,700 | | | | 950 | | 7 | | | | Elementary | | | | 10,400 | | | | 2,240 | | 6 | | | Base: Column 1 all establishments (6,012 unweighted); Column 2 all establishments with staff in each occupation. Number of skills gaps rounded to nearest 100 ## 5.3 Causes Of Skills Gaps The main causes of staff not being fully proficient are presented in Figure 5.1. Results are shown as a percentage of all skills gaps rather than a percentage of establishments with gaps; the figure therefore shows what proportions of skills gaps are caused by the various factors reported by employers. Establishments could give more than one cause for skills gaps within each occupation. Staff training only being partially completed, and staff being new to the role generally (either because they have recently started the job or have recently been promoted to a higher level role) are the most common causes of skills gaps, with 50 per cent and 46 per cent of all skills gaps respectively being attributed, at least in part, to these reasons. These causes are for the most part transient factors that suggest the skills gap will disappear once training is completed and the employee has some experience in their role; skills gaps such as these are often to be expected and the establishment is likely to be prepared to deal with them, reducing the impact they have. Two other factors relating to training - training proving ineffective and staff not receiving the appropriate training - are also quite common causes (explaining at least in part 32 per cent and 25 per cent of skills gaps respectively). These could be addressed by further training and their impact and duration may be dependent on the establishment's ability to provide the appropriate training. A requirement for (further) training is also implicit in those skills gaps arising from the introduction of new working practices (27 per cent), the development of new products or services (21 per cent), and the introduction of new technology (20 per cent). In cases where skills gaps are caused by new developments, it could be argued they are no bad thing as the establishment is innovating and expanding the skills of its staff. Staff lacking motivation is the other key cause of skills gaps, which is perceived to explain around one third (31 per cent) of all skills gaps. Recruitment-related factors are less likely to be cited, though nonetheless approaching one-in-five skills gaps (19 per cent) result from an inability to recruit appropriately skilled individuals, and eight per cent of gaps arise from retention difficulties. In both cases the underlying implication is that experienced staff have left or a new post has been created and employers have had to fill these positions with people who do not have the required skill set. Training is currently only partially completed 50% New to the role 46% Been on training but their performance has not 32% improved sufficiently Staff lack motivation 31% Introduction of new working practices 27% Not received the appropriate training 25% Development of new products and services 21% Introduction of new technology 20% Unable to recruit staff with the required skills 19% Problems retaining staff 8% Base: All establishments with skills gaps: 1,355 (unweighted) Percentages are based on all skills gaps followed up rather than all establishments with skills gaps, figures therefore show the proportion of skills gaps caused by each stated reason. While training only being partially completed and staff being new to the role were generally the most important factors in causing skills gaps across all sizes of establishment, there were some other variations by size. Larger establishments were more likely to report that skills gaps were caused by the introduction of new working practices (36 per cent of 250+ establishments compared with 21 per cent of the smallest establishments). Smaller establishments were more likely to state that staff simply had not received the appropriate training. Sectors especially likely to be affected by skills gaps as a result of staff being new to the role were Financial Services (74 per cent) and Health and Social Work (59 per cent). Establishments in Financial Services and Business Services were more likely to report that staff had been on training which had proved ineffective (56 per cent and 43 per cent respectively), or that their staff lacked motivation (55 per cent and 47 per cent). Reasons were fairly similar to those given by establishments in the UK as a whole, with the exception that establishments in Wales were marginally more likely to cite the development of new products and services and the introduction of new technology as causes of gaps (21 and 20 per cent respectively in Wales compared to 15 and 17 per cent respectively in the UK). Training is currently only partially completed New to the role Been on training but their performance has not improved sufficiently Staff lack motivation Introduction of new working practices Not received the appropriate training Development of new products and services Introduction of new technology Unable to recruit staff with the required skills Problems retaining staff Base (unwtd) % % % % % % % % % % Wales total 1,355 50 46 32 31 27 25 21 20 19 8 UK total 20,839 46 47 29 32 23 23 15 17 18 10 Size 1-4 101 58 43 20 23 21 30 20 27 19 10 5-24 793 54 47 33 39 24 27 17 19 23 11 25-99 359 49 50 31 35 23 29 17 17 23 10 100-249 62 51 44 22 27 29 19 29 19 22 9 250+ 40 63 44 47 19 36 22 23 23 5 * Sector Agriculture 7 ** ** ** ** ** ** ** ** ** ** Mining and Quarrying 2 ** ** ** ** ** ** ** ** ** ** Manufacturing 115 55 43 26 23 31 30 36 31 17 2 Electricity, Gas and Water 20 ** ** ** ** ** ** ** ** ** ** Construction 75 55 46 20 26 15 33 12 15 13 7 Wholesale and Retail 303 49 47 33 37 24 25 19 23 18 8 Hotels and Restaurants 195 51 51 35 40 18 25 11 7 28 18 Transport and Communications 95 59 38 33 41 31 33 19 19 22 11 Financial Services 30 21 74 56 55 11 8 37 2 28 44 Business Services 164 47 41 43 47 44 31 20 20 12 4 Public Administration 24 ** ** ** ** ** ** ** ** ** ** Education 86 42 28 35 19 38 21 29 33 15 8 Health and Social Work 135 52 59 26 19 14 17 8 8 18 11 Community, Social and Personal Services activities 104 54 46 36 28 29 22 23 20 13 5 Region North Wales 332 46 47 28 26 16 18 15 11 20 10 Mid Wales 171 38 32 27 34 23 29 10 15 24 9 South West Wales 282 50 34 28 31 30 20 29 29 22 8 South East Wales 570 53 54 36 32 31 30 23 21 17 8 ESF Region West Wales and the Valleys 819 53 48 28 28 24 23 22 19 21 9 East Wales 536 44 45 36 35 31 29 19 21 17 7 Base: All establishments reporting skills gaps. Results are based on skills gaps rather than establishments with skills gaps; the figures therefore show the proportion of skills gaps caused by each factor reported by employers. '*' denotes a figure larger than zero but smaller than 0.5. '**' denotes base size under 25: too low to report. Figures in italics denote base size <50: treat figures with caution. ## 5.4 Impact Of Skills Gaps Three in five establishments with skills gaps (62 per cent) said they had seen an impact on business performance. This was a similar level to that seen across the UK as a whole (61 per cent). Like hard-to-fill vacancies, establishments with skills gaps most commonly report that the impact of these skills gaps is to increase the workload for other staff (50 per cent). Around three-in-ten (31 per cent) believe that their skills gaps lead to increased operating costs and a quarter find they encounter difficulties in introducing new working practices (26 per cent) or meeting quality standards (25 per cent). Fewer, although still sizeable numbers of employers, find that skills gaps prohibit their business developing or growing specifically in terms of: losing business to competitors (22 per cent); or developing new services or products (19 per cent). The impact of skills gaps increased in line with establishment size. While just over half (55 per cent) of the smallest establishments who experienced skills gaps reported that these had had an impact, this proportion increased to 80 per cent for the largest establishments. In particular, larger establishments were more likely to experience increased operating costs. Smaller establishments were more likely to lose business to competitors as a result of these gaps, and the smallest establishments were most likely to need to outsource work. In the Health and Social Work sector, skills gaps were particularly likely to cause difficulty in introducing new working practices. Establishments in Transport and Manufacturing were more likely than those in other sectors to report that they had been forced to outsource work as a result of skills gaps. Increased workload for other staff Increased operating costs Difficulties introducing new working practices Difficulties meeting quality standards Loss of business or orders to competitors Delays developing new products or services Need to outsource work No impact % % % % % % % % Base (unwtd) Wales total 1,355 50 31 26 25 22 19 11 38 UK total 20,839 48 28 23 25 20 16 9 39 Size 1-4 101 35 31 24 22 21 24 19 45 5-24 793 58 28 26 27 24 17 7 35 25-99 359 53 35 24 25 19 15 8 37 100-249 62 51 41 33 35 11 23 11 36 250+ 40 63 49 31 28 15 13 4 20 Sector Agriculture 7 ** ** ** ** ** ** ** ** Mining and Quarrying 2 ** ** ** ** ** ** ** ** Manufacturing 115 58 39 18 24 32 29 20 31 Electricity, Gas and Water 20 ** ** ** ** ** ** ** ** Construction 75 41 39 20 11 16 20 10 47 Wholesale and Retail 303 52 26 26 26 26 16 6 37 Hotels and Restaurants 195 53 32 24 37 29 16 13 36 Transport and Communications 95 43 31 29 26 23 23 31 44 Financial Services 30 61 25 25 32 28 6 3 23 Business Services 164 48 34 17 25 20 24 10 42 Public Administration 24 ** ** ** ** ** ** ** ** Education 86 54 26 31 31 7 19 3 37 Health and Social Work 135 50 28 37 18 11 16 4 36 Community, Social and Personal Services activities 104 49 20 31 32 27 27 12 43 Region North Wales 332 49 27 24 24 18 17 5 37 Mid Wales 171 53 34 33 32 24 24 19 34 South West Wales 282 48 30 28 19 17 13 9 42 South East Wales 570 51 32 24 27 25 22 14 38 ESF Region West Wales and the Valleys 819 50 29 26 23 21 18 8 40 East Wales 536 50 33 25 28 22 21 16 36 Base: All establishments reporting skills gaps. **' denotes base size under 25: too low to report. Figures in italics denote base size <50: treat figures with caution. ## 5.5 Skills That Need Improving As seen with skill-shortage-vacancies in the previous chapter, the areas where employers are most likely to experience skills gaps is job specific skills (53 per cent of all skills gaps). Almost half (48 per cent) of gaps were for Planning and Organisation skills, and over two-fifths were for problem solving skills (41 per cent) or team working skills (40 per cent). Slightly over one in ten gaps were for oral (12 per cent) or written (11 per cent) Welsh language skills. The pattern of skills that need improving is similar to that seen in the UK. Skills gaps in Wales however are slightly more likely to be caused by literacy or numeracy issues, or a lack of admin or IT skills, though the difference here is not as stark as that found for skill shortage vacancies. There were some variations by region: skills gaps in South East Wales were more likely than those in the rest of Wales to be caused by job-specific, technical or practical skills, whereas basic computer literacy was more of an issue in South West Wales. Table 5.5 shows the breakdown by region. | | South | South | |------------------------------------|----------|----------| | UK | North | Mid | | | | | | Wales | | | | West | East | | | Total | Total | Wales | | Wales | Wales | | | Column % | | | | % | % | % | | Base (unweighted) | | | | 1,355 | 20,839 | | | | | | | 332 | 171 | 282 | | Job specific skills | 53 | 48 | | Technical or practical skills | 34 | 27 | | Basic computer literacy / using IT | 21 | 17 | | Advanced IT or software skills | 21 | 15 | | Oral communication skills | 36 | 34 | | Written communication skills | 31 | 28 | | Customer handling skills | 39 | 38 | | Team working skills | 40 | 38 | | Written Welsh language skills | 11 | n/a | | Oral Welsh language skills | 12 | n/a | | Foreign language skills | 7 | 9 | | Problem solving skills | 41 | 35 | | Planning and Organisation skills | 48 | 39 | | Strategic Management skills | 19 | 19 | | Numeracy skills | 22 | 15 | | Literacy skills | 26 | 19 | | Office admin skills | 24 | 16 | Base: All establishments reporting skills gaps. Results are based on skills gaps rather than establishments with skills gaps; the figures therefore show the proportion of skills gaps caused by a lack of each skill. 'n/a' denotes Welsh language skills; these questions were only asked in Wales and as such there is no comparable UK-wide figure. ## 5.6 Actions Taken To Overcome Skills Gaps Around three quarters (74 per cent) of establishments had taken action of some kind to overcome the skills gaps they were experiencing. However, action on the part of the employer is not necessarily required to remedy all skills gaps because, as discussed above, large proportions of skills gaps are caused by training not being fully complete or staff being new to the role. The most likely response was to increase training activity or increase trainee programmes; this approach was taken by almost two-thirds (64 per cent) of establishments experiencing skills gaps. Almost half (46 per cent) increased their supervision of staff, and two-fifths increased staff appraisals or reviews, or implemented a mentoring scheme (both 38 per cent). The likelihood of taking most measures increases in line with establishment size. Over four-fifths (83 per cent) of establishments with 250+ staff had increased their training activity, compared with only half (54 per cent) of establishments with up to four staff. Similarly, 69 per cent of the largest establishments had increased staff supervision, compared with only a third (33 per cent) of the smallest establishments. By contrast, smaller establishments were much more likely to have taken no specific action. Establishments in the Education sector were the most likely to increase training (82 per cent of employers), implement mentoring schemes (70 per cent), increase supervision (66 per cent), and increase staff reviews (62 per cent). Establishments were most likely to address skills gaps by increasing recruitment activity in the Transport and Communications (21 per cent) and Community, Social and Personal Service activities (19 per cent) sectors. Establishments in North Wales were most likely to have taken any action to overcome skills gaps. The pattern of action taken was very similar to that seen across the UK as a whole (see Table 5.8). Base (unwtd) % % % % % % % % % Wales total 1,355 64 46 38 38 30 20 11 7 26 UK total 20,839 62 46 41 38 25 23 11 7 26 Size 1-4 101 54 33 20 22 22 11 7 6 38 5-24 793 64 51 42 41 32 20 10 5 24 25-99 359 75 53 55 51 34 30 19 11 16 100-249 62 82 57 54 54 32 31 22 12 14 250+ 40 83 69 69 72 44 45 31 27 6 Sector Agriculture 7 ** ** ** ** ** ** ** ** ** Mining and Quarrying 2 ** ** ** ** ** ** ** ** ** Manufacturing 115 54 34 32 26 32 18 10 11 29 Electricity, Gas and Water 20 ** ** ** ** ** ** ** ** ** Construction 75 62 28 12 30 16 5 3 1 30 Wholesale and Retail 303 64 46 40 38 27 16 7 3 26 Hotels and Restaurants 195 61 51 45 41 30 18 14 13 24 Transport and Communications 95 63 38 21 22 28 22 21 14 35 Financial Services 30 82 50 54 56 19 22 12 - 8 Business Services 164 61 50 36 35 30 29 12 4 30 Public Administration 24 ** ** ** ** ** ** ** ** ** Education 86 82 66 62 70 43 39 9 6 9 Health and Social Work 135 66 58 48 48 36 24 12 13 24 Community, Social and Personal Services activities 104 63 47 45 35 42 22 19 * 26 Region North Wales 332 71 50 44 46 30 23 9 6 18 Mid Wales 171 57 38 40 23 38 19 13 12 32 South West Wales 282 59 40 34 32 22 14 9 6 28 South East Wales 570 63 49 37 39 31 20 12 6 28 ESF Region West Wales and the Valleys 819 62 44 38 37 27 19 10 6 26 East Wales 536 66 50 38 38 34 20 13 8 25 Base: All establishments reporting skills gaps. '-' denotes a figure of zero; '*' denotes a figure larger than zero but smaller than 0.5. '**' denotes base size under 25: too low to report. Figures in italics denote base size <50: treat figures with caution. ## 5.7 Combined Skill Deficiencies The previous chapter examined skill-shortage vacancies and this one has explored skills gaps. The identification of these two measures as separate phenomena may not reflect how employers experience them, however. It is useful to combine the two separate indicators into a single measure: the proportion of establishments who report that they face a skill deficiency, i.e. a skills gap, skill-shortage vacancy or both. When expressed in this way, 15 per cent of establishments were suffering from a skill deficiency, but just one per cent reported both. Table 5.7 summarises the situation in Wales compared to the UK as a whole. | | | |---------------------------------------------------|-------| | Wales Total | | | | | | UK Total | | | | | | Base | | | | 6,012 | | Column % | | | | % | | Skill-shortage vacancies | | | | | | | | | % of establishments with a skill-shortage vacancy | | | | | | | | | 3 | | | | | | 3 | | | | | | Number of skill-shortage vacancies | | | | | | | | | 5,700 | | | | | | 103,500 | | | | | | Skill-shortage vacancy density | | | (% of vacancies that are | | | SSVs) | | | (Unweighted base=Wales 1,100, UK 17,116) | | | | | | | | | 22 | | | | | | 16 | | | | | | Skill gaps | | | | | | | | | % of establishments with a skills gap | | | | | | | | | 13 | | | | | | 13 | | | | | | Number of skill gaps | | | | | | | | | 53,700 | | | | | | 1,490,000 | | | | | | Skills gap density | | | (% of workforce with gaps) | | | | | | | | | 5 | | | | | | 5 | | | | | | Combined | | | | | | | | | % with SSV only | | | | | | | | | 2 | | | | | | 2 | | | | | | % with skill gap only | | | | | | | | | 12 | | | | | | 12 | | | | | | % with both | | | | | | | | | 1 | | | | | | 1 | | | | | | % with either | | | | | | | | | 15 | | | | | | 15 | | | | | Base: All establishments, except for skill-shortage vacancy density which is all establishments with vacancies. Number of skill-shortage vacancies and number of skills gaps rounded to nearest 100. SSV density is shown as a proportion of all vacancies and skills gap density as a proportion of the workforce thus percentages shown are a proportion of vacancies and of staff, not of establishments experiencing these issues. As might be expected the proportion of establishments reporting that they face any or both types of skill deficiency issue rises with size of establishment (Figure 5.7). None of the smallest establishments (employing less than five staff) report both, perhaps unsurprisingly, but two per cent of establishments employing 5-24 staff do, which might cause particular difficulties in those small establishments in being able to respond to the deficiencies. The Manufacturing, Hotels and Restaurants, and Public Administration sectors are the most affected by skills deficiencies. Agriculture is the least likely sector to be affected. 0% There is little variation by region (Figure 5.9), ranging from 14 per cent in North Wales to 16 per cent in South East Wales. ## 5.8 Difficulties Retaining Staff Six per cent of establishments in Wales reported that there are specific jobs in which they have difficulties retaining staff; this is similar to the proportion reporting retention difficulties in England, Northern Ireland and Wales as a whole (five per cent). The proportion of establishments reporting retention difficulties rises with establishment size, from just five per cent of establishments with 1-4 staff, up to a sixth (17 per cent) of those with 100-249 staff. 15 per cent of those with 250+ staff had difficulties retaining staff. As shown in Figure 5.3, establishments operating in the Hotels and Restaurants sector are the most likely to experience retention difficulties (11 per cent). As previously discussed, this is also the sector with one of the highest density and incidence of skills gaps (seven per cent of staff and 18 per cent of establishments). Employers in the Hotels and Restaurants sector are particularly likely to attribute skills gaps to problems retaining staff: retention difficulties are linked to 18 per cent of skills gaps within this sector, compared with an overall average of 8 per cent of skills gaps (see Table 5.3). By ESF region establishments in West Wales and the Valleys were slightly more likely to experience retention difficulties compared to establishments in East Wales (seven per cent and five per cent respectively). Where employers experience retention difficulties, these are most likely to relate primarily to Skilled Trades occupations and Elementary staff (each cited by over 20 per cent of establishments with retention difficulties as the main occupation for which they had difficulties). Large establishments were much more likely to have problems retaining Professionals (cited by 22 per cent of employers with 100+ staff). Smaller establishments with fewer than 100 staff were more likely to have problems with Skilled Trades and Elementary staff. As Table 5.8 shows, the Construction and Manufacturing sectors were particularly likely to face problems in retaining staff in Skilled Trades occupations. Retention of staff in Elementary occupations was a particular issue for the Hotels and Restaurants and Education sectors. In the Health and Social Work and Community, Social and Personal Service activities sectors, the main difficulty is in retaining Caring, Leisure and Other services staff (48 and 38 per cent respectively). In Business Services, the main retention issue is with Associate Professionals (33 per cent) and for Transport and Communications the main challenge lies with Machine Operatives (69 per cent). This was similar to the occupational pattern seen in the UK. Establishments in the East Wales ESF region are more likely than establishments in West Wales and the Valleys to find their retention problems are related to Elementary staff. Establishments in West Wales and the Valleys on the other hand were more likely to report their difficulties related to the retention of Skilled Trades staff. Managers Professionals Associate Professionals Admin / Clerical Skilled trades occupations Caring, Leisure and Other services Sales / Customer services Machine Operatives Elementary Base (unwtd) % % % % % % % % % Wales total 512 2 6 10 5 23 11 12 9 22 England/NI/Wales total 5,866 3 9 13 7 19 11 11 7 19 Size 1-4 65 4 1 12 8 27 4 14 8 21 5-24 283 1 7 7 4 22 15 10 10 24 25-99 123 1 13 9 1 13 27 5 8 22 100-249 26 - 22 9 - 10 18 14 7 15 250+ 15 ** ** ** ** ** ** ** ** ** Sector Agriculture 7 ** ** ** ** ** ** ** ** ** Mining and Quarrying 3 ** ** ** ** ** ** ** ** ** Manufacturing 34 - 5 8 - 67 - 1 9 8 Electricity, Gas and Water 8 ** ** ** ** ** ** ** ** ** Construction 31 8 - 1 3 79 - 1 1 8 Wholesale and Retail 63 1 1 8 - 20 - 40 15 16 Hotels and Restaurants 104 7 - * - 29 9 5 - 50 Transport and Communications 40 - 8 8 3 2 3 5 69 - Financial Services 8 ** ** ** ** ** ** ** ** ** Business Services 47 - 10 33 9 4 2 27 1 14 Public Administration 11 ** ** ** ** ** ** ** ** ** Education 43 - 24 4 6 6 16 - - 44 Health and Social Work 51 - 10 6 27 2 48 - - 6 62 - 5 28 7 3 38 1 - 17 Community, Social and Personal Services activities Region North Wales 122 4 7 5 2 21 17 7 10 26 Mid Wales 87 1 9 3 4 22 13 9 4 35 South West Wales 133 * 3 7 1 30 7 17 9 24 South East Wales 170 2 6 17 10 19 10 12 10 14 ESF Region West Wales and the Valleys 347 3 7 7 5 26 11 11 10 19 East Wales 165 * 4 16 5 16 12 13 6 27 Base: All establishments that have difficulty retaining staff. '-' denotes a figure of zero; '*' denotes a figure larger than zero but smaller than 0.5. '**' denotes base size under 25: too low to report. Figures in italics denote base size <50: treat figures with caution. ## 5.9 Reasons For Retention Difficulties The most common reason given for retention difficulties was a lack of interest in the type of work in question, reported by almost three-fifths (58 per cent) of establishments with retention difficulties. A third (32 per cent) reported that staff did not want a long term commitment. Various issues relating specifically to the job, such as long/unsocial hours (35 per cent), unattractive conditions of employment (30 per cent), low wages in comparison to other employers (28 per cent), lack of career progression (29 per cent) and location of the organisation (24 per cent) were reported by around a quarter to a third of employers with retention difficulties. Factors external to the employer were also evident as issues. Three-in-ten (30 per cent) establishments cited the impact of the benefits trap (where employees perceive they were better off on benefits than they are working), and a fifth cited too much competition from other employers (21 per cent). Figures may add to over 100% due to multiple responses ## 5.10 The Impact Of Retention Difficulties Virtually all employers that experienced retention difficulties (91 per cent) reported that these had affected the business in some way, a similar figure to that seen in the UK as a whole. The overwhelming impact was an increased strain on remaining staff to cover the shortage, reported by 81 per cent of establishments. Half (49 per cent) experienced a drop in efficiency, and just under half experienced increased running costs or quality issues (both 44 per cent). Around a third reported restriction to business development activities (36 per cent), increased recruitment costs (34 per cent), or problems with customer service (32 per cent). Figures may add to over 100% due to multiple responses ## 5.11 Measures Taken To Overcome Retention Difficulties The response to retention difficulties most frequently involved either higher remuneration or the introduction of improved recruitment methods (both used by 17 per cent of establishments experiencing such difficulties). Almost as many (15 per cent) had introduced further training and development opportunities. Other possible approaches were used by relatively few employers. Seven per cent introduced flexible working hours, while the introduction of changes to the working environment, job enrichment, career progression and job specifications were each reported by five per cent or fewer of employers with retention difficulties. Although only nine per cent of employers reported that staff retention difficulties had not affected the business, over two-fifths (42 per cent) reported that they had not taken any measures to try and overcome difficulties retaining staff. This suggests that a considerable proportion of establishments are not acting to solve a problem that they are both aware of and believe to be impacting their business. Employers are more likely to take some action to resolve skills gaps (only a quarter of employers took no action in response to a skills gap) and hard-to-fill vacancies (only a fifth of employers took no action). Establishments in Wales were less likely to have taken measures to overcome retention difficulties than employers in the UK as a whole; just 26 per cent of employers UK-wide had not taken any measures at all compared to 42 per cent in Wales. ## 5.12 Under-Utilisation Of Skills Historically, skills surveys have tended to focus on those imbalances and mismatches in the labour market that result from a lack of skills, either in the form of staff not being fully proficient (skills gaps), or employers reporting difficulties filling vacancies because of lack of candidates with the required skills, work experience or qualifications (skill-shortage vacancies). However, further disparities are caused when the skills held by employees are not used to their full extent. This occurrence is referred to as over-skilling, overqualification, or under-employment. While a number of studies have attempted to measure the extent and, on occasion, the nature and impact of skills under-use, these have tended to be through research among individuals (rather than among employers). This is generally a reflection of the fact that while employers are likely to know the qualification level held by an employee, they are not always aware of the full range of skills that the individual possesses (some of which may be used in / required by the job role they perform, others potentially not). Even at an individual level, the majority of research and academic literature focuses on qualification mismatches. Notwithstanding these challenges, the UK Commission's Employer Skills Survey 2011 included a question which asked employers how many of their staff they considered to have both qualifications and skills that are more advanced than required for their current job role. Although this allows only limited analysis at an overall rather than an occupational level, it does allow us to estimate the extent of the problem from an employer perspective and to start to explore the relationship between under-use of skills and the skills challenges faced by employers. Approaching half of all establishments in Wales (45 per cent) reported having at least one employee with both qualifications and skills that are more advanced than required for their current job role, this equates to 14 per cent of the workforce, or 165,100 staff in total. This is similar to the UK as a whole, where the incidence was 49 per cent, or 16 per cent of the workforce. As Table 5.9 shows, it was mid-size employers with between 25 and 249 staff that were most likely to report the under-use of employees' skills. In terms of proportion of the workforce, the incidence of under-used staff declines with firm size: 30 per cent of the workforce is reported to be under-used in establishments with 1-4 employees versus only nine per cent in establishments with 250 or more staff. % of Number of establishments % of staff under-used with underunder-used staff used staff Unwtd base % Rounded to nearest 100 % Wales total 6,012 45 165,100 14 UK total 87,572 49 4,456,000 16 Size 1-4 1,216 44 40,500 30 5-24 3,474 45 47,600 16 25-99 1,074 51 32,200 11 100-249 151 54 18,600 11 250+ 97 38 26,300 9 Sector Agriculture 102 37 6,200 22 Mining and Quarrying 22 ** ** ** Manufacturing 468 40 10,400 8 Electricity, Gas and Water 111 38 1,200 8 Construction 503 40 8,500 13 Wholesale and Retail 1,069 49 28,900 15 Hotels and Restaurants 675 55 18,000 23 Transport and Communications 439 51 9,100 14 Financial Services 173 52 3,300 11 Business Services 791 36 21,900 17 Public Administration 130 42 9,800 11 Education 391 57 21,800 19 Health and Social Work 580 51 16,500 9 Community, Social and Personal Services activities 558 47 9,400 20 Region North Wales 1,431 39 35,700 14 Mid Wales 798 44 14,100 18 South West Wales 1,389 50 36,400 14 South East Wales 2,394 45 78,900 13 ESF Region West Wales and the Valleys 3,732 45 99,700 14 East Wales 2,276 44 65,500 14 Base: All establishments. Percentages in column 3 are based on all employment rather than all establishments; proportions therefore show the percentage of employees who are under-used. '**' denotes base size under 25: too low to report. More than half (57 per cent) of establishments in the Education sector reported having under-used staff, comprising a fifth (19 per cent) of the workforce. The proportion of staff who were under-used was also high in sectors that contain large numbers of low skill jobs such as Agriculture (22 per cent) and Hotels and Restaurants (23 per cent). Establishments in South West Wales were most likely to report that they had under-used staff (50 per cent). This compares with only 39 per cent in North Wales. In terms of the proportion of the workforce, under-employment was highest in Mid Wales (18 per cent) although the variation by region was fairly small. ## 5.13 Conclusion This chapter has addressed the issue of skills mismatch in establishments, that is, the extent to which individuals and their skills are matched (or not) to those that employers require. It has also addressed the issue of retention and the extent to which this has been a problem for employers. Overall across Wales 13 per cent of establishments report having at least one skills gap among their staff; this equates to 53,700 skills gaps or five per cent of the workforce. This is in line with the levels seen in the UK as a whole. The skills gaps are not evenly distributed across the economy; pockets exist in certain sectors (such as Hotels and Restaurants, where 18 per cent of establishments and seven per cent of the workforce have a skills gap), and in specific occupations including Machine Operatives, Skilled Trades, Sales and Customer Services and Elementary occupations. Machine Operatives was also one of the highest occupations in terms of skill-shortage vacancies suggesting either a more general lack of relevant skills in this occupation in Wales, or alternatively that establishments with skill-shortage vacancies in this area are taking on staff with fewer skills than they would ideally like, thus converting a skill-shortage vacancy to a skills gap. Where skills gaps exist, their impact on business performance can be significant, though impacts were reported by a smaller proportion of employers than for hard-to-fill vacancies (62 per cent as opposed to 97 per cent - see Chapter 4 for more information on hard-tofill vacancies). The most common impact was on the workload of other staff. Half of employers (50 per cent) reported an increase in workload for other staff, which may in turn lead to an increase in operating costs (particularly for larger employers) through paying for overtime or agency staff. Other direct business impacts included losing business to competitors (particularly an issue for smaller employers) and delays in developing new products and services. The survey introduced an experimental question to look at how employers perceived potential under-use of skills in the workplace. This single question indicated that approaching half of establishments in Wales (45 per cent) report having at least one employee with **both** qualifications **and** skills that are more advanced than required for their current role. In volume terms, this is 165,100 employees, or 14 per cent of the total workforce in Wales, similar proportions to those seen in the UK as a whole. It should be noted that this indicative finding requires more investigation and follow-up work, and was reached in a single question, rather than an established suite of questions, as for skills gaps. However, the early indications we can glean from it show that under-use of skills is an issue that employers understand and can recognise in their workforce. This inevitably has consequences for the overall productivity of the Welsh economy. The other area investigated in this chapter was retention issues. Overall, six per cent of establishments in Wales reported having difficulties retaining staff (similar to the five per cent reported in the UK as a whole). Employers operating in the Hotels and Restaurants sector were the most likely to experience retention difficulties, and particularly in Skilled Trades and Elementary occupations. The main reason cited for a difficulty retaining staff was lack of interest in the type of work in question. As with skill-shortage vacancies and skills gaps, the most commonly cited impact of retention issues was an impact on other staff, particularly a strain on management of other staff covering the shortage. However employers in Wales were far less likely than their counterparts in the UK as a whole to be taking action to overcome these retention difficulties. The survey shows the similarity in the causes and effects of recruitment and retention difficulties and skills gaps. Training is often a solution to these problems and a lack of training, or a time-lag in seeing the impact of training, can be a cause of these problems. The next chapter explores employer investment in training and in the skills of their staff. ## 6 Workforce Development Chapter Summary Most establishments (59 per cent) had provided off- or on-the-job training for at least one of their staff members in the previous 12 months. Employers had funded or arranged training in this period for approximately 650,000 staff (equivalent to 56 per cent of the total workforce in Wales at the time of the survey) and provided five million days of training (equivalent to 4.2 days per employee per annum and 7.5 days per person trained). There is variation by sector and occupation: sectors comprising of mostly public sector organisations are more likely to provide training for staff, and staff in Professional occupations are more likely to receive training than those in other roles. Employer expenditure on training in the previous 12 months was £1.72bn, equivalent to £1,450 per employee and £2,600 per person trained. Half of total expenditure is accounted for by the cost of paying staff while they are being trained, while eight per cent is accounted for by fees to external providers. Fewer than half of workplaces (44 per cent) had either a training plan (38 per cent) or a budget for training expenditure (26 per cent). Many workplaces undertake training on an ad hoc basis, indeed over half of those providing training did not have a formal training plan in place. The most common reason for not training is that employers consider their staff to be fully proficient and / or that their staff did not need training (mentioned spontaneously by 65 per cent of non-trainers). Few point to failures in training supply as a reason for not training. ## 6.1 Introduction This chapter reports on the quantity of training and development activity undertaken by employers in Wales as well as reporting on the amount invested by employers in training. Businesses that train are less likely to go out of business plus there is much evidence to suggest the important contribution training and development makes to business, individual and economic success (UKCES, 2010a) More specifically the chapter discusses the proportion of establishments that engage in training or informal workforce development activities and how this varies by establishment size, sector, geography and occupation. It also examines the quantity of training provided in terms of training days and the proportion of workers trained, and the nature of this training including whether it involves training staff towards nationally recognised qualifications. Finally the chapter looks at the financial investment that employers are making in training. Throughout the chapter, unless otherwise stated, an employer is described as providing training if in the previous 12 months they had funded or arranged one or both of the following for any of their employees based at their site: - off-the-job training or development: training away from the individual's immediate work position, whether on their premises or elsewhere; - on-the-job or informal training or development: activities which take place at the individual's immediate work position which would be recognised as training by recipients. Training as defined in this way is intended to capture all activity which employers and employees would recognise as training. However, broader activity can take place which leads to skill development but which may not be classified as training. For this reason the UK Commission's Employer Skills Survey 2011 also asked employers whether they had engaged in any broader development activities, specifically: supervision to ensure that employees are guided through their job role over time; opportunities for staff to spend time learning through watching others perform their job roles; and allowing staff to perform tasks that go beyond their strict job role and providing feedback on how well they had done. As we see later in this chapter, a large minority of (mostly small) employers did not provide off- or on-the-job training but did engage in some of these broader development activities. However, unless otherwise stated it is on- and off-the-job training activity which is described in this chapter. ## 6.2 The Extent Of Training And Workforce Development Activity Overall 59 per cent of establishments had funded or arranged on-the-job or off-the-job training for at least one of their employees in the 12 months preceding the survey. This was similar to the figures in England, where 58 per cent had provided training to staff, but lower than for Northern Ireland (64 per cent) and Scotland (68 per cent). Similar proportions had provided on-the-job training (46 per cent of all workplaces) and off-thejob training (44 per cent); approaching a third of establishments (31 per cent) had provided both types of training. The likelihood that training is provided in a workplace is closely related to the number of staff working at the establishment. Just under half (45 per cent) of workplaces with fewer than five staff provided any training in the previous 12 months, rising to over threequarters (77 per cent) of those where 5-24 staff are employed, and to more than nine-inten where 25 or more people are employed. Results by size of establishment are presented in Figure 6.1. The incidence of training varies widely by sector, as shown in Figure 6.2. Differences by sector are in part driven by size: as is the case across the UK as a whole, sectors with low incidences of training such as Agriculture (31 per cent train) and Construction (54 per cent train) are dominated by small establishments, and sectors with high levels of training, such as Education (92 per cent) and Public Administration (also 92 per cent), tend to consist of large establishments. 0% There was also some variation in training activity by region, with the overall proportion of establishments training ranging from 66 per cent in South East Wales to 43 per cent in Mid Wales (Figure 6.3). This correlates with the geographic distribution of small and large establishments in Wales, where Mid Wales is dominated by smaller establishments and South East Wales is more likely to contain large establishments. Accordingly, establishments in the East Wales ESF region were more likely to provide training than those in West Wales and the Valleys (see Table 6.1). West Wales and the Valleys East Wales Column % % % Base 3,732 2,276 Total doing any training 56 63 On-the-job training only 16 14 Off-the-job training only 12 13 Both on- and off-the-job training 28 36 Do not train 44 37 Base: All establishments ## 6.3 Incidence Of Training And Workforce Development Activity Broader activity can take place in establishments which leads to skill development but which may not be classified as training. For this reason the UK Commission's Employer Skills Survey 2011 also asked employers whether they had engaged in any broader development activities, specifically: - supervision to ensure that employees are guided through their job role over time; - opportunities for staff to spend time learning through watching others perform their job roles; - allowing staff to perform tasks that go beyond their strict job role and providing feedback on how well they had done. This section explores the proportion of workplaces that have funded or arranged training or further development for their staff over the previous 12 months. In addition to the 59 per cent of establishments in Wales who train staff, a further 22 per cent have provided more informal development activity for their staff. The total proportion of establishments in Wales that provide any form of staff development is 81 per cent; however almost a fifth (19 per cent) of establishments offer no development at all for staff. This is slightly larger than the 17 per cent UK average of establishments providing no development for staff. Larger establishments are most likely to offer any form of development (Figure 6.4). The incidence of staff development varies by sector, as Figure 6.5 shows. The Agriculture industry was least likely to offer staff any form of development, with approaching a half of establishments offering no development for staff. Public Administration, Education and Health and Social Work were most likely to offer staff development; these establishments were also the most likely to train. This is partly a function of size: the Agriculture sector is dominated by small establishments more than any other sector in Wales. Although the Mid and South West regions were less likely to provide training for staff, establishments in this region that didn't provide training were slightly more likely to engage staff in these broader development activities (Figure 6.6). Although the cumulative effect when added to the proportion training is still that these regions are less likely to be providing any form of development for staff, the difference is not as large as it was for purely training activity. ## 6.4 The Volume Of Staff Trained And The Quantity Of Training Provided (Training Days) Having briefly considered broader development activities, the remainder of this section deals with on- and off-the job training. Notwithstanding possible double counting (staff being trained by two or more different employers in a 12 month period), in the previous 12 months employers in Wales had provided training to just over 650,000 staff, equivalent to 56 per cent of the total workforce. Between them, these 650,000 staff had spent almost five million days in training, equating to 7.5 days per trainee or 4.2 per staff member in the total workforce (see Table 6.5). This is similar to training levels in the UK as a whole, where 54 per cent of the workforce had been trained with an average of 7.8 days per trainee and 4.3 per employee. Although it is the largest establishments that are most likely to provide training to staff, it is the mid-size establishments (with 25-99 and 100-249 staff) that train the largest percentage of their workforce (66 and 68 per cent respectively), and the smallest establishments that provide most days training per trainee (10.2). The proportion of the workforce trained varied widely by sector, from only just over a quarter (27 per cent) in the Agriculture sector to almost three-quarters (74 per cent) in the Education sector. Hotels and Restaurants (9.2) and Health and Social Work (9.0) provided the most days training per trainee. Despite being less likely than South West Wales to offer training, employers in Mid Wales train a larger proportion of their staff than those in South West Wales (51 per cent compared to 45 per cent). This is still lower however than the proportions trained in North Wales (59 per cent) and South East Wales (61 per cent). % of Number of Days per Days per workforce days training employee trainee trained Unwtd base % Wales total 6,012 56 4.97m 4.2 7.5 UK total 87,572 54 117.29m 4.3 7.8 Size 1-4 1,216 44 590,000 4.5 10.2 5-24 3,474 56 1,340,000 4.6 8.2 25-99 1,074 66 1,330,000 4.7 7.1 100-249 151 68 580,000 3.6 5.3 250+ 97 47 1,120,000 3.6 7.8 Sector Agriculture 102 27 40,000 1.5 5.7 Mining and Quarrying 22 ** ** ** ** Manufacturing 468 56 570,000 4.1 7.3 Electricity, Gas and Water 111 66 40,000 2.4 3.6 Construction 503 46 260,000 4.0 8.7 Wholesale and Retail 1,069 57 950,000 5.0 8.7 Hotels and Restaurants 675 48 350,000 4.5 9.2 Transport and Communications 439 51 180,000 2.9 5.6 Financial Services 173 59 150,000 4.9 8.3 Business Services 791 60 440,000 3.3 5.6 Public Administration 130 57 370,000 4.2 7.3 Education 391 74 490,000 4.2 5.7 Health and Social Work 580 52 860,000 4.7 9.0 Community, Social and Personal Services activities 558 63 250,000 5.2 8.2 Region North Wales 1,431 59 1,390,000 5.3 8.9 Mid Wales 798 51 310,000 3.9 7.7 South West Wales 1,389 45 1,040,000 4.1 9.3 South East Wales 2,394 61 2,230,000 3.8 6.3 ESF Region West Wales and the Valleys 3,732 54 3,080,000 4.4 8.1 East Wales 2,276 59 1,890,000 3.6 6.7 Base: All establishments Number of training days rounded to nearest 10,000 '**' denotes base size under 25: too low to report. ## 6.5 Incidence Of Training By Occupation Figure 6.7 illustrates how the provision of training varies by occupation, and shows the number employed in each occupation (the full height of each bar), the number trained in the last 12 months (the darker subdivision), and the number trained in the last 12 months as a proportion of total employment (the figure in the boxes at the top of the chart). It is worth noting that the occupational profile shown is derived from employers describing their workforce structure within the survey, and differs somewhat from that shown by the Labour Force Survey which derives its profile from a survey of individuals. While more Managers are trained than any other occupational group, this is because they are the most numerous group of employees: in proportional terms, Managers are one of the least likely occupational groups to benefit from training (48 per cent), along with Elementary occupations (47 per cent) and Admin/Clerical staff (46 per cent). This is the same pattern as seen in the UK. Staff employed in Professional roles are the most likely occupational group to be trained (75 per cent),12 this is far higher than the level seen for this group in the UK as a whole (61 per cent). ## 6.6 The Planning And Budgeting Of Training Approaching two-fifths of all workplaces (38 per cent) have a training plan that specifies in advance the level and type of training employees will need in the coming year, and around a quarter (26 per cent) have a budget for training expenditure, with 44 per cent having at least one of these. Given that we have seen that 59 per cent of workplaces had provided training in the last 12 months, clearly training quite often takes places on an ad hoc basis without being formally planned. Just over a third of sites that had provided training in the last 12 months did not have either a training plan or budget covering their workplace (36 per cent); only just over half of those providing training said they had a formal training plan (56 per cent). This is similar to the proportions seen in the UK as a whole. The existence of a training plan or budget is not a guarantee that training will take place, as 15 per cent of employers with a training plan and or a budget had not funded or arranged any training for staff at their site in the previous 12 months. The likelihood of an establishment being covered by either a training plan or budget increases with the size, as shown in Table 6.6. TOTAL 1-4 5-24 25-99 100-249 250+ Column % % % % % % % Base: 6,012 1,216 3,474 1,074 151 97 Training plan 38 25 53 81 86 88 Training budget 26 15 36 66 74 85 Both / either 44 29 62 89 95 96 Base: All establishments ## 6.7 Types Of Training The most common type of training provided by employers is job-specific training (mentioned by 84 per cent of employers that trained staff in the last 12 months), followed by health and safety/first aid training (73 per cent). More than half of training employers had provided induction training for new recruits (52 per cent) and almost half provided training in new technology (47 per cent). Over a third had funded or arranged management or supervisory training (35 and 34 per cent respectively). This hierarchy of training types is very similar to that seen across the UK as a whole. ## 6.8 Training To Qualifications This section explores the extent to which employers train staff to nationally recognised qualifications and the level of the qualifications to which staff are trained. A quarter of employers (26 per cent, equating to 43 per cent of establishments that train) had funded or arranged training which was intended to lead to a nationally recognised qualification (whether it did lead to the that qualification being obtained or not); this was similar to levels seen in the UK as a whole where 25 per cent of employers (also equivalent to 43 per cent of establishments that train) were training staff to qualifications. Size is again a key discriminator here: the larger the training establishment the more likely it is to provide training leading to qualifications (although there is a slight drop amongst the very largest establishments with 250 or more staff). Just 14 per cent of those with fewer than five staff train to qualifications, whereas around three quarters of those with 100 or more do so. Establishments are most likely to provide training to nationally recognised qualifications in the Education (60 per cent) and Public Administration (55 per cent) sectors. Agriculture (7 per cent), Wholesale and Retail (17 per cent) and Transport and Communications (21 per cent) were least likely to provide this training. By region the pattern was driven by the proportion providing any training; looking at only those establishments providing training, the proportion training to qualifications is similar across the regions at around 42 to 44 per cent in each. Table 6.7 shows the proportion of all establishments providing any training to qualifications and the proportion that provide training to each level on the Qualifications and Credit Framework (QCF) (Ofqual, 2012). % of establishments providing training to each level Any Level 1 Level 2 Level 3 Level 4 Unwtd base % % % % % Wales total 6,012 26 5 9 10 8 UK total 87,572 25 8 9 9 7 Size 1-4 1,216 14 2 4 4 3 5-24 3,474 38 7 13 16 11 25-99 1,074 64 11 28 32 25 100-249 151 78 22 47 47 47 250+ 97 68 22 35 40 32 Sector Agriculture 102 7 0 2 1 3 Mining and Quarrying 22 ** ** ** ** ** Manufacturing 468 29 5 11 8 11 Electricity, Gas and Water 111 34 4 11 14 11 Construction 503 29 7 8 11 4 Wholesale and Retail 1,069 17 5 6 6 2 Hotels and Restaurants 675 28 7 13 8 3 Transport and Communications 439 21 4 6 6 5 Financial Services 173 22 5 5 5 8 Business Services 791 22 3 5 6 10 Public Administration 130 55 9 22 26 30 Education 391 60 8 15 37 34 Health and Social Work 580 48 4 21 30 20 Community, Social and Personal Services activities 558 31 5 17 12 7 Region North Wales 1,431 27 6 11 11 7 Mid Wales 798 18 3 6 6 4 South West Wales 1,389 24 5 8 10 6 South East Wales 2,394 28 4 9 11 10 ESF Region West Wales and the Valleys 3,732 25 5 9 10 7 East Wales 2,276 26 5 8 10 9 Base: All establishments '**' denotes base size under 25: too low to report. ## 6.9 Employer Expenditure On Training Across Wales, total employer expenditure on training in the 12 months prior to the UK Commission's Employer Skills Survey 2011 is estimated to have been £1.72bn. The total figure splits relatively evenly between expenditure on on-the-job training (£931m, 54 per cent of total expenditure) and off-the-job training (£793m, 46 per cent of total expenditure); this is a very similar proportionate division as seen across the UK as a whole. Table 6.8 presents a breakdown of the overall figure by component elements. Around half of total expenditure is accounted for by the cost of paying staff while they are being trained (49 per cent). In comparison a relatively small share of overall spend is accounted for by fees to external providers (eight per cent, though it represents 18 per cent of expenditure on off-the-job training). and the components of training expenditure Wales UK Unweighted base 1,501 % 11,117 % Total training spend: £1.72bn 100 £49.0bn 100 Off-the-job training: Total: £793m 46 £23.2bn 47 Off-the-job training: course-related: £655m 38 £19.3bn 39 Trainee labour costs £161m 9 £5,417m 11 Fees to external providers £100m 6 £2,776m 6 On-site training centre £84m 5 £2,986m 6 Off-site training centre (in the same company) £22m 1 £653m 1 Training management £280m 16 £6,794m 14 Non-training centre equipment and materials £18m 1 £404m 1 Travel and subsistence £21m 1 £480m 1 Levies minus grants -£32m -2 £-251m -1 Off-the-job training: other (seminars, workshops etc.): £138m 8 £3.9bn 8 Trainee labour costs £98m 6 £2,806m 6 Fees to external providers £40m 2 £1,128m 2 On-the-job training: Total: £931m 54 £25.8bn 53 Trainee labour costs £588m 34 £16,076m 33 Trainers' labour costs £343m 20 £9,717m 20 Base: All trainers completing the Investment in Training survey Clearly a large component of the overall training expenditure figure presented in the previous table is the wages of staff being trained, and in comparison relatively little is spent on payments to external training providers. Because of these very different elements within the overall figure it is useful to breakdown the overall figure between direct and indirect costs. In the following analysis, the following categories are used: - Indirect costs - the trainee labour costs (wages) of paying workers while they are not producing. - Direct costs - all other costs. Direct costs have been further broken down into i) external direct costs, elements that could in theory be outsourced to another organisation to provide and ii) internal direct costs, those elements that could not be transferred or outsourced to another organisation. External direct costs have been defined as fees to external providers and off-site training centre costs. Internal direct costs include on-site training centre costs, equipment and materials, travel and subsistence and levies minus grants. The costs of managers and supervisors being involved in organising and providing training has been treated as internally provided (not able to be outsourced) except where this involvement represented a reasonable amount of managers'/supervisors' time, since then this provision could potentially be externally outsourced by buying in a dedicated training organiser. It was classified as an 'external' direct cost where the training work of the managers/supervisors represented the work of one full person (i.e. where multiplying the average proportion of time spent on training matters by the number of people involved in organising/providing training within the establishment was at least one). Across Wales costs split evenly between direct (£877m) and indirect costs (£846m). External direct costs represent a slightly higher proportion of total training expenditure (28 per cent and £478m) than internal direct costs (23 per cent and £399m). This is a similar split to that seen across the UK as a whole. Each region saw a similar pattern with approximately half of investment going towards labour cost and half on direct expense. Establishments in Mid Wales had spent a slightly higher proportion of their investment on direct costs, with just 42 per cent going towards wages. This could be due to lower wages in the region on average, or higher costs of the types of training being provided. | | | | | |--------------------|-----------|--------|--------| | Per cent spent on: | | | | | | | | | | Unweighted | | | | | Expenditure | | Direct | Direct | | base | | | | | Row percentages | | | | | on training | tradeable | non- | costs | | tradeable | | | | | Wales | | | | | 1,501 | | | | | £1.72bn | | | | | | | | | | % | | | | | | | | | | 28 | | | | | | | | | | 23 | | | | | | | | | | 49 | | | | | | | | | | UK | | | | | 11,117 | | | | | £49.0bn | | | | | | | | | | % | | | | | | | | | | 27 | | | | | | | | | | 23 | | | | | | | | | | 50 | | | | | | | | | | Region | | | | | | | | | | | | | | | North Wales | | | | | 384 | | | | | £402.2m | % | 29 | 25 | | Mid Wales | | | | | 189 | | | | | £175.6m | % | 31 | 27 | | South West Wales | | | | | 338 | | | | | £302.5m | % | 26 | 24 | | South East Wales | | | | | 587 | | | | | £839.3m | % | 27 | 21 | Base: All establishments in each region. Expenditure rounded to nearest 100,000. Training expenditure by establishments in Wales is lower than in the rest of the UK, with an average spend per trainee of £2,600, as compared to upwards of £3,100 per trainee in England, Scotland and Northern Ireland. This could be related to Welsh median earnings being lower than the UK median (Office for National Statistics, 2012). As labour costs comprise a significant proportion of training spend, lower wages would reduce this figure compared to the UK average. Another possibility is that it results from the *specific types* of training undertaken in Wales (i.e. the average cost of these is lower than across the UK more widely). Furthermore, the fact that a slightly higher proportion of staff in Wales are trained than across the UK as a whole may also explain why the difference widens between the per capita and per trainee expenditure. Wales total UK total Unweighted base 1,501 11,117 Total training expenditure £1.72bn £49.0bn Per capita training expenditure (total workforce) £1,450 £1,775 Per capita training expenditure (training employers' workforce) £1,650 £2,050 Per trainee training expenditure £2,600 £3,275 Spend per trainee/per employee rounded to the nearest £25. Expenditure per staff member and per trainee was higher in Mid Wales than in the other regions. Table 6.9 shows that a higher proportion of Mid Wales training investment went on direct costs rather than indirect, suggesting that establishments in this region are investing in more expensive training solutions. This is likely to be related to the establishment size profile of the region: there is a clear pattern that larger establishments spend less on training per trainee and per capita due to being able to access economies of scale. (As shown in Figure 2.5, Mid Wales has more small establishments than other regions.) | South | South | |--------------------------------|----------| | North | Mid | | West | East | | | | | Wales | | | total | | | | | | Wales | | | | | | Wales | | | | | | Wales | | | | | | Wales | | | | | | Unweighted base | 1,501 | | Total training expenditure | | | | | | £1.72bn | | | | | | £402.2m | | | | | | £175.6m | | | | | | £302.5m | | | | | | £839.3m | | | | | | Per capita training | | | expenditure (total workforce) | | | | | | £1,450 | | | | | | £1,525 | | | | | | £2,200 | | | | | | £1,200 | | | | | | £1,425 | | | | | | £1,650 | | | | | | £1,750 | | | | | | £3,050 | | | | | | £1,375 | | | | | | £1,575 | | | | | | Per capita training | | | expenditure (training | | | employers' workforce) | | | | | | Per trainee training | | | expenditure | | | | | | £2,600 | | | | | | £2,575 | | | | | | £4,350 | | | | | | £2,700 | | | | | | £2,350 | | | | | Spend per trainee/per employee rounded to the nearest £25. ## 6.10 Training And Investors In People Status Investors in People is a leading people management standard, with the aim of improving business performance through people; 15 per cent of establishments in Wales are accredited with the Investors in People Standard (Table 6.12). Larger establishments are much more likely to be accredited than smaller establishments, 60 per cent of establishments with 250+ staff are accredited compared to only 10 per cent of establishments with fewer than five. Sectors with larger establishments such as Public Administration and Education have the highest proportion of employers accredited (45 per cent and 39 per cent respectively). Employers are least likely to be accredited in the Agriculture sector (only three per cent of employers), which is dominated by small sites. There is some regional variation in accreditation: establishments in Mid Wales are the least likely to be accredited (11 per cent) and establishments in South East Wales and North Wales are the most likely (17 per cent are in each). This is also likely to be influenced by typical establishment size in these regions. Accredited with Investors in People Standard Unwtd base % Total 6,012 15 Size 1-4 1,216 10 5-24 3,474 20 25-99 1,074 39 100-249 151 50 250+ 97 60 Sector Agriculture 102 3 Mining and Quarrying 22 ** Manufacturing 468 12 Electricity, Gas and Water 111 12 Construction 503 8 Wholesale and Retail 1,069 17 Hotels and Restaurants 675 14 Transport and Communications 439 9 Financial Services 173 21 Business Services 791 12 Public Administration 130 45 Education 391 39 Health and Social Work 580 31 Community, Social and Personal Services activities 558 21 Region North Wales 1,431 17 Mid Wales 798 11 South West Wales 1,389 14 South East Wales 2,394 17 ESF Region West Wales and the Valleys 3,732 16 East Wales 2,276 14 Base: All establishments '**' denotes base size under 25: too low to report. ## 6.11 Assessing The Impact Of Training Almost two-thirds of workplaces that train (63 per cent) formally assess whether the training received by employees impacts on their performance, similar to the number seen in the UK (65 per cent). The larger the size of the workplace the more likely they are to assess the impact of their training activity, the figure increasing from 53 per cent among establishments that train who have fewer than five staff, up to over eight-in-ten of those with 100 or more staff (Figure 6.9). There were noticeable differences by sector, with those operating in Public Administration (80 per cent), Education (78 per cent) and Health and Social Work (74 per cent) more likely than average to assess the impact of their training. The majority of establishments in three of these sectors are government-funded or charities, and there is a marked difference by broad status in the likelihood that training activity is formally assessed. Differences by region were less marked, though establishments in South East Wales that trained (65 per cent) were slightly more likely to formally assess the impact of their training than employers in the other regions. Base: All establishments providing training (unwtd) (4,681) 63% Wales (607) 53% 1 to 4 (2,818) 68% 5 to 24 (1,013) 80% 25 to 99 (147) 86% 100 to 249 (96) 83% 250+ (40) 32% Agriculture (20) ** Mining and quarrying (355) 58% Manufacturing (82) 69% Electricity, Gas and Water (336) 57% Construction (785) 66% Wholesale and Retail (470) 64% Hotels and Restaurants (318) 56% Transport and Communications (143) 72% Financial services (656) 59% Business Services (121) 80% Public Administration (379) 78% Education (534) 74% Health and Social Work (442) 66% Community, Social and Personal Services … (1,133) 61% North (559) 62% Mid (1,054) 60% South West (1,935) 65% South East ## 6.12 Reasons For Not Providing Training All employers that had not funded or arranged any off-the-job or on-the-job training for staff at their site over the last 12 months were asked why they had not done so. Results are summarised in Figure 6.10. The most common reason given by establishments that did not train was that they considered their staff to be fully proficient and / or that their staff did not need training. This was mentioned spontaneously by almost two-thirds of non-trainers (65 per cent). This included 39 per cent of non-trainers who reported having skills gaps. This suggests that the skills gaps these establishments reported were not the type that could be addressed by training measures. These could have been related to experience in the job role, for example. A lack of money for training and training not being a key priority for the establishment were secondary reasons for not training (11 per cent mentioned each). Issues relating to training supply were relatively infrequently mentioned: only small proportions said a reason for not training was that they do not feel there is training available in a relevant subject area (four per cent) or that no training was available locally (one per cent). establishment development takeover transition) ## 6.13 Conclusion The majority of employers in Wales are investing in the skills and development of their workforce, with 59 per cent providing training for staff; a further 22 per cent do still provide some form of development for staff (such as supervision and working beyond their role). The proportion of establishments that provide training is highest in South East Wales; there is a lot of variation by sector however and approaching half of establishments in the Agriculture sector do not provide any training or development for their staff. Conversely establishments in Public Administration, Education and Health and Social Work are most likely to be offering development for their staff, indicating that the public sector is an important driver for much of the skills investment activity. The proportion of establishments providing training in Wales is similar to that in the UK as a whole. Over half of all employees receive training (56 per cent) but involvement varies markedly by occupation. In particular, it is Managers (48 per cent receive training), those in Elementary roles (47 per cent) and Administration/Clerical occupations (46 per cent) who are least likely to receive training. Employees working at mid-sized establishments (with 25-249 staff) are most likely to receive training, as these establishments train a larger percentage of their workforce than the smallest and largest employers (around twothirds of staff in these establishments receive training). However whilst the proportion of staff trained is only slightly more than that seen across the UK, training spend per trainee is less in Wales than it is in the rest of the UK. This could be related to there being lower median earnings in Wales than across the UK as a whole. Another possibility is that it results from the *specific types* of training undertaken in Wales (i.e. the average cost of these is lower than across the UK more widely). In terms of the relationship between levels of training and other indicators, it is notable that employers with skills gaps are more likely to train their staff than those without (82 per cent v 55 per cent). This confirms that training is a common response to having a skills deficiency, as seen elsewhere in the report. However, it also reflects the extent to which skills gaps should not necessarily be viewed in isolation as a negative issue. Those businesses with skills gaps are engaged enough to have identified an issue with their staff and in the vast majority of cases are taking action to overcome these problems, if they require attention. As well as raising questions about the volume and scale of skills investment, the findings also raise important questions about the quality of the training. Only a quarter of establishments (26 per cent) provide training leading to a nationally recognised qualification. If qualification attainment encourages transferability and is a good indicator of quality it might be expected that this would be higher. Again there are some important variations by sector with establishments in Education (60 per cent) and Public Administration (55 per cent) more likely to provide training towards a nationally recognised qualification. Among the 41 per cent of employers in Wales not providing any training for staff, the main reasons were related to the perception that all staff were proficient in their roles and the costs of training, rather than training supply. This suggests that it is the attitudes of employers and the value that they place on training that may need tackling in order to increase skills investment, rather than any shortfall in the supply of training in Wales. ## 7 How Employers Use Staff Skills Chapter Summary Most establishments in Wales were engaging in what have become known as "high performance working practices": working practices deliberately introduced to improve organisational performance that maximise employee commitment and skills use. Most commonly this involved providing a flexible working environment in which employees have variety in their work and discretion over their tasks, with around nine-inten establishments providing this for at least some of their employees. Communication with employees was also widespread, most commonly via scheduled team meetings. In terms of people management practices, around two-thirds of establishments gave formal job descriptions to at least some of their employees (53 per cent to all employees), and one half of establishments had annual performance reviews for at least some staff (39 per cent for all staff). Fewer used pay and incentive schemes to motivate staff: 39 per cent had any policy in place; the most common incentives were bonuses based on overall company performance (23 per cent). Larger establishments and those in South East Wales were most likely to have high performance working practices in place. In common with other themes driven by establishment size, this means that establishments in South East Wales, the region with the highest proportion of large establishments, were most likely to have high performance working practices in place. ## 7.1 Introduction High performance working is an approach to managing organisations that consciously aims to stimulate more effective employee involvement and a commitment in order to achieve high levels of performance. (Sung and Ashton, 2005; UKCES, 2009b; WESB, 2011). The approach is designed to increase employee discretion over their work and use and develop employees' skills effectively. The adoption of high performance working systems can potentially offer benefits to both employers *and* employees. For employers there is a strong association, backed up by several research studies, between high performance working practices and improved performance as well as staff retention. For employees, there is an association between high performance working and increased job satisfaction and well-being (SSDA, 2006; UKCES, 2009b). High performance working is also associated with innovation and the pursuit of high value-added business strategies. The presence of high performance working practices alone will not necessarily lead to performance benefits - it is crucial that the practices are properly implemented and integrated into a system. In this sense, the use of the term 'high performance working' should be viewed as an aspirational objective, rather than a description of a set of practices with a guaranteed outcome. However, there are limitations in terms of how high performance working can be measured in a large scale survey, and the measurement of sets of practices is a recognised approach that can give an *indication* of the extent of high performance working (Sung and Ashton, 2005; Bates et al, 2009). The high performance working indicators measured in the survey can be classified into four broad categories: human resource management (e.g. annual performance reviews and formal job descriptions); reward and commitment practices (e.g. performance based pay and incentives and the use of flexible working conditions); employee involvement practices (e.g. meetings, team working and staff surveys); and workplace culture practices, which includes job design (e.g. task discretion and variety). The UK Commission's Employer Skills Survey 2011 covered a varied selection of practices that would fall under the banner of high performance working practices in each of these broad categories. This chapter looks specifically at the prevalence of high performance working practices amongst employers in Wales. ## 7.2 Human Resource Management Practices High performance working practices under the human resource management category help to engage staff by working with them as individuals to make the most of their skills and their potential, or in other words to optimise skills utilisation. The focus is on maximising the contribution that people can make in the work place, ensuring their skills are fully deployed, harnessed and developed to optimise organisational performance (UKCES, 2010b). The survey covered three practices that can contribute to this: whether employers identified "high potential" individuals in their organisations, whether they performed annual staff evaluations, and whether they had formal job descriptions in place. Identifying "high fliers" is important for establishments as these individuals can contribute considerably to organisational performance if their skills are fully utilised. As well as the risk of missing the benefits to be achieved by fully unlocking their potential, highly skilled individuals may become dissatisfied and leave if they do not feel challenged by a role. About four-in-ten establishments (41 per cent) in Wales have ways to identify high potential staff, either informally or formally (Table 7.1). Larger establishments were more likely to have the means to identify talented staff: 29 per cent of establishments with fewer than five staff had such processes in place, rising to 80 per cent of establishments with 250+ staff. Among employers that do identify talented staff, the processes are more likely to be informal than formally documented. Total 1-4 5-24 25-99 100-249 250+ Column % % % % % Base: 2,998 602 1,727 535 82 52 Yes - formally documented 10 4 17 35 36 50 Yes - informal 31 26 40 39 50 30 No 56 67 41 24 13 20 Base: All establishments in Module 1 (weighted to be representative of all establishments) Establishments in Mid Wales were less likely to have a formal process in place to identify talented staff (five per cent); those in South East Wales were most likely (14 per cent). Annual performance reviews are another indicator of high performance working. These potentially increase an employer's ability to get the most out of all of their staff. Half of establishments in Wales reported using annual reviews for any staff and in 39 per cent of establishments all staff have an annual review However, no staff at all receive an annual performance review in 50 per cent of establishments (see Figure 7.1). Part of getting the best out of staff is making it clear to them what is expected of them; this gives staff direction and ensures everyone knows their responsibilities. Most establishments make use of formal job descriptions for this: two-thirds of establishments in Wales (64 per cent) have job descriptions for at least some staff. Establishments in Mid Wales were least likely to have either annual performance reviews (34 per cent) or formal job descriptions (51 per cent) for any staff; establishments in South East Wales were most likely (59 and 74 per cent respectively). ## 7.3 Use Of Reward And Commitment Practices A key facet of high performance working is creating employees who are motivated and have high morale. Pay and reward schemes play a part (although are certainly not the whole story) in ensuring this happens. A key part of this is ensuring employees feel adequately remunerated for the effort they put in, through pay and reward schemes that are individual to the employee and related to their performance, rather than generic remuneration irrespective of individual efforts and abilities. To address this, employers reported whether they reward staff based on company performance and based on individual performance, and whether they provided flexible benefits. This information is only reported in relation to employers in the private sector, as public sector bodies generally have less autonomy over how their pay grades are calculated or the reward and commitment practices used. Around two-fifths of establishments in Wales had some form of pay and incentive scheme covered by the survey. Approaching a quarter of establishments (23 per cent) in the private sector reward staff based on the overall performance of the organisation and six per cent have share options for employees below senior management (Figure 7.2). Almost a fifth (17 per cent) of establishments reward employees based on based on individual performance, and a fifth (19 per cent) offered flexible benefits13 to employees. Establishments in South East Wales were most likely to have any of the performance related pay schemes covered by the survey (45 per cent had at least one) and establishments in Mid Wales least likely (25 per cent had at least one). ## 7.4 Employee Engagement Practices Engaging employees in dialogue and decision making and the way in which information is disseminated to employees in an establishment is also important in making employees feel valued and thus increasing their engagement and motivation. Employee engagement practices are widely recognised as key to high performance working systems (UKCES, 2009b). Examples of such practices include transparency in the way employees are treated in disciplinary situations, and the extent to which they are encouraged to give opinions and work with others in the organisation through team working for the benefit of the organisation. Of the communication and engagement techniques covered by the survey, the most common was the use of a formal procedure for dealing with discipline and dismissals for non-managerial employees, cited by 64 per cent of establishments (Figure 7.3). About half of establishments reported use of other practices that involve their employees in company decision making. These included: use of problem solving or continuous improvement groups (cited by 53 per cent of establishments); giving employees information about the financial position of the establishment (51 per cent); creating teams for projects (47 per cent); and consulting employees (37 per cent). Establishments in South East Wales were more likely than establishments in any other region to have each of these practices in place. Scheduled team meetings were the most commonly cited means of communicating with employees (cited by 81 per cent of establishments). Other popular methods of sharing information in the workplace include intranet (56 per cent), newsletters (52 per cent), formal staff suggestion schemes (45 per cent) and annual staff surveys (40 per cent, see Figure 7.4). Establishments in South East Wales were more likely than average to have each of these communication channels in place with the exception of newsletters; establishments in Mid Wales were less likely than average to have any of them in place. Base: All establishments in Wales that are multi-site or have more than 10 employees : 2,069 (unweighted) NB. Question only asked to establishments randomly assigned to "Module 1" in the survey; data has been weighted to be representative of all in Wales ## 7.5 Workplace Culture Practices The variety, flexibility and discretion in staff members' day to day work are all indicators of how much perceived trust the employer has in the employee, as well as giving some feel of the extent to which the working environment allows employees to adapt to new situations and to change, and thus the extent to which they are able to deploy their skills in a way that is both efficient for the organisation and rewarding for the employee. The vast majority of employers provided staff with at least some variety in their work (Figure 7.5). Only 12 per cent of establishments offered little or no variety in work. Similarly most employers in Wales allow staff to exercise discretion in their work; again only 12 per cent of establishments allowed staff little or no discretion. This flexibility and the ability to exercise discretion not only indicates trust in the employee on the employer's part, but also means that any unusual situations that may arise can be dealt with promptly and effectively, as the employee will be empowered to take a call on the correct course of action (for example). Three-quarters of establishments allowed at least some degree of flexible working. Almost four-in-ten (39 per cent) offered a large amount and a further third offered some flexible working. A quarter (25 per cent) of establishments allowed not much or no flexibility. Allowing employees to work in the way that best suits them can increase engagement and morale, and ensure the employee's outputs are optimised by reducing absenteeism and helping employees to balance their work and home life (ACAS, 2012). NB. Question only asked to establishments randomly assigned to "Module 1" in the survey; data has been weighted to be representative of all in Wales ## 7.6 Conclusions Adopting high performance working practices can help organisations maximise the skills their staff possess, effectively developing them and putting them most efficiently to use to ensure that every staff member is performing to their maximum potential. If implemented properly, these practices can benefit both employers and employees. There are also wider implications that go beyond individual organisations: unlocking the potential in the workforce is central to improving the economic prospects of the nation. The UK Commission's Employer Skills Survey measured a number of working practices to assess the extent to which establishments in Wales are using high performance working practices. The majority of establishments are using at least some practices, with clear differences by size and by geography. Establishments in Wales give their employees variety in their work and discretion over how they do this work. Around half said employees had this "to a large extent" and a further third "to some extent". Most are also communicating with staff, most commonly via team meetings. These sorts of practices should allow employees to feel valued and trusted. Around half of establishments also engaged in some form of performance management, saying they hold annual performance reviews for staff. However, only ten per cent had formal procedures in place to identify "high potential" staff, suggesting that some establishments are missing out on getting the best out of their talent. Larger establishments were more likely to have high performance working practices in place than smaller establishments. Although reasons for this were not explored in the survey, research suggests that smaller establishments may be able to achieve the higher level goals associated with these practices without formal methods, or they may be less likely to have human resource staff or other managers to promote these ways of working (UKCES, 2009b). The overall picture is therefore a positive one in terms of the prevalence of the individual working practices we have identified. However, it should be noted that the presence of practices alone is not a guarantee that organisations are truly engaged in high performance working, or that they have full high performance *systems* in place. As noted above, for an organisation to be successfully classed as a high performance workplace, it is vital that the practices are *implemented* properly and integrated into a system. The results from the survey do, however, give an indication of the extent of high performance working in Wales. ## 8 Conclusions The UK Commission's Employer Skills Survey 2011 is a large-scale employer survey, covering an extensive range of topics including recruitment, internal skills gaps, investment in training, recruitment and high performance working. This concluding chapter summarises the key messages coming out of the project. ## 8.1 Skills Deficiencies In Wales A similar proportion of employers were recruiting in Wales at the time of the survey as were in the UK as a whole (11 per cent in Wales compared to 12 per cent in the UK), and the proportion of these experiencing problems filling their vacancies was also matched at four per cent, a small minority of employers. However for those who were experiencing difficulties filling vacancies in Wales the problem was acute, with a third of vacancies in Wales at the time of the survey proving hard to fill. This compares to just under a quarter of vacancies in the UK as a whole. Where hard-to-fill vacancies are being experienced, nearly all employers reported that the inability to fill these vacancies was having an impact on their business performance. Key impacts included increasing the workload for other staff, difficulties meeting customer service targets, losing business to competitors and delays in bringing new products or services to market. It is clear that where demand for skills is not met it can act as a brake on performance and innovation. One of the main reasons for hard-to-fill vacancies is a lack of applicants with the skills, qualifications or experience the employer demands (a "skill-shortage" vacancy). Over a fifth (22 per cent) of vacancies in Wales were proving hard to fill due to skill shortages, compared to just 16 per cent in the UK as a whole. This figure across Wales is driven by skill deficiencies in Mid Wales, where three-fifths (59 per cent) of vacancies are hard to fill due to skill shortages; in the other regions the figure is similar to the UK figure (ranging from 15 to 18 per cent). This indicates a serious issue with skills availability in this region, and is likely to be a key factor holding back economic progress there. Skills deficiencies are not evenly spread across the economy either. Concentrated pockets exist by sector with the Business Services sector most likely to suffer skillshortage vacancies, and data suggests that employers in Wales find it hardest to find skilled staff to fill vacancies in Associate Professional, Machine Operative and Skilled Trade roles; the former two more so than employers in the rest of the UK. Skills gaps, where existing employees are not fully proficient at their jobs, are reported at similar levels to that seen across the UK; a minority of establishments (13 per cent) reported having any skills gaps among their staff, equating to five per cent of employees in the workforce in Wales. Again some sectors are more affected by skills gaps than others, with establishments and staff in the Hotels and Restaurants sector more likely to be affected. Skills gaps were more prevalent in typically lower skilled occupations such as Elementary, Machine Operatives and Sales and Customer Services roles, and in Skilled Trade occupations. Mid Wales stands out on a number of measures. As noted when discussing regional breakdowns, the size distribution of sectors across Wales is uneven, and the concentration of small establishments in Mid Wales should be borne in mind. Despite having the highest levels of skill-shortage vacancies, and the lowest levels of training, employers in Mid Wales were no more likely to report having staff who were not proficient at their jobs than the other regions in Wales. This could be because employers in this region, knowing they do not have the capacity or budget to train staff, are more selective about who they employ thus skill deficiencies in the region present themselves as skillshortage vacancies, rather than taking people on who are not sufficiently skilled and causing a skills gap. It could however be indicative that employers in the region are less aware of employees skills needs and issues have passed unidentified. The survey findings can only report those employers that are aware of the skills gaps they face, and other evidence of a low-skill equilibrium within the UK (for example see the original paper on this subject by Finegold and Soskice, 1988) suggests that many employers not registering problems may be doing so because of a lack of desire to build up skills, innovate, grow and move up the value chain. Hence the survey results on the extent of skills gaps, in combination with the evidence that, for example, establishments in this region are the least likely to have annual review for staff or processes in place to identify talent supports this latter hypothesis. It also needs to be borne in mind that having a skills gap can be a transient issue where some employees may be new to the role and developing proficiency, or where the nature of the role is changing to meet new business opportunities. In such cases skills gaps would be expected to decrease over time. This means skills gaps are not necessarily negative: they may reflect a business that is innovating and creating new products, processes or services and is noticing the need to upskill its staff as a result. This is not always the case and, similar to hard-to-fill vacancies, where these skills gaps occur they have an impact on business performance, for example through increasing the workload of other staff, potentially leading to increased operating costs (for example by having to pay overtime or to bring in temporary staff). Manufacturing is an important sector in Wales, accounting for 139,000 jobs (12 per cent of total employment). This makes Manufacturing the third largest sector by employment (after Health & Social Work and Retail & Wholesale), so is an important sector in the Welsh economy. Manufacturing accounts for a similar proportion of establishments in all four regions: five or six per cent and it is notable that combined skills deficiencies in Manufacturing as a sector are higher than the average for each region. Although results are not presented for skills-shortage vacancies by occupation by sector due to a small base size, both Skilled Trades and Machine Operatives are occupations that have high densities of skills shortages, and both are well represented in the Manufacturing sector. Establishments in Manufacturing also show a slightly higher level of skills gaps among their current employees than the Wales average. This slightly higher level would not be commented upon were it not for the results of the follow-up question, which asked establishments what action they had taken to overcome skills gaps. Manufacturing was the least likely sector to have increased training in response to skills gaps. When combined with future employment projections showing Manufacturing's continued decline in overall employment (see UKCES, 2012), this raises questions about the ability of the sector to stay competitive. Are Manufacturing firms taking sufficient action to address skills deficiencies? ## 8.2 Retention The survey also explored retention difficulties as a factor which contributes to the overall demand and supply of suitably skilled people in the labour market. A minority of establishments in Wales reported retention difficulties (six per cent), with lack of interest in the type of work in question the most prevalent reason for difficulties. Despite a similar proportion of establishments with retention difficulties reporting it had an impact on the establishment, most commonly on existing staff, far fewer of these establishments in Wales are taking any action to overcome these difficulties. ## 8.3 Investment In Training A total of 58,000 employers in Wales, equivalent to 59 per cent of all establishments, invested £1.72bn in the skills development of their employees in the 12 months prior to the survey. Of this, 49 per cent was indirect costs (costs of paying wages to staff whilst training); 28 per cent was direct tradeable, outsourceable costs (for example fees to external providers); and 23 per cent was spent on non-tradeable direct costs that cannot typically be outsourced by the establishment (such as management of training). Whilst the proportion of employers providing training was similar in Wales to that seen in the UK as a whole, training expenditure per trainee was lower in Wales than it was in the UK as a whole. This could be related to there being lower median earnings in Wales compared to the UK, as labour costs of trainees make up a significant proportion of the overall training spend. Skills investment and training is not provided to all employees. Overall, 56 per cent of employees were trained in the previous 12 months. This varies markedly by occupation. Those in Elementary occupations, Administrative and Clerical workers and those in the Managerial occupational group are the least likely to receive training. Elementary occupations are also less likely to be fully proficient in their role. Is it possible that enhanced training opportunities could address those difficulties? Similar patterns are observed in the Manufacturing and Hotels and Restaurants sectors which experience greater skills gaps but, across all measures, do not necessarily invest more in training. Whilst training is not necessarily the solution to skills gaps, the data raises questions about whether training investment is supporting business development and addressing the potentially severe impacts of skills deficiency reported. Employers that do not train were most likely to state that all staff were fully proficient in their roles, rather than any particular issues with training supply. This however raises questions about the levels of innovation in these establishments, their processes for recognising training needs, and the capacity they have to maintain a competitive advantage. ## 8.4 The Work-Readiness Of Education Leavers Despite a sometimes negative press about young people, the survey finds that the majority of the 24 per cent of employers who had recruited education leavers in the last 2- 3 years found them well prepared for work. Employers' views of the preparedness of such recruits increases with the age of the recruit and their time spent in education. Higher Education leavers are seen as being better prepared on the whole than younger recruits, or those that have spent less time in education. There seem to be several reasons for this which may include: the additional time Higher Education leavers spend in education developing their skills and experience; employers may simply invest more in graduate recruitment to help them identify a more appropriately suited recruit; or it may just be that graduates are older, more experienced and more mature generally. In common with the results across England and Northern Ireland, employers in Wales found that 17-18 year old FE leavers were generally better prepared for work than school leavers of the same age. This may be because college students are more likely to study vocational courses more closely related to the jobs they go on to take, or they may be more likely to combine work and learning and therefore have more experience of the world of work. For the minority of employers who find education leavers poorly prepared for work, the main reason is a lack of experience. Unsurprisingly, this lack of experience is more common for younger recruits, which is challenging to ameliorate. However, it suggests many employers may support the idea of increased work experience opportunities for young people within the education system. Creative employer involvement with young people in education may also go some way to improving the high numbers of establishments reporting that they cannot find staff who are interested in working in their sector. ## 8.5 Facing The Challenge The survey points to pockets of skills deficiency in workplaces in Wales– by region, establishment size, occupation and sector. Most of these pockets are the same as the UK as a whole, but some are distinct or more pronounced such as hard-to-fill vacancies for Associate Professional and Machine Operative staff. Retaining staff also poses problems to business in Wales, but they are less likely to take action to address retention than skill deficiency. However, all of these factors impact on business success. At a challenging time for the economy, arguably it is more important than ever to take measures to retain and develop talent to help counter the economic challenges. Employers in Wales are as likely to train their staff as employers in England, but less so than in Northern Ireland and Scotland. They also spend less on training per trainee. Are businesses in Wales investing wisely enough: to tackle the pockets of deficiency; to counter the business impacts of those deficiencies and to support prosperity? The survey data highlights potential areas of concern, further dialogue will support the development of effective solutions. ## Appendix A: Comparisons With Future Skills Wales 2005 The UK Commission's Employer Skills Survey 2011 (UKCESS 2011) took a sampling approach that included all establishments in the UK excluding sole traders. This is slightly different to the population used in the Future Skills Wales (FSW) survey of 2005, which used all establishments with two or more people working at them as its criteria for inclusion. This means the results reported in the main body of this report for Wales are not directly comparable to those reported by FSW 2005. However it is possible to take a cut of the UKCESS 2011 data and apply the same weighting principles as used in FSW 2005 to produce comparable figures and thus analyse patterns over time for those questions that remained the same. In the six years that elapsed between the surveys much changed in the economic landscape of Wales. Comparison of the survey figures at these two points emphasises the extent to which the 2008 recession affected the labour market in Wales, with vacancy levels still less than two-thirds what they were during the mid-2000s. Logically, with fewer jobs to be had there will be more applicants per position. It therefore follows that proportionately the reduction in the percentage of establishments that are finding any of their vacancies hard-to-fill vacancies is higher than the reduction in vacancies overall. However, it is of note that the proportion experiencing skill-shortage vacancies has not reduced at all, suggesting that there is as much of an issue in finding suitably skilled applicants for positions as there was previously. When viewed as a proportion of those with vacancies, there are in fact more: one in three establishments with vacancies in 2011 were finding any of their vacancies hard to fill due to skill-shortages, compared to one in five in 2005. The proportion of establishments experiencing skills gaps, where one or more of their staff are not fully proficient at their job role, reduced slightly between the two surveys, from 20 per cent to 17 per cent. This could be because people are staying in their jobs for longer due to the more difficult prospects of finding a new job, and thus gaining proficiency over time (as Chapter 5 of this report shows staff being new to the role is one of the largest causes of gaps). This reduction was not uniform across all sizes and sectors of establishment, as seen in Table A.5 below. Worryingly, however, the proportion of establishments providing off-the-job training for their staff had reduced across all sizes and sectors of establishment (with the exception of Business Services and Manufacturing). Whether budgetary cuts due to the recession have led those who have ceased off-the-job training to move to on-the-job or whether they have stopped training entirely cannot be deduced from our survey results. ## Employers' Interaction With The Labour Market 2005 2011 Unweighted base 6,719 5,958 Column % % % % of establishments with a vacancy 21 13 % of establishments with a hard-to-fill vacancy 10 5 % of establishments with a skill-shortage vacancy 4 4 Base: All establishments in Wales in comparable sample 2005 2011 Column % % % Size 2-9 Base: 3,538 2,655 % of establishments with a vacancy 17 9 % of establishments with a hard-to-fill vacancy 8 4 % of establishments with a skill-shortage vacancy 4 3 10-24 Base: 1,632 1,981 % of establishments with a vacancy 30 19 % of establishments with a hard-to-fill vacancy 14 8 % of establishments with a skill-shortage vacancy 5 5 25-99 Base: 1,283 1,074 % of establishments with a vacancy 40 30 % of establishments with a hard-to-fill vacancy 17 9 % of establishments with a skill-shortage vacancy 8 6 100+ Base: 266 248 % of establishments with a vacancy 61 57 % of establishments with a hard-to-fill vacancy 22 11 % of establishments with a skill-shortage vacancy 10 9 Base: All establishments in Wales in comparable sample 2005 2011 Column % % % Sector Agriculture Base: 214 101 % of establishments with a vacancy 4 3 % of establishments with a hard-to-fill vacancy 1 2 % of establishments with a skill-shortage vacancy 1 2 Mining & Quarrying Base: 20 22 % of establishments with a vacancy ** ** % of establishments with a hard-to-fill vacancy ** ** % of establishments with a skill-shortage vacancy ** ** Manufacturing Base: 1,031 467 % of establishments with a vacancy 21 17 % of establishments with a hard-to-fill vacancy 9 6 % of establishments with a skill-shortage vacancy 5 5 Electricity, Gas and Water Base: 13 110 % of establishments with a vacancy ** 14 % of establishments with a hard-to-fill vacancy ** 8 % of establishments with a skill-shortage vacancy ** 6 Construction Base: 438 498 % of establishments with a vacancy 13 6 % of establishments with a hard-to-fill vacancy 9 3 % of establishments with a skill-shortage vacancy 6 2 Wholesale and Retail Base: 1,315 1,062 % of establishments with a vacancy 16 12 % of establishments with a hard-to-fill vacancy 7 3 % of establishments with a skill-shortage vacancy 4 2 Hotels and Restaurants Base: 415 666 % of establishments with a vacancy 32 15 % of establishments with a hard-to-fill vacancy 19 8 % of establishments with a skill-shortage vacancy 4 5 2005 2011 Column % % % Transport and Communications Base: 522 435 % of establishments with a vacancy 21 15 % of establishments with a hard-to-fill vacancy 9 8 % of establishments with a skill-shortage vacancy 4 6 Finance Services Base: 215 173 % of establishments with a vacancy 15 12 % of establishments with a hard-to-fill vacancy 8 3 % of establishments with a skill-shortage vacancy 4 3 Business Services Base: 833 789 % of establishments with a vacancy 22 14 % of establishments with a hard-to-fill vacancy 10 7 % of establishments with a skill-shortage vacancy 6 5 Public Administration Base: 54 129 % of establishments with a vacancy 33 16 % of establishments with a hard-to-fill vacancy 3 2 % of establishments with a skill-shortage vacancy 3 1 Education Base: 418 391 % of establishments with a vacancy 29 24 % of establishments with a hard-to-fill vacancy 8 3 % of establishments with a skill-shortage vacancy 3 2 Health and Social Work Base: 626 571 % of establishments with a vacancy 24 20 % of establishments with a hard-to-fill vacancy 11 6 % of establishments with a skill-shortage vacancy 3 4 Community, Social and Personal Services activities Base: 605 544 % of establishments with a vacancy 28 17 % of establishments with a hard-to-fill vacancy 12 7 % of establishments with a skill-shortage vacancy 4 4 Base: All establishments in Wales in comparable sample '**' denotes base size below 25: too small to report. 2005 2011 Column % % % Region North Base: 1,511 1,420 % of establishments with a vacancy 21 12 % of establishments with a hard-to-fill vacancy 11 5 % of establishments with a skillshortage vacancy 5 3 Mid Base: 675 788 % of establishments with a vacancy 24 13 % of establishments with a hard-to-fill vacancy 13 6 % of establishments with a skillshortage vacancy 3 4 South West Base: 1,593 1,376 % of establishments with a vacancy 22 12 % of establishments with a hard-to-fill vacancy 11 6 % of establishments with a skillshortage vacancy 4 4 South East Base: 2,940 2,374 % of establishments with a vacancy 21 14 % of establishments with a hard-to-fill vacancy 8 5 % of establishments with a skillshortage vacancy 4 4 Base: All establishments in Wales in comparable sample ## Internal Skills Mismatch 2005 2011 Unwtd base % Unwtd base % Wales Total 6,719 20 5,958 17 Size 2-9 3,538 19 2,655 13 10-24 1,632 23 1,981 26 25-99 1,283 23 1,074 34 100+ 266 50 248 42 Sector Agriculture 214 11 101 7 Mining and Quarrying 20 ** 22 ** Manufacturing 1,031 28 467 22 Electricity, Gas and Water 13 ** 110 22 Construction 438 24 498 13 Wholesale and Retail 1,315 19 1,062 21 Hotels and Restaurants 415 19 666 22 Transport and Communications 522 15 435 17 Finance Services 215 27 173 17 Business Services 833 19 789 17 Public Administration 54 9 129 16 Education 418 19 391 22 Health and Social Work 626 21 571 18 Community, Social and Personal Services activities 605 22 544 16 Region North 1,511 20 1,420 18 Mid 675 19 788 16 South West 1,593 19 1,376 15 South East 2,940 20 2,374 19 Base: All establishments in Wales in comparable sample '**' denotes base <25: too small to report ## Workforce Development 2005 2011 Unwtd base % Unwtd base Wales Total 6,719 58 5,958 50 Size 2-9 3,538 50 2,655 42 10-24 1,632 77 1,981 68 25-99 1,283 88 1,074 80 100+ 266 90 248 86 Sector Agriculture 214 30 101 27 Mining and Quarrying 20 ** 22 ** Manufacturing 1,031 52 467 55 Electricity, Gas and Water 13 ** 110 52 Construction 438 54 498 48 Wholesale and Retail 1,315 48 1,062 38 Hotels and Restaurants 415 49 666 39 Transport and Communications 522 52 435 48 Finance Services 215 75 173 55 Business Services 833 59 789 60 Public Administration 54 90 129 76 Education 418 88 391 80 Health and Social Work 626 87 571 77 Community, Social and Personal Services activities 605 58 544 54 Region North 1,511 58 1,420 52 Mid 675 52 788 40 South West 1,593 58 1,376 46 South East 2,940 59 2,374 54 Base: All establishments in Wales in comparable sample '**' denotes base <25: too small to report ## Appendix B: A Note On Proficiency And Skills Gaps To ascertain the number of staff with skills gaps, respondents were asked, for each major (one-digit SOC 201014) occupation where they employed staff, how many of those they employed were fully proficient. If respondents asked for clarification, then a proficient employee was described as 'someone who is able to do their job to the required level'. 'Proficient employee', however, is clearly a subjective and relative term to the extent that: - Different managers in an organisation may have different views on whether an individual member of staff is able to do the job to the required level. Indeed, they may have different views on what the required level is that the organisation is looking for within an occupational category. - An employee could be regarded as fully proficient but if the requirements of the job change (for example, some new machinery or technology is introduced) then they could be regarded as not being able to do their job to the required level, despite the fact that their skills were unchanged. - The same is true if a person were to be promoted to a more demanding position - the company might go from having no skills gaps to saying that this newly promoted member of staff was not fully proficient in the new job, despite having the same proficiency as before. - Different companies may be more demanding and 'critical' of their staff than others: an individual considered fully proficient by one company might be seen as having a skills gap if performing the same role to the same standard in another company. A final point to note is that the survey categorises staff as either fully proficient or not: it takes no account of the range that can clearly exist between those who are very nearly proficient and those who are significantly lacking. While from a policy perspective, there is interest in raising skills in the workforce at all levels, survey data can only identify changes year on year in the proportion of staff reported as fully proficient, not cases where skills levels have been raised but where staff still remain below full proficiency. ## Appendix C: Technical Appendix A full Technical Report accompanies the main UK Commission's Employer Skills Survey report and can be downloaded from the UKCES website (www.ukces.org.uk) or obtained by contacting UKCES directly. This appendix provides brief details on the key areas of sampling, fieldwork and analysis. The data reported in this document came from two surveys: - Wave 1: the main skills survey, covering business strategy, retention, recruitment, skills gaps and high performance working; - Wave 2, Investment in Training Survey: covering the financial investment establishments make in training their staff. ## Employer Skills Survey: Wave 1 Sampling All establishments excluding sole traders were eligible for the survey. Quotas were set on a size by sector within region basis, proportioned to give a robust base size in each subgroup of the overall sample. Sample was drawn from Experian's business database. ## Fieldwork A total of 6,012 interviews were completed in Wales, by telephone using computerassisted telephone interviewing (CATI) technology. Interviews were conducted with the most senior person at the site with responsibility for recruitment, human resources and workplace skills. Fieldwork for Wave 1 took place from March to July 2011. ## Response Rate The response rate for the survey in Wales was 55%, calculated as a proportion of all completed contacts. A detailed breakdown of survey outcomes is shown below: % of complete Outcome Number of contacts % of all sample contacts Total sample 30,428 100% Ineligible 3,895 13% 'Live' / not available during fieldwork / out of quota 13,100 43% Unobtainable number 2,447 8% Total complete contacts 10,986 36% 100% Achieved interviews 6,012 20% 55% Respondent refusal 3,267 11% 30% Quits during interview 871 3% 8% Company policy refusal 836 3% 8% ## Questionnaire Design The questionnaire design harmonised previous questionnaires used by the four nations of the UK in their own skills surveys. This included the National Employer Skills Survey series in England, the Scottish Employer Skills Surveys, the Northern Ireland Skills Monitoring Surveys and Future Skills Wales. A task and finish group chaired by the UK Commission and including IFF Research, and representatives from each of the four nations, was set up to drive this process. The group's aim was to develop a questionnaire that answered the Employer Skills Survey objectives, whilst maintaining time series data for each nation as far as was feasible in the framework of the ESS. The questionnaire is available on the UK Commission's website at: http://employersurveys.ukces.org.uk/ess/ess11/default.aspx. ## Weighting / Grossing Up Data for the survey was weighted and grossed up to population estimates of establishments and to the population of employees, as derived from the 2010 Inter- Departmental Business Register (IDBR). The UK Commission's Employer Skills Survey 2011 was weighted using interlocking grids of SSC by sizeband. Target weights were used to gross up the survey data to the population: - Population: 1+ employment (excluding sole traders) - Strategy: Size by 14 broad sectors (see Appendix D for definitions). - Separate weights were calculated for unit and employment measures. ## Employer Skills Survey: Investment In Training Follow-Up A separate Investment in Training study was conducted by IFF Research to provide detailed estimates of employer expenditure on training. ## Sampling At the end of the UKCESS Core questionnaire those respondents who had arranged or funded training for their staff in the previous 12 months were asked if they would be willing to take part in a follow up study on training expenditure. Those agreeing to participate formed the sample for this follow-up survey. Quotas were set on the basis of training type by size within region. ## Fieldwork Employers who had indicated agreement to take part were called by an IFF interviewer to confirm participation and contact details. They were then sent a datasheet via email or fax containing the questions that were to be asked in the full interview (a copy of which can be seen below). Sending this datasheet in advance allowed the respondent time to collect the relevant information and increase the accuracy of responses. A few days after sending, an interviewer called back to conduct the full interview. Overall information on training was collected from 1,501 respondents in Wales. Fieldwork was undertaken by IFF Research from 16th May to 29th July 2011. ## Weighting/Grossing Up In order to weight the Investment in Training study, population figures were calculated from weighted UKCESS Wave 1 data which had in turn been weighted using the IDBR figures used for the main survey analysis. Data was weighted on the basis of interlocking grids on size by sector by the type of training they carried out, with a regional rim weight. For further detail on cost calculations and data modelling for the Investment in Training study please see Appendix C of the UK Report. ## Appendix D: Industry Coding Each establishment was allocated to one of 14 sectors, based on their Standard Industrial Classification (SIC). SIC 2007 was used to classify establishments using the following method. Using the four-digit SIC supplied for each record from the Experian database, a description of business activity was read out to each respondent. If they agreed that this description matched the main activity undertaken at the establishment, then the SIC on Experian's database was assumed to be correct. If however the respondent felt the description did not correspond to their main business activity at the site, a verbatim response was collected to find out what they do (see question A7 on the survey; questionnaire available at www.ukces.org.uk). At the analysis stage this was coded to a four-digit SIC which was then used as the basis for allocation into sector. The table below shows the 14 sectors and their corresponding SIC 2007 definitions. Sector SIC 2007 A - Agriculture, forestry and fishing (01-03) 1. Agriculture Including farming, hunting and other related service activities, forestry and logging, fishing and aquaculture B - Mining and quarrying (05-09) 2. Mining & Quarrying Including mining of coal, metals, sand/stone/clay, and extraction of crude petroleum and natural gas C - Manufacturing (10-33) 3. Manufacturing Including manufacture of food and beverage, textiles, chemicals and chemical products, basic pharmaceutical products, other mineral products, manufacture of metals and metal products, machinery, computer and electronic products and equipment, motor vehicles and other transport equipment, furniture, and repair and installation of machinery and equipment 4. Electricity, Gas and Water D - Electricity, gas, steam and air conditioning supply (35) E - Water supply, sewerage, waste management and remediation activities (36-39) Including electric power generation, transmission and distribution, manufacture of gas and distribution of gaseous fuels, steam and air conditioning supply, water collection, treatment and supply, sewerage and waste collection, treatment and disposal activities and materials recovery F - Construction (41-43) 5. Construction Including the construction of buildings, civil Sector SIC 2007 engineering (constructing roads, railways and other utility projects), demolition, and specialised activities such as electrical installation, roofing and scaffold erection 6. Wholesale and Retail G - Wholesale and retail trade; repair of motor vehicles and motor cycles (45-47) Including sale, maintenance and repair of motor vehicles, parts and accessories, non-vehicle wholesale (for example agriculture, food, household goods), and the retail trade of all products whether in stores, stalls, markets, mail order or online 7. Hotels and Restaurants I - Accommodation and food service activities (55- 56) Including hotels, campsites, youth hostels, holiday centres, villages and other short stay accommodation, restaurants and takeaways, event catering and licensed clubs, pubs and bars 8. Transport and Communications H - Transport and storage (49-53) J - Information and communication (58-63) Including land, water and air transport (passenger and freight), warehousing and support activities for transportation, postal and courier activities, publishing (books, journals, newspapers etc and software/computer games), television, film and music production, broadcasting, telecommunications, computer programming and consultancy, information service activities (e.g. data processing and hosting) 9. Financial Services K - Financial and insurance activities (64-66) Including banks and building societies, activities of holding companies, trusts, funds and similar financial entities, credit granting, pensions, insurance and reinsurance L - Real estate activities (68) 10. Business services M - Professional, scientific and technical activities Sector SIC 2007 (69-75) N - Administrative and support service activities (77-82) Including the buying, selling and renting of real estate, legal activities, accounting, bookkeeping and auditing, management consultancy, architectural and engineering activities, scientific research and development, advertising and market research, specialist design, photographic activities, translation and interpretation, veterinary activities, renting and leasing of tangible goods (motors, household, machinery), employment agencies, travel agencies and tour operations, security and investigation activities, office administration and business support 11. Public Administration O - Public administration and defence; compulsory social security (84) Including administration of the State and economic and social policy of the community, provision of services to the community as a whole such as defence activities, foreign affairs, justice and judicial activities, fire service and compulsory social security activities P - Education (85) 12. Education Including pre-primary, primary, secondary and higher education, other education (such as sports, driving schools, cultural education), educational support activities Q - Human health and social work activities (86-88) 13. Health and Social work Including Hospitals, medical and dental practices, residential care, social work activities R - Arts, entertainment and recreation (90-93) 14. Other Community, Social and Personal Services S - Other service activities (94-96) Including performing arts, libraries and museums, gambling and betting, sports facilities, amusement and recreation activities, activities of membership organisations (religious, political, trade union, professional), personal services (hairdressing, beauty, textile cleaning, well-being activities, funeral activities) NOT COVERED IN SURVEY T - Activities of households as employers; undifferentiated goods and services producing activities of households for own use (97-98) Sector SIC 2007 U - Activities of extraterritorial organisations and bodies (99) Including households as employers of domestic personnel, private households producing goods for own use ## Appendix E: Occupational Coding The occupational data collected in the survey were collected both pre-coded and verbatim. The former included the occupational breakdown of employment (question D5 to D8) where respondents were asked how many of their workforce fell into each of the nine major (one-digit) Standard Occupation Classification (SOC) 2010 categories (Managers, Directors and Senior Officials through to Elementary Occupations). However, on vacancy measures (for example the occupations in which vacancies exist - question C2) this information was collected verbatim. This was then coded at the analysis stage, where possible to a four-digit level SOC, if not three, two- or one-digit level. Examples of what might fall into each occupational band are as follows: Occupational group Service sectors (retail, business, finance, transport etc) Primary sectors (Agriculture, manufacturing, construction etc) Managers, Directors and Senior Officials Site managers, Department Heads, Shift Managers (not supervisors) Directors, Managers / Branch/site managers, shift managers (not supervisors Professionals Professional engineers, software and IT professionals, accountants, chemists, scientific researchers Solicitors, lawyers, accountants, IT professionals, economists, architects, actuaries Associate Professionals Science and engineering technicians, lab technicians, IT technicians, accounting technicians Insurance underwriters, finance/investment analysts and advisers, writers/journalists, buyers, estate agents Secretaries, receptionists, PAs, telephonists, bookkeepers Administrative staff Secretaries, receptionists, PAs, communication operators, market research interviewers, clerks Skilled Trades Motor mechanics, printers, TV engineers, butchers Farmers, electricians, machine setters / tool makers, carpenters, plasterers Care assistants, nursery nurses Travel agents, travel assistants, hairdressers, housekeepers Caring, Leisure and Other Service Occupations Customer facing roles: sales staff and call centre agents Sales assistants and retail cashiers, telesales, call centre agents Sales and customer service occupations Public sector (Public Admin, Health, Education etc) Police inspectors and above, department heads, Head teachers, Senior Officials Doctors, nurses, midwives, teachers, social workers, librarians Junior police/fire/prison officers, therapists, paramedics, community workers, H&S officers, housing officers Secretaries, receptionists, PAs, local government officers and assistants, office assistants, library and database assistants Chefs Care assistants, home carers, nursery nurses, ambulance staff, pest control, dental nurses, caretakers Customer care operations HGV, van, fork-lift, bus and taxi drivers Drivers, vehicle inspectors Process, plant and machine operatives Routine operatives, drivers, machine operators, sorters and assemblers Labourers, packers, goods handling and storage staff Elementary occupations Bar staff, shelf fillers, catering assistants, waiters/waitresses, cleaners Labourers, cleaners, road sweepers, traffic wardens, security guards ## Appendix F: Sampling Error And Statistical Confidence Sampling error for the survey results overall and for different sub-groups by which analysis is presented in the report is shown in Table F.1. Figures have been based on a survey result of 50 per cent (the 'worst' case in terms of statistical reliability), and have used a 95 per cent confidence level. Where the table indicates that a survey result based on all respondents has a sampling error of +/- 0.32 per cent, this should be interpreted as follows: 'for a question asked of all respondents where the survey result is 50 per cent, we are 95 per cent confident that the true figure lies within the range 49.68 per cent to 50.32 per cent'. These confidence intervals are based on the assumption of a normal distribution of responses. Sampling error (at the confidence 95 per cent level) associated with findings of 50 per cent Number of (Maximum) interviews Sampling Error Wales total 6,012 +/-1.26 By size of establishment 1-4 1,216 +/-2.81 5-24 3,474 +/-1.66 25-99 1,074 +/-2.99 100-249 151 +/-7.98 250+ 97 +/-9.95 By sector Agriculture 102 +/-9.70 Mining & Quarrying 22 +/-20.89 Manufacturing 468 +/-4.53 Electricity, Gas and Water 111 +/-9.30 Construction 503 +/-4.37 Wholesale and Retail 1,069 +/-3.00 Hotels & Restaurants 675 +/-3.77 Transport and Communications 439 +/-4.68 Financial Services 173 +/-7.45 Business Services 791 +/-3.48 Public Administration 130 +/-8.60 Education 391 +/-4.96 Health and Social Work 580 +/-4.07 | Number of | |--------------------------------| | interviews | | | | Sampling Error | | | | Community, Social and Personal | | Services | | | | 558 | | | | +/-4.15 | | | | By region | | | | North Wales | | | | 1,431 | | | | +/-2.59 | | | | Mid Wales | | | | 798 | | | | +/-3.47 | | | | South West Wales | | | | 1,389 | | | | +/-2.63 | | | | South East Wales | | | | 2,394 | | | | +/-2.00 | | | | By ESF Region | | | | West Wales and the Valleys | | | | 3,732 | | | | +/-1.60 | | | | East Wales | | | | 2,276 | | | | +/-2.05 | | | Mining and Quarrying base size is below the reporting threshold ## Appendix G: Weighted Base Sizes Throughout this report figures have been reported next to their unweighted base sizes to demonstrate statistical reliability. For reference, the following table shows the weighted number of employers this represents for the key measures in the report. Weighted base Overall 98,950 Chapter 3: Work-readiness of those leaving education Taking on leavers from education in the last 2-3 years 23,664 16 year-olds from school 7,516 17-18 year-olds from school 8,180 17-18 year-olds from FE College 9,600 From university 10,304 Chapter 4: Employers, Recruitment and Skills shortages With a vacancy 11,320 With a hard-to-fill vacancy 4,260 With a skill-shortage vacancy 3,206 Chapter 5: Internal Skills Mismatch With at least one skills gap 12,963 Chapter 6: Employer Investment in Training and Skills Providing any training 58,172 On-the-job training only 15,005 Off-the-job training only 12,373 Both on- and off-the-job training 30,794 Providing no training for staff 40,778 Providing training towards nationally recognised qualifications 25,274 ## Appendix H: Unweighted Base Sizes This annex shows a reference table of the key unweighted base sizes used in this report. Note that throughout the report, figures are not reported where the base is under 25 and are highlighted in italics where the base is 25 to 49. | | | Establishments with… | |--------------|---------|--------------------------| | | Overall | Vacancies | | Hard-to-fill | | | | vacancies | | | | Skills gaps | | | | Estab's that | | | | train | | | | England | 6,012 | 1,100 | Size | 1-4 | 1,216 | 95 | 43 | 101 | 607 | |---------|----------|-------|-------|--------|--------| | 5-24 | 3,474 | 567 | 219 | 793 | 2,818 | | 25-99 | 1,074 | 304 | 90 | 359 | 1,013 | | 100-249 | 151 | 74 | 17 | 62 | 147 | | 250+ | 97 | 60 | 8 | 40 | 96 | Sector Agriculture 102 4 2 7 40 Mining and Quarrying 22 3 3 2 20 Manufacturing 468 85 31 115 355 Electricity, Gas and Water 111 16 8 20 82 Construction 503 39 19 75 336 Wholesale and Retail 1,069 187 46 303 785 Hotels and Restaurants 675 152 72 195 470 Transport and Communications 439 89 45 95 318 Financial Services 173 22 6 30 143 Business Services 791 138 51 164 656 Public Administration 130 25 4 24 121 Education 391 94 10 86 379 Health and Social Work 580 126 41 135 534 Community, Social and Personal Service activities 558 120 39 104 442 Region | North Wales | 1,431 | 246 | 92 | 332 | 1,133 | |------------------|----------|--------|-------|--------|----------| | Mid Wales | 798 | 153 | 59 | 171 | 559 | | South West Wales | 1,389 | 255 | 95 | 282 | 1,054 | | South East Wales | 2,394 | 446 | 131 | 570 | 1,935 | ESF Region | West Wales and the Valleys | 3,732 | 668 | 250 | 819 | 2,868 | |-------------------------------|----------|--------|--------|--------|----------| | East Wales | 2,276 | 432 | 127 | 536 | 1,811 | | | | Establishments with… | |------------------------------------|---------|--------------------------| | | Overall | Vacancies | | Hard-to-fill | | | | vacancies | | | | Skills gaps | | | | Estab's that | | | | train | | | | Occupation | | | | Managers | | | | 5,699 | 69 | 16 | | Professionals | | | | 1,162 | 179 | 59 | | Associate Professionals | | | | 773 | 150 | 44 | | Administrative/ Clerical staff | | | | 3,490 | 174 | 20 | | Skilled Trades occupations | | | | 1,550 | 164 | 85 | | Caring, Leisure and Other services | | | | 969 | 152 | 45 | | Sales and Customer services | | | | 1,618 | 164 | 36 | | Machine Operatives | | | | 950 | 86 | 45 | | Elementary staff | | | | 2,240 | 211 | 64 | ## Appendix I: Bibliography ACAS (2012) "ACAS Model Workplace," Advisory, Conciliation and Arbitration Service, London [available at www.acas.org/modelworkplace, accessed 13th November 2012] Bates, P., Cox, A., Robertson-Smith, G. (2009) High Performance Working: Developing a Survey Tool UKCES Evidence Report 5, UK Commission for Employment and Skills, Wath-upon-Dearne and London Davies, B., Gore, K., Shury, J., Vivian, D., Winterbotham, M. (2011) The UK Commission's Employer Skills Survey 2011: UK Results. UKCES Evidence Report 45, UK Commission for Employment and Skills, Wath-upon-Dearne and London Finegold, D. and Soskice, D. (1988). "The failure of training in Britain: analysis and prescription", *Oxford Review of Economic Policy*, Vol 4 No 3 Office for National Statistics (2010). Inter Departmental Business Register (March 2010), Newport. Office for National Statistics. Labour Force Survey, UK, October-December 1993 and 2010, Newport. Office for National Statistics (2012). "Statistical Bulletin: 2011 Annual Survey of Hours and Earnings (SOC 2000), Annual Survey of Hours and Earnings 2011 Provisional Results, Newport. Ofqual (2012) "Qualification levels: comparison of qualification levels between the NQF and QCF frameworks", Ofqual.gov.uk [available at http://www.ofqual.gov.uk/qualifications-and-assessments/qualificationframeworks/levels-of-qualifications/, accessed 13 November 2012] Shury J., Vivian, D., Davies, B., Gore, K. (2011) Employer Perspectives Survey 2010. UKCES Evidence Report 25, UK Commission for Employment and Skills, Wathupon-Dearne and London. SSDA (2006) "Smarter Ways of Working: the benefits of and barriers to adoption of high performance working", *SSDA Catalyst*, SSDA: Wath-upon-Dearne. [Available at http://www.ukces.org.uk/assets/ukces/docs/publications/ssda-archive/ssdacatalyst-issue-3-smarter-ways-of-working.pdf, accessed 15 November 2012] Sung, J. and Ashton, D. (2005) High Performance Work Practices: linking strategy and skills to performance outcomes, Department of Trade and Industry, London UKCES (2009a) *Ambition 2020: World class skills and jobs for the UK.* UK Commission for Employment and Skills, Wath-upon-Dearne and London UKCES (2009b) *High Performance Working: A Synthesis of Key Literature.* UKCES Evidence Report 4, UK Commission for Employment and Skills, Wath-upon-Dearne and London.UKCES (2010a) *The Value of Skills: An Evidence Review*. UKCES Evidence Report 22, UK Commission for Employment and Skills, Wath-upon- Dearne and London. UKCES (2010b) *High Performance Working: A Policy Review.* UKCES Evidence Report 18, UK Commission for Employment and Skills, Wath-upon-Dearne and London. UKCES (2011) Employer ownership of skills: securing a sustainable partnership for the long term. UK Commission for Employment and Skills, Wath-upon-Dearne and London. UKCES (2012) *Working Futures 2010-20: Report for Wales,* UK Commission for Employment and Skills, Wath-upon-Dearne and London ## Wales Employment And Skills Board (2011) *High Performance Working*, Young, V., and Morrell, J. (2006) Future Skills Wales 2005: Sector Skills Survey Main Report. Future Skills Wales, Caerphilly. List of previous publications Executive summaries and full versions of all these reports are available from www.ukces.org.uk ## Evidence Report 1 Skills For The Workplace: Employer Perspectives Evidence Report 2 Working Futures 2007-2017 Evidence Report 3 Employee Demand for Skills: A Review of Evidence & Policy Evidence Report 4 High Performance Working: A Synthesis of Key Literature Evidence Report 5 High Performance Working: Developing a Survey Tool Evidence Report 6 Review of Employer Collective Measures: A Conceptual Review from a Public Policy Perspective Evidence Report 7 Review of Employer Collective Measures: Empirical Review Evidence Report 8 Review of Employer Collective Measures: Policy Review Evidence Report 9 Review of Employer Collective Measures: Policy Prioritisation Evidence Report 10 Review of Employer Collective Measures: Final Report Evidence Report 11 The Economic Value of Intermediate Vocational Education and Qualifications Evidence Report 12 UK Employment and Skills Almanac 2009 Evidence Report 13 National Employer Skills Survey 2009: Key Findings Evidence Report 14 Strategic Skills Needs in the Biomedical Sector: A Report for the National Strategic Skills Audit for England, 2010 Evidence Report 15 Strategic Skills Needs in the Financial Services Sector: A Report for the National Strategic Skills Audit for England, 2010 ## Evidence Report 16 Strategic Skills Needs In The Low Carbon Energy Generation Sector: A Report For The National Strategic Skills Audit For England, 2010 Evidence Report 17 Horizon Scanning and Scenario Building: Scenarios for Skills 2020 Evidence Report 18 High Performance Working: A Policy Review Evidence Report 19 High Performance Working: Employer Case Studies Evidence Report 20 A Theoretical Review of Skill Shortages and Skill Needs Evidence Report 21 High Performance Working: Case Studies Analytical Report Evidence Report 22 The Value of Skills: An Evidence Review Evidence Report 23 National Employer Skills Survey for England 2009: Main Report Evidence Report 24 Perspectives and Performance of Investors in People: A Literature Review Evidence Report 25 UK Employer Perspectives Survey 2010 Evidence Report 26 UK Employment and Skills Almanac 2010 Evidence Report 27 Exploring Employer Behaviour in relation to Investors in People Evidence Report 28 Investors in People - Research on the New Choices Approach Evidence Report 29 Defining and Measuring Training Activity Evidence Report 30 Product strategies, skills shortages and skill updating needs in England: New evidence from the National Employer Skills Survey, 2009 Evidence Report 31 Skills for Self-employment Evidence Report 32 The impact of student and migrant employment on opportunities for low skilled people Evidence Report 33 Rebalancing the Economy Sectorally and Spatially: An Evidence Review Evidence Report 34 Maximising Employment and Skills in the Offshore Wind Supply Chain Evidence Report 35 The Role of Career Adaptability in Skills Supply Evidence Report 36 The Impact of Higher Education for Part-Time Students Evidence Report 37 International approaches to high performance working Evidence Report 38 The Role of Skills from Worklessness to Sustainable Employment with Progression Evidence Report 39 Skills and Economic Performance: The Impact of Intangible Assets on UK Productivity Growth Evidence Report 40 A Review of Occupational Regulation and its Impact Evidence Report 41 Working Futures 2010-2020 Evidence Report 42 International Approaches to the Development of Intermediate Level Skills and Apprenticeships Evidence Report 43 Engaging low skilled employees in workplace learning Evidence Report 44 Developing Occupational Skills Profiles for the UK Evidence Report 45 UK Commission's Employer Skills Survey 2011: UK Results Evidence Report 46 UK Commission's Employer Skills Survey 2011: England Results Evidence Report 47 Understanding Training Levies Evidence Report 48 Sector Skills Insights: Advanced Manufacturing Evidence Report 49 Sector Skills Insights: Digital and Creative Evidence Report 50 Sector Skills Insights: Construction Evidence Report 51 Sector Skills Insights: Energy Evidence Report 52 Sector Skills Insights: Health and Social Care Evidence Report 53 Sector Skills Insights: Retail Evidence Report 54 Research to support the evaluation of Investors in People: Employer Survey Evidence Report 55 Sector Skills Insights: Tourism Evidence Report 56 Sector Skills Insights: Professional and Business Services Evidence Report 57 Sector Skills Insights: Education Evidence Report 58 Evaluation of Investors in People: Employer Case Studies Evidence Report 59 An Initial Formative Evaluation of Best Market Solutions Evidence Report 60 UK Commission's Employer Skills Survey 2011: Northern Ireland National Report Evidence Report 61 UK Skill levels and international competitiveness Evidence Report 62 UK Commission's Employer Skills Survey 2011: Wales Results Evidence Reports present detailed findings of the research produced by the UK Commission for Employment and Skills. The reports contribute to the accumulation of knowledge and intelligence on skills and employment issues through the review of existing evidence or through primary research. All of the outputs of the UK Commission can be accessed on our website at www.ukces.org.uk UKCES Sanctuary Buildings Great Smith St. Westminster London SW1P 3BT T +44 (0)20 7227 7800 UKCES Renaissance House Adwick Park Wath-upon-Dearne Rotherham S63 5NB T +44 (0)1709 774 800 F +44 (0)1709 774 801 This document is available at www.ukces.org.uk under "Publications" ISBN 978-1-908418-01-2 © UKCES 1st Ed/11.12
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## Why Did People Go To War In 1642? Case study 1: 1637-39 - Source 4 An announcement from Charles to the people of Scotland, May 1639 (Catalogue ref: SP 45/10/225) ## What Is This Source? This is an extract from a proclamation (announcement or order) made by Charles at Newcastle on 14 May 1639 telling people in Scotland what he wanted them to do. He was trying to end rebellion in Scotland. Charles was king of England and Scotland. He wanted the English and the Scots to obey the same laws and he wanted the English and Scottish churches to be run the same way. ## What'S The Background To This Source? Charles had been facing rebellion from his subjects in Scotland since 1637. The Scots refused to accept changes that Charles wanted to make to the church in Scotland. • Throughout the 1630s Charles and his Archbishop of Canterbury, William Laud, brought changes to the organisation of the church and also to the way people worshipped in church. Charles and Laud wanted to make the clergy, especially bishops, more important and powerful. Many Protestants in England and Scotland disliked these changes. • In 1637 Charles and Laud tried to force the Scots to accept a new prayer book. The Scots refused. (Religion was a very important issue to everyone in Scotland and England.) • In February 1638 the Scottish rebels formed themselves into a National Assembly. They signed a Covenant (agreement) banning the new prayer book. • The Covenanters (rebels who supported the Covenant) then went on to get rid of other changes brought in by Laud. In November they abolished bishops altogether. • Charles would not put up with this challenge to his authority. In November 1638 Charles raised an army and tried to crush the Scots, but he failed. ## It'S Worth Knowing That … Charles raised an army to fight the Scots in 1638. By May 1639, when this proclamation was made, Charles did not have enough money to continue the fight. This meant he had to try and reach an agreement with the Scottish rebels. Although Charles threatened to invade Scotland, he did not have a good enough army to do this. He did not have enough money for a large, well-equipped army. To get the money he needed, he would have to ask his Parliament. However, Charles did not like working with Parliament. He ruled without it from 1629-40. By the time he did call Parliament in 1640, many MPs were anxious to tell the king why they were unhappy about many aspects of his rule. Plus his conflict with the Scots dragged on until October 1640. ## Your Turn: What Can We Learn From This Source? 1. What did the king offer the Scots? 2. What did the Scots have to promise in return? 3. How would you describe Charles's attitude towards the Scots? 4. Does this source give us any clues about why the kingdom went to war in 1642? 5. Study the notes that support this source. 6. What problems caused the rebellion in Scotland? 7. What other problems did the Scottish rebellion cause for Charles? Source 4
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Science and research budget allocations for financial year 15/16 World class research plays a key role in economic growth and the continued improvement to health and wellbeing of society. At a time of tight control over public spending, the Government continues to offer strong support for science and research. We continue to protect the science ring fence in cash terms for financial year 15/16. In addition the Chancellor has previously announced a long term commitment to investment in science infrastructure of £1.1Bn in real terms to 2021 and increased investment for science with funding for Quantum Technologies and collaboration with emerging powers. This brings the overall investment in science and research to £5.8Bn1 in 15/16 ‐ an increase in overall spending compared to recent years. The below table shows the 15/16 resource and capital budget allocations from the ring fenced budget for science and research. We will be publishing further details of these allocations shortly. ## Financial Year 15/16 Allocation To Ringfenced Science And Research Funding Organisations Organisation 15/16  Rdel Allocation (£M) 15/16 CDEL allocation (£M)  AHRC  98.3  0  BBSRC  351.2  71  ESRC  153.2  25  EPSRC  778.5  80  MRC  580.3  36 35*  NERC (core programme)  260  NERC (Antarctic logistics and infrastructure)  29  STFC (core programme)  165.1  53.3  STFC (international subscriptions)  127.5    27.3  STFC (large facilities)  107.4  48.5  HEFCE QR  1573.3  N/A  Contribution towards HEIF  113  N/A  Research Capital England  117.3  N/A  HEI research capital (England)  86.2  University research  capital    HEI Research Capital (Scotland)  16.1  HEI Research Capital (Wales)  3.7  HEI Research Capital (NI)  1.7  RPIF (UK)  100  1 Cash terms. | Organisation  | 15/16  RDEL allocation  | |--------------------------------------------------|---------------------------| | (£M) | | | 15/16 CDEL | | | allocation (£M) | | | UK Space Agency | 170.2 | | Royal Society | 47.1 | | British Academy | 27 | | Academy of Engineering | 12.4 | | Academy of  Medical Sciences | 0.47 | | International programme and Emerging Powers Fund | 79.2 | | Science & Society programme | 13 | | Government Office for Science | 2.8 | | Evidence and evaluation | 2.1 | | TOTAL ringfence science spend | 4691 | | Science capital spending for bodies outside the | | | Ringfence for current spending | | | N/A | | | 251 | | | TOTAL UK science spend | 4691 | *Includes capital funding for (NERC) Antarctic Logistics and Infrastructure which will be partitioned in due course. Notes:   Figures include science funding announced in Autumn Statement 2013.   For the first time we are funding the Academy of Medical Sciences. This does not reduce funding  to other Academies.    In addition to the capital allocated to ring fenced science and research funding bodies to maintain  existing programmes a number of specific capital investments have been previously announced at  recent fiscal events. These include a new super computer for the MET office, the NMO's  Advanced Metrology Lab, investment in medical research facilities by Dept of Health and  managed by MRC (MRC Clinical Research Infrastructure Initiative) and maintenance and  development of the Atomic Energy Authority's portfolio. This brings the science capital budget to  £1.1Bn in 15/16.   The funding for HEIF is the research contribution to the HEIF budget. HEFCE can decide to add  additional funding from teaching budgets.    The allocation for RPIF is the first year of a two year RPIF settlement.  © Crown copyright 2014 You may re-use this information (not including logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit www.nationalarchives.gov.uk/doc/open- government-licence/ This publication is also available on our website at www.gov.uk/bis BIS/14/P200
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Front cover with Department for Business, Innovation and Skills logoFront cover with Department for Business, Innovation and Skills logo ## Market Assessment Of Public Sector Information Written by Deloitte MAY 2013 A report by Deloitte for the Department for Business, Innovation and Skills Deloitte Stonecutter Court 1 Stonecutter Street London EC4A 4TR Web: UUwww.deloitte.co.uk The views expressed in this report are the authors' and do not necessarily reflect those of the Department for Business, Innovation and Skills. Department for Business, Innovation and Skills 1 Victoria Street London SW1H 0ET www.gov.uk/bis URN BIS/13/743 May 2013 ## Contents Acknowledgements ........................................................................................................................ 9  Executive Summary...................................................................................................................... 10  Key findings................................................................................................................................. 10 Policy context.............................................................................................................................. 12 Defining public sector information and the market...................................................................... 13  Public sector information dimensions...................................................................................... 13 Public sector information holders and customers ................................................................... 14  The value of public sector information today............................................................................... 16  The link between public sector information and growth .......................................................... 16 Generating value from public sector information..................................................................... 16 Value from different public sector information datasets .......................................................... 17 Understanding how public sector information creates value in the UK................................... 19 Estimates of the value of public sector information and value to PSIHs................................. 21  Barriers to realising the full potential of public sector information in the UK ............................... 24  A taxonomy of barriers............................................................................................................ 24  Legislative barriers.................................................................................................................. 25  Economic barriers ................................................................................................................... 27 Access barriers ....................................................................................................................... 32  Summary of key research questions answered .......................................................................... 35  1.  Introduction and approach................................................................................................... 42  Project scope and objectives ...................................................................................................... 42 Approach..................................................................................................................................... 43 Data sources............................................................................................................................... 43  ## Acknowledgements This report has been produced by Deloitte between October 2012 and March 2013. The lead authors are Andrew Tong, Haris Irshad and Daniel Revell Ward. The Deloitte team acknowledges the support of Stephan Shakespeare and the Data Strategy Board, the Cabinet Office, the Open Data Institute, other public sector bodies and the wider open data community who have contributed their time, data and comments to this report. In particular, the team would like to express its thanks to the different start-up companies and established companies who have contributed to the case study analyses. ## Executive Summary Key Findings This is the first UK-wide market assessment of public sector information1. It spans the use and reuse of public sector information at the UK-level, regionally and locally by a wide range of businesses, civil society groups, government and members of the general public. The aim of this market assessment is to establish a robust evidence base on its value and to highlight the policy implications flowing from an examination of how public sector information could be utilised further. The research has covered three broad thematic areas:  definitions of public sector information and its characteristics;  how public sector information is used and re-used inside and outside of government; and  barriers to fully exploiting the value of public sector information, including issues around competitiveness, funding and regulation. The research has used a combination of literature reviews, analysis of secondary sources, stakeholder interviews and case studies. The key research findings are summarised below. Key research findings  This report has estimated that the value of public sector information to consumers, businesses and the public sector in 2011/12 was approximately **£1.8 billion** (2011 prices). o This is a mid-point estimate, with the sensitivity analyses giving a range between £1.2 billion and £2.2 billion  However, the use and re-use of public sector information has much larger downstream impacts affecting all areas of society beyond the direct customer.  The **UK is a global leader in releasing public sector information** for use by its citizens, businesses and policymakers. Through initiatives such as the data.gov.uk, the Open Data User Group, Departmental Data Strategies, as well as the establishment of the Data Strategy Board and Open Data Institute, the UK has taken significant steps to creating a worldclass public data infrastructure. o While there is no central figure on the number of public sector information datasets currently being made available, a review of selected data portals suggests the number could exceed 37,500 from over 750 different publishers with over 2.5 million downloads by October 2012  There is a link between the provision and use/re-use of public sector information and economic growth. Public sector information is used by businesses, individuals and the public sector to: o stimulate **innovation** and **develop new products and services**; o hold public service providers to account, **promote democratic engagement** and foster greater transparency and **better policymaking**; o reduce barriers to entry into markets and **address information asymmetries**; and o generate network effects that drive disruptive change by connecting increasing numbers of consumers and businesses  The most popular, and potentially most valuable, datasets include geo-spatial, environmental, transport, health and **economic data**, with the construction, real estate, finance and insurance, public sector and arts, entertainment and recreation sectors being some of the largest users and re-users of public sector information and open data.  Case studies examining the downstream impacts created by different organisations using and re-using public sector information have shown the monetary value of some of these benefits can be in the order of millions, if not billions. For example: o publishing data on adult cardiac surgery is estimated to have reduced mortality rates, which in turn has an **economic value in excess of £400 million p.a**. o using live data from Transport for London in apps can save users time to the economic **value of between £15 million and £58 million p.a.**  While an aggregate figure on the social value of public sector information is difficult to reach without more information on the way data is used and how it then permeates society, on the basis of conservative assumptions, it is estimated this figure could be in excess of £5 billion for 2011/12 (2011 prices). o This estimate is likely to increase as public sector information is used more widely and in more impactful ways.  Adding this social value estimate to the calculated value of public sector information to consumers, businesses and the public sector, gives an aggregate estimate of between £6.2 billion and £7.2 billion in 2011/12 (2011 prices). Future uses of public sector information that have the potential to generate much more value include greater combining of public and private sector information, exploiting the benefits of **linked data**, embedding geospatial and **location data across more and more products and services**, and **more informed policymaking based on better utilised public sector information**.  Using a taxonomy originally developed by the Data Strategy Board, this report has considered a number of **barriers** that may be preventing the UK from fully realising the benefits of public sector information: o **Legislative barriers**: while current legislation, guidance and regulations are not hindering the public sector information market themselves, there is often a perception (right or wrong) that some legislation, guidance and regulations prevent datasets from being released and shared thereby reducing the availability of datasets. The Open Government Licence is widely seen as an effective means of improving the availability of public sector information; o **Economic barriers**: the issue of charging for public sector information datasets is complex, with a lack of data from both providers and users/re-users making it hard to conduct cost-benefit analyses on data release. While significant progress has been made in making more datasets available, there remains a perception (actual and perceived) that charging creates barriers to using and re-using public sector information. In the short-term there are a number of opportunities for improving the availability of certain datasets; and o **Access barriers**: improvements continue to be made to reduce fragmentation and improve the consistency of public sector information; however there remains scope for improvements in the accessibility of public sector information datasets to the general public. Equally, in some parts of the private and public sector, there is a skills shortage preventing the effective extraction of value from public sector information. ## Policy Context As highlighted by Rt. Hon. Francis Maude MP in his foreword to the Open Data White Paper (June 2012), data is the twenty-first century's raw material: "its value is in holding governments to account; in driving choice and improvements in public services; and in inspiring innovation and enterprise that spurs social and economic growth"2. Beginning with transparency statements originally set in the Coalition Agreement3, the UK has continued to push forward with the release of more public sector information, much of which meets the criteria of being 'open data'.4 Recent developments include (these are not exhaustive):  the establishment of the **Data Strategy Board** (DSB5) and the **Open Data User Group**6 (ODUG) to create the maximum value for businesses and people across the UK from data held by the **Public Data Group**7 (PDG) members and beyond;  the establishment of the **Transparency Board**8 to drive forward the Government's transparency agenda, set open data standards across the whole public sector and facilitate the release of more public sector information;  the creation of the **Open Data Institute** (ODI), an independent, non-profit company funded by the Government and the private sector to incubate, nurture and mentor new ideas using open data (and the first organisation of its kind in the world);  the publication of new **Open Standards Principles**9 for all government bodies to comply with making IT more open, cheaper and better connected;  discussions at a European level on the revision of the **Public Sector Information Directive** and reforms to data protection rules;  the publication of **departmental open data commitments** in their business plans;  the on-going implementation of the Government's **Transparency and Open Data** agenda led by **Cabinet Office**. This includes the publication of updates on the Government Digital Strategy10 providing details on how services are being moved online to achieve efficiencies and how Cabinet Office is supporting improved digital capabilities across departments;  the completion of a competition awarding investment to Glasgow to demonstrate how a city of the future could work by hosting the Technology Strategy Board's Future City Demonstrator11; and  specific policy announcements such as: o the **Open Data Immersion Programme**12 to accelerate innovative open data ideas and develop market-ready businesses; o the expansion of the Technology Strategy Board's **Innovation Voucher** programme available to SMEs to use open data to help commercialise their ideas and develop new products and prototypes; and o other funding for a DSB **Breakthrough Fund** and upgrades to Ordnance Survey OpenData products13. Together these developments are helping place the UK at the forefront of public sector information and open data initiatives globally. Research by Deloitte suggests that the UK has the most page views of any open data portal in the world14. However, while the UK holds a number of strengths in the availability, analysis and value extraction of public sector information, there are challenges in fully exploiting the potential value from public sector information. There are logistical challenges around what data should be made available, when, in which format and the choice of funding model to use. There also exist challenges around ensuring businesses, civil society and the public sector itself are able to effectively use and re-use public sector information so as to fully exploit its value. The Government has recognised that these challenges may be becoming barriers and on 22 October 2012 launched the **Shakespeare Review** led by Stephan Shakespeare, Chair of the Data Strategy Board. This review covers the entire breadth of the public sector information market (current and future) in order to make recommendations to Ministers on how to widen access to public sector information and consider new and innovative opportunities for open data.15 As part of the Shakespeare Review, **Deloitte** has been commissioned by the Department of Business, Innovation and Skills (BIS) on behalf of Stephan Shakespeare, to undertake an independent assessment of the market for public sector information, in order to establish a robust evidence base on its value and to highlight the policy implications flowing from an examination of how public sector information could be utilised further. Defining public sector information and the market ## Public Sector Information Dimensions Broadly speaking the term 'public sector information' refers to **data**16 and **information**17 that the public sector collects, produces, reproduces, publishes and disseminates in many areas of activity while accomplishing their public task or other duties18. In some limited cases for particular public sector information datasets19, there will also be private sector suppliers of data and information that can be considered substitutes for public sector information. ## Figure 1: Public Sector Information Dimensions Public sector information datasets differ across a number of dimensions:  whether the public sector information is made available to the general public and, if so, under what conditions (if any);  the complexity of the dataset in terms of the number of records and variables, whether it is anonymised or aggregated or is quantitative or qualitative;  how often the dataset is updated or replaced;  whether public sector information is generated or collected as part of an public body's public task or whether its generation is the result of other activities not related to public sector information;  the content of the public sector information dataset;  the electronic or non-electronic format of the dataset;  the ways in which the public sector information dataset is distributed; and  the cost of generating/collecting/maintaining/updating the public sector information dataset. Source: Deloitte analysis ## Public Sector Information Holders And Customers Public sector bodies that generate, collect and disseminate public sector information (hereafter referred to as Public Sector Information Holders or 'PSIHs') will themselves differ in size, role and purpose and the extent to which, and how, they make the information and data available. Figure 2 below summarises. ## Figure 2: Public Sector Information Holders And Routes To Market As Figure 2 illustrates, public sector information is generated by a plethora of different PSIHs. It can be **generated specifically** (e.g. the Met Office collecting weather data), as a by-product of other activities (e.g. salary data - so called **exhaust data** that is generated through the performance of regular activities that are not data collection specific) or combined with third party data (e.g. financial data analysed and combined with other statistics by the Bank of England that is then used to inform economic forecasts). While data on the total number of public sector information datasets is not recorded, a review of selected data portals reveals there to be over 37,500 datasets currently being made available as open data by PSIHs (this is likely to be an underestimate given a wealth of public sector information is also available through other routes). Focusing on data.gov.uk, analysis shows that the Office for National Statistics, Department for Communities and Local Government and the Health and Social Care Information Centre - with the analysis showing that of a total of 781 different publishers (as of 27th February 2013), the top ten suppliers of public sector information supplied over half of all datasets published on the website. On the demand side of the market, customers come from the private sector, civil society, individuals and government itself. Some customers will use the data as direct inputs into products, services and research, while others will be repackaging the data for others to use - so-called infomediaries. The market for public sector information can therefore be summarised as shown in Figure 3 below. ## Figure 3: Public Sector Information Market Source: Deloitte analysis As Figure 3 shows, on the supply side, PSIHs consist of the public sector and private business - though in practice the overwhelming majority will be supplied by the public sector. Intermediaries take this information and data and host and repackage it for a wider audience - in some cases this means augmenting the public sector information with other data elements. On the demand side, final consumers (which can include PSIHs themselves) can use and re-use the public sector information to develop new products, inform decision-making, improve research and make efficiency savings. As public sector information is increasingly used and re-used, actors across the supply, intermediary and demand sides will improve their data analysis skills, which can raise competitiveness and drive economic growth. ## The Value Of Public Sector Information Today The Link Between Public Sector Information And Growth The economic importance of public sector information has increased radically with the spread of new communication technologies, most notably the Internet, and the development of a 'knowledge economy' in which value is generated through innovation in information and services. There is now a considerable body of academic and other literature supporting the view that the greater availability and **accessibility**21 of public sector information can boost innovation and facilitate economic growth. Vickery (2011) and others have concluded that "knowledge is a source of competitive advantage in the 'information economy', and for this reason alone it is economically important that public information is widely diffused"22. ## Generating Value From Public Sector Information Following a review of the evidence it is apparent that the two main ways in which value is being generated currently, which will likely remain the case in the future, is through **data discovery** and data exploitation. The former relates to making better and, in some cases more, public sector information available and making it more accessible - what might be loosely term **supply-side** considerations. The second dimension relates to using and re-using public sector information better - **demand-side** considerations. This might be through reducing consumer risk aversion to using public sector information, improving data exploitation techniques, changing cultures and improving data analysis skills (which, in turn can improve competiveness). Source: Deloitte analysis. Boxes not to scale. Value is thus generated through exploiting existing datasets to identify insights through statistical analysis, 'data-mashing' and visualisations. The value of public sector information in the UK can therefore be increased both by increasing the quality (and quantity) of public sector information (increasing the potential for data discovery) or by better using existing and new datasets. While, in some cases, more public sector information being available can also increase value, there is not a linear relationship between quantity of public sector information and its value. What is key is the quality of this data and its amenability to data analytics. Simply releasing more datasets, irrespective of their quality, is likely to only have a minimal value impact. ## Value From Different Public Sector Information Datasets Clearly the value of public sector information will vary according to the identity of the final beneficiary, the dataset in question and how and when the information is being exploited. Figure 5 highlights how different public sector information datasets can generate different levels of value. ## Figure 5: Value Of Different Public Sector Information Datasets It should be noted that in and of themselves, public sector information datasets do not carry any intrinsic value. Value is a function of customers being able to use the datasets to generate revenue and jobs, assist in decision making, and promote transparency and accountability - these impacts are discussed in the following sections. The evidence points to the value of any given public sector information dataset to society as being positively correlated with:  the content of the dataset - there are certain content themes that have well-established uses and re-uses or may be fundamental to the provision of services, products and types of research. Where this is the case, certain content themes (e.g. geo-spatial data or transport data) will positively influence the value of the public sector information dataset to society;  the flexibility of the dataset - where datasets can be used in multiple ways to generate insights (e.g. house price data that can be used as proxies for a range of factors such as environmental conditions or school performance), the relative value of the dataset to society may be higher than a single-use dataset;  the accuracy, comprehensiveness and speed of refresh of the dataset - as one would expect, the value of public sector information dataset will increase with its accuracy, comprehensiveness and speed of which it is updated (e.g. economic statistics); and  the ability to link the data - the easier it is to link a given dataset with other datasets and other forms of information will increase its flexibility and comprehensiveness, and again can increase its value to society. Of course, it should be noted that the value of a given public sector information dataset to society will vary over time, with some datasets becoming more or less valuable as new uses are discovered or rival datasets used - and accordingly predicting the future value of any given dataset is difficult. Building on existing analyses, it is possible to create a data intensity matrix to compare how different types of datasets are used by different economic sectors in the UK currently (see Chapter 3 of the main report). The analysis shows that the construction, real estate, financial and insurance, public sector and arts, entertainment and recreation sectors are some of the largest users and re-users of open data23. Dataset types most commonly being used include demographics, economic, environmental and geo-spatial and housing data. From an analysis of data.gov.uk dataset requests, the most popular dataset category requested is location (or geospatial) data. This reinforces the impression that this category of data generates some of the highest levels of value. Environment, transportation, health and society are also data that attract particularly high levels of requests. Requests for data used to scrutinise and hold government accountable, such as government, finance, policy, administration and spending data are significantly lower, suggesting that this attracts less interest. However, even in these categories the numbers of requests are not insignificant, and the threat of accountability arising from the data, rather than the specific use of the data may be the primary driver of value. Source: Deloitte analysis Nonetheless, at a broad level, from the literature surveyed for this evidence review, it is clear that the release of public sector information has the potential to generate significant economic value through stimulating innovation, **addressing market failures** (such as barriers to entry and information asymmetries), **facilitating new ways of working** and creating network effects arising from more and more users of public sector information generating new insights and crossfertilisation of ideas, helping with the creation of **new markets**. Conceptually, one can see how public sector information can drive economic growth and wider prosperity in the form of happiness and sustainability. The simplified framework, shown below in Figure 6, illustrates the long-term drivers of the UK's **economic growth** and **prosperity**. Measurable outputs (such as Gross Value Added24, employment and productivity) as well as less easily measured outcomes (such as happiness and sustainability) are determined by two key drivers in the form of **productivity** and **employment levels**. In other words, in the long-term and considering the supply side of the economy only, the economic output of the UK is a function of only two things: the number of people engaged in gainful employment and the amount each person in employment is capable of producing. In turn, these two key drivers of economic growth and prosperity are determined by seven necessary enablers. These are related to the infrastructure required to facilitate long-term growth: a deficit in these enablers will equate to a supply-side constraint on economic growth in the longrun. This could be caused either by limiting the growth in the working population (through insufficient affordable housing capacity limiting labour mobility) or by acting as a drag on productivity growth (through below-par ICT connectivity or a sclerotic transport system). The amount each worker produces is determined by skill levels; the extent of innovation in products and processes; the degree of investment in capital; entrepreneurial activity; and, lastly, levels of competition. Expanding and enhancing these enablers can therefore positively impact employment and productivity, which in turn can generate economic growth and greater prosperity. Source: Deloitte analysis based on HMT and BIS analysis. See www.hm-treasury.gov.uk/d/ACF1FBD.pdf for more details. As is shown in Figure 6, the introduction of more public sector information can have a positive impact on infrastructure and other enablers. For example, it can stimulate innovation, help enhance skills, promote competition and enterprise and attract investment to new products and services. In terms of infrastructure, public sector information can help generate efficiency savings across public services and improve business decision-making. ## Understanding How Public Sector Information Creates Value In The Uk Having reviewed the literature, it is useful to disaggregate the different types of value generated by public sector information according to the beneficiary:  the direct value of public sector information to producers and suppliers (the PSIHs): these are the benefits accruing to producers and suppliers of public sector information through the sale of public sector information or related value-added services;  the indirect value of public sector information arising from its production and supply: the benefits accruing up the supply chain to those organisations interacting with and supplying PSIHs (but not directly using or re-using public sector information), and the benefits accruing to those organisations where employees of PSIHs and supply chain organisations spend their wages;  the direct use value of public sector information to consumers of public sector information: the benefits accruing to businesses, civil society, individuals and the public sector from directly using and re-using public sector information for a variety of purposes; and  the wider societal value arising from the use and re-use of public sector information: the benefits to society of public sector information being exploited, which are not readily captured elsewhere. Using the above disaggregation, Figure 7 overleaf shows how value can be created across the public sector information market, from the perspective of different participants along the supply chain. Three (hypothetical) broad examples are shown:  a **policy efficiency example** where value is generated by the re-use of health data;  an **app developer example** where value is generated by the use of data as a key input into transport apps that seek to save time; and  a **data analytics example** where value is generated by the use and re-use of data to generate customer and business insights. Value is generated across each element of the supply chain. PSIHs who produce and disseminate the public sector information can create value through employing staff to collect and organise the public sector information. If they also sell public sector information or value-added products, value will be created through the revenue attributable to public sector information. Or, if the PSI is made available for free under the Open Government License (OGL) this has the potential to maximise its use by third parties to generate added-value in the supply chain (see downstream impact). Upstream along the supply chain, value will be created as a variety of third party organisations doing business with PSIHs (such as IT suppliers, operations and maintenance firms, caterers, recruitment agencies, etc.) will receive orders from the PSIHs and earn revenue. Similarly, businesses such as retailers where employees from PSIHs and other organisations in the supply chain spend their wages will also earn revenue and generate jobs. Downstream along the supply chain, value is created by consumers of public sector information directly and indirectly using the information and data. In the policy efficiency example, this is through using the public sector information to identify efficiency savings; in the app developer case value is created through the sales of the app and the direct financial benefits to users in the form of time saved; and in the data analytics example, value comes from efficiency savings and better targeted products for consumers - raising revenue. Source: Deloitte analysis. In the Figure 7, the term Gross Value Added (GVA) is used to capture economic value (from profits, wages and rents). Even for these three archetypal examples, the wider societal value from public sector information is more challenging to measure as it captures wider benefits arising from the use and re-use of public sector information that are typically not measured in monetary terms. The literature discusses a number of ways in which public sector information can have broader value impacts through:  increasing democratic participation: giving citizens and businesses access to public sector information allows them to perform their own analyses of salient issues, make more informed choices about public service providers and interact with policymakers to challenge their assumptions and improve the policymaking process;  promoting greater accountability: for example through the scrutiny of costs of public service provision and benchmarking comparable services;  greater social cohesion: for example, by providing more information on the provision and distribution of services, public sector information can be used to dispel myths on who receives certain public services;  generating environmental benefits: such as reducing congestion and pollution through the release of better traffic and transport data which helps drivers to better plan journeys; and  identifying previously unknown links between different policy areas: through data-mash ups it may be possible to develop system-wide solutions that holistically seek to address the root of policy challenges. This value is potentially significant and is likely to have a major influence on overall societal wellbeing. ## Estimates Of The Value Of Public Sector Information And Value To Psihs Economic value Figure 7 reflects the complex nature of the public sector information market and its participants for just three very specific examples25. Very little evidence exists to accurately identify the ways in which public sector information acts as an input in the productive process and the importance it has in generating value. There is no central database tracking data and information collected and stored by the public sector and many businesses are reluctant to disclose how they use and re-use public sector information. As part of this research, steps have been taken to remedy these gaps through stakeholder consultations, but the fact remains that it is necessary, in many cases, to make a number of simplifying assumptions to arrive at indicative quantitative value estimates. Whilst Deloitte is content that these estimates make best-use of the information provided within the scope and parameters of the study, the estimates quoted in this report should be considered with regard to these caveats. Using an adapted bottom-up methodology outlined by the Office of Fair Trading in its 2006 Commercial Use of Public Information report26 that is consistent with HMT Green Book guidance27, this report has estimated that the value of public sector information to consumers, businesses and the public sector is currently approximately £1.8 billion in 2011/12 in 2011 prices (what is termed the economic value). This figure includes the direct value of public sector information to PSIHs, the indirect value of public sector information arising from its production and supply, and the direct use value of public sector information to consumers of public sector information - for shorthand, this is referred to as the narrow **economic value of public sector information**. | Value category | Central scenario | High scenario | Low scenario | |---------------------------|---------------------|------------------|-----------------| | Direct consumer surplus | £1.6 billion | £2.00 billion | £1.00 billon | | Producer surplus | £0.1 billion | £0.1 billion | £0.1 billion | | £0.1 billion | £0.1 billion | £0.1 billion | | | Indirect and induced | | | | | value (supply chain and | | | | | consumer spending) | | | | | Total | £1.8 billion | £2.2 billion | £1.2 billion | | Source: Deloitte analysis | | | | | | | | | Subjecting this modelling approach to sensitivity tests28 generates a lower bound value of £1.2 billion, and an upper bound value of £2.2 billion for the value of public sector information in 2011/12. Wider societal value The use and re-use of public sector information has much larger downstream impacts affecting all areas of society. Public sector information can act as a catalyst for positive creative destruction - the process of generating innovation, identifying and making efficiency savings, helping officials, business leaders and ordinary citizens make better policy and business decisions and promoting accountability and transparency. Through the use of case studies, it is possible to derive some indications of the financial scale of different components of social value. | Sector | Example | |------------------------------------------------------------------------------|------------------------------------------------------------------------------| | Healthcare and life sciences | | |  | | | | Using NHS prescribing data to identify efficiency savings of up to £1.4 | | billion per annum from switching from branded to generic drugs | | |  | | | | Reducing mortality rates following cardiac surgery leading to a positive | | impact on standards | | | Transport | | |  | | | | Using traffic data provided by the Highways Agency to build a tool to | | better plan road trips - potentially saving motorists up to £6.5 million per | | | annum (value of time saved) | | |  | | | | Using public sector information on roadworks to better co-ordinate utilities | | work and journey planning - leading to estimated benefits of around £25 | | | million per annum for local authorities and road users in terms of | | | efficiency savings and reduced congestion | | |  | | | | Embedding public sector information on real-time transport data in apps in | | London can save users between £15 million and £58 million in terms of | | | time saved, each year | | See main report for further details of report authors and details Whilst these individual estimates of social value from the different case studies cannot be simply summed (some are cost-savings, some are time-savings some are economic value and some are non-quantifiable), they suggest that the total social value of public sector information is likely to be significantly greater than the narrow economic value presented here. A conservative estimate of the wider social value of public sector information suggests a value at least three times the size of the £1.8 billion economic value may be appropriate29, i.e. over £5 billion p.a. However, without further data on the relationship between public sector information use and social outcomes, it is not possible to say definitively what the value might be. Total value Aggregating the calculated economic value and the conservative estimate of wider societal value generates a total current value of public sector information of between £6.2 billion and £7.2 billion in 2011/12 (2011 prices). Future uses Given the unpredictable nature of innovation, with the most valuable new products often being among the least anticipated, it is risky to offer firm predictions of the future uses and value of public sector information. Nonetheless, given the current trajectory of increasing volumes of public sector information being made available in ever more accessible formats, it seems reasonable to hypothesise that the larger part of the value to be generated from public sector information lies in the future. Much of this value may come from combining public sector information with information from other sources, such as details of consumer spending habits held by supermarkets and other retail firms, or details of domestic and commercial properties. Many of these future uses may be extensions of the ways in which public sector information is already being used. For example, a recent study calculated that the benefit to the local government sector from the use of geospatial data was £232m over five years, through a variety of measures such as more efficient routes for waste collection.30 It is to be expected that such uses will become increasingly widespread throughout the public sector at both a local and central level, as more information becomes available, methods of harnessing this information are improved, and best practice becomes more widely adopted, thus increasing the value derived from public sector information. Further benefits are likely to emerge for private individuals, business and other organisations as methods of exploiting public sector information are developed and improved. More effective ways of data exploitation can include:  greater system-wide analysis through more sharing and combining datasets together to consider policy and business issues from a range of non-traditional perspectives;  unlocking the potential from linked data: and better integrating; and  greater data-mashing with private sector and individual datasets. The case studies explored in the main report illustrate some of the ways in which public sector information is generating value. Such examples are likely to proliferate as available data proliferates and the expertise to exploit it is developed. An example is the case of Honest Buildings, described in Chapter 6: this SME is exploring ways to help businesses reduce their energy bills by combining Energy Performance Certificate data with privately held data, potentially delivering significant savings and reducing the UK's energy usage. Such examples may be expected to proliferate as access to information increases, and innovative uses are developed. In addition, there are likely to be benefits from wholly new uses of public sector information. Numerous additional possibilities for achieving such savings and improving policy may become apparent as more information is made available and expertise in its use increases. In addition, there are likely to be more 'blue sky' opportunities, such as those identified by the Government Office for Science. These are explored further in Chapter 5, but include improving management and resilience of food supplies, tackling obesity, and detecting and identifying infectious diseases. These require combining public sector information with other sources of information rapidly and making the resulting insights available to decision makers in a timely fashion to allow prompt responses to crises and informed policy decisions. Barriers to realising the full potential of public sector information in the UK ## A Taxonomy Of Barriers Adapting a taxonomy originally developed by the Data Strategy Board, the research has examined the evidence to identify the areas where barriers may currently exist. Note, some of the themes under each barrier overlap, e.g. privacy could be captured under legislation or access. Source: adapted from DSB Legislative barriers include whether certain acts of legislation and other regulations reduce the usability of public sector information datasets by consumers. There are also further questions over whether current assurance/accreditation standards for public sector information remain effective and whether there is scope for existing licensing arrangements to be improved. Economic barriers include questions of which datasets to release (which datasets yield the highest value) and how their costs (if any) should be covered. Access barriers to maximising the value from public sector information can include:  a reluctance to publish or share datasets;  a bias against using non-traditional datasets;  a reluctance to use public sector datasets because of concerns around quality, reliability and on-going support; and  a lack of skills to fully exploit the value of public sector information. It should be noted that the extent of these barriers may differ between public sector information datasets and also between the different types of users. Each of these barriers is discussed in more detail below. ## Legislative Barriers Privacy and the impact of current regulations and legislation The review of available evidence suggests that by and large, the current legislative and regulatory environment around public sector information is not acting as a barrier to generating value and market development. While a full legal analysis has been beyond the scope of this study, particular acts and regulations such as those covering Data Protection and Human Rights legislation have not emerged as preventing the development of new products or services using public sector information31. The majority of stakeholders consulted have not reported that these generic legislative acts are currently preventing them from using and re-using public sector information, but, in some cases specific legislation controlling a particular data collection exercise do. However, the evidence received does suggest there are some current challenges around perceptions and attitudes towards data release. In particular:  regulations such as Data Protection are sometimes used as a shorthand justification for not sharing public sector information within the public sector, with PSIHs not always able to translate their awareness of their rights and duties into scenarios where public sector information is released or shared, causing a barrier; and  when a policy decision is taken not to release public sector information datasets to the general public, the reasons are often not well articulated or the conditions attached to access are overly restrictive. Stakeholders have cited examples where the Data Protection Act (and other legislation) has been used as a reason for a PSIH to withhold information from the general public. However, as noted above, in reality, the Act should rarely be a barrier to sharing information. Where public sector information datasets do contain personal details, these may need to be aggregated or anonymised. Where this is done effectively the Data Protection Act, in most cases, no longer applies to the information and it can be made available. This is not to downplay data protection issues. The impact of breaches leading to the release of personal information can be extremely serious. Further, even if data is anonymised, people may be reluctant to report it if they believe it can have wider consequences, e.g. reporting crime data may adversely affect house prices32. These issues notwithstanding, PSIHs are beginning to use innovative methods to test different ways of anonymising datasets - for example the Ministry of Justice worked with statisticians, the private sector and the academic community to avoid the 'jigsaw effect'33 occurring from the release of offender data. Within the public sector, there are also questions surrounding the ability of different public bodies to share datasets with one another. These have been explored in depth in the recent report by the Administrative Data Taskforce34. It notes that as regards the legal gateways established to allow departments and other public sector bodies to share information without obtaining the consent of the data subjects, "recent experience demonstrates that link-specific gateway legislation is both cumbersome and inefficient." As a solution to this, the Taskforce recommends the creation of a generic legal gateway to reduce this barrier to the exploitation of public sector information and clarify the legal position around sharing data. Note that this applies to sharing of data within the public sector and with certain accredited third parties such as researchers, rather than publication for use by the general public. Insights  Existing regulations and legislation governing public sector information do not appear to be acting as actual barriers to realising the full potential value of public sector information. However, the manner in which some of these regulations and legislation are interpreted can lead to overly risk averse behaviour and can create barriers.  Increasingly effective anonymisation techniques and an approach across the public sector that emphasises granting access to as much data that is compatible with privacy and security has the potential to improve access to public sector information. Licences Licensing conditions play an important role in facilitating (or preventing) the full exploitation of the value of public sector information. The ideal standard widely acknowledged by stakeholders was licensing public sector information under the Open Government Licence (OGL), and increasing amounts of public sector information are being made available as open data under it, even by organisations that have traditionally charged for data35. Some groups of stakeholders have argued that if the OGL were used for all public sector information, this could substantially increase the openness of the UK's public sector information and could remove many of the barriers to use and re-use that currently inhibit the realisation of the full value of public sector information. However, some argue that the public sector information landscape is characterised by its diversity, and for this reason a 'one size fits all' solution is unlikely to be practical or necessarily desirable. For cases where the release of information under the OGL is not considered appropriate and cost recovery is justified, the introduction of a generic charging licence could, in principle, address the current complexity of charging arrangements for public sector information, completing the UK Government Licensing Framework and simplifying licensing arrangements for users. Some stakeholders pointed out that by having a charge, users and re-users can be re-assured of the quality of data and be able to expect a certain level of service (this is discussed in more detail below). However, one concern raised was that such a licence could encourage some PSIHs who are not covered by the OGL, to charge for certain datasets. Insights:  Making public sector information available under the Open Government Licence is seen by a large number of stakeholders as an effective means of removing barriers to exploiting the value of public sector information.  If there are instances where a generic Government Licence for charging for public sector information are applicable, such a Licence would need to be drafted in a way to avoid incentivising charging when there is no strong justification or leading it to become the default alternative to the Open Government Licence. Eligibility restrictions on accessing particular datasets With respect to access restrictions to public sector information datasets (such as the datasets only being available to researchers or in secure environments), in many cases the rationale for these restrictions are clear. The rationale may cover national security reasons or genuine data protection concerns. However, some stakeholders have reported that in some cases, the rationale for restrictive access to certain datasets is not always clear, appears overly restrictive or may no longer be relevant, although it should be noted that just because a stakeholder feels the rationale is overly restrictive, that does not necessarily make it so. For example, some commercial start-up companies have reported difficulties in accessing different versions of the National Pupil Database as non-research organisations. While restrictions on access are in this case clearly needed to protect sensitive and personally identifiable information; there is a valid question as to whether there are ways that some or all of this information could be made available to commercial organisations to develop new products and services to help parents, teachers and other stakeholders to improve decision-making, increase accountability and identify good practice. Without this, opportunities for innovations using this and other datasets are likely to be missed, meaning loss of the value that they could potentially create. Insights:  The eligibility restrictions imposed around certain datasets are typically due to reasons of national security, data protection and other sensitivities.  The rationale behind these restrictions is not always clearly articulated and may, in some cases, no longer apply. In some cases, this may be preventing opportunities for innovation to take place. ## Economic Barriers The evidence reviewed suggests a number of key economic challenges around maximising the value from public sector information in the UK. Primarily these relate to the value and cost of datasets, which can be grouped into two key themes:  which datasets are made available to the general public; and  which datasets consumers have to pay to access for (funding models). Data gaps There is currently no national or local information asset register covering the amount and type of public sector information datasets held36 (irrespective of whether it is being released to the public) or the detailed costs of collection and dissemination. Similarly, there is little evidence on how consumers themselves are using and re-using particular datasets. While this has meant this report has been forced to make a number of assumptions in order to reach quantitative estimates, there is a more significant impact on PSIHs themselves. By not being able to accurately ascribe value to different datasets, PSIHs are generally unable to reach evidence-based decisions as to which datasets to publish, how to publish them and what support to provide. One consequence of this is that the costs (which are readily measurable *a priori*) of making particular public sector information datasets available may appear to be much larger than the benefits - as the benefits case cannot be clearly articulated due to a lack of evidence. Indeed, as part of this report, a sample of government officials have been consulted over the reasons why public sector information datasets are not released: over 50 per cent of those responding identified resources as an issue preventing the release of more public sector information, with the following response being typical: "in a time of diminishing resources and the need to make best use of the resources we have; the time and the cost of ensuring data validity before release is an issue." This was one of the most common reasons given for why data is not released, but not the only one - others include data protection and legislation. Stakeholders have identified particular datasets (such as an aggregate Energy Performance Certificate database) that are currently not available to them (either for free or for a fee) that they could use to generate new products and services. By not making these datasets more widely available (or articulating the reasons they are not available), PSIHs may, whether knowingly or not, be acting as a barrier to realising the full potential of public sector information. There are routes to address these data gaps. One route might involve conducting a public sectorwide audit of public sector information (which also covers the customers using and re-using it). This would involve both primary research to determine the stock of public sector information held across all PSIHs and also identifying how this data is being used commercially across different economic sectors and actors. This would help match costs and benefits to individual datasets and building this report to identify those datasets that can generate the most value for the UK. The costs of doing such an audit would not be insignificant and for it to be effective, it would need to be repeated in future years (though the on-going costs may be lower than the one-off start-up costs). However, the benefits of doing such an audit could be outweighed by PSIHs having a much better sense of which datasets are creating the most value, which can guide future policy decisions around releasing data. Other routes to addressing data gaps might involve better tracking of usages (perhaps through measuring how often data is re-used in other sources), requiring all new public sector information datasets to be logged centrally or crowdsourcing an audit across the public sector. Another potential route for the long-term, at least conceptually, might be a true single conduit for the access of all public sector information. The Open Data User Group (ODUG) has been set up as an advisory group to Government and provides a channel through which the potential users of data, from all areas of the community, can identify their need for data and set out the benefits they expect this data to deliver. This will help PSIHs understand in more detail the potential benefits which the release of individual datasets can be expected to deliver. Through the completion of data gaps, it would be possible for government to articulate what is meant by the term **core reference dataset** (beyond the definition contained in the Open Data White Paper). The issue of core reference datasets is also raised in recent work by APPSI on the national information framework for public sector information and open data. 37 Consideration could include:  the features of a particular dataset that make it a core reference dataset;  the funding arrangements of core reference datasets (see below);  the obligations of suppliers of core reference datasets; and  the rights of citizens to core reference datasets. Insights:  There are significant data gaps when it comes to public sector information. This lack of data can, in some cases, lead to inertia with certain public sector information datasets not be released or conversely, undue attention being given to datasets that are unlikely to generate significant value but have a low cost of dissemination.  There are a number of routes to addressing these data gaps. These range from a detailed, regular audit of public sector information to improved tracking of current usage and a single conduit for all public sector information. Funding models Related to the question of making the business case for more public sector information being released is the issue of how the cost of generation, collection, retention and dissemination of the datasets should be funded. This also leads to questions around pricing for access to public sector information. This is a complex issue and data on costs (and benefits) is not fully available. Further, one must take account of different costs being incurred across the different stages of the data lifecycle. For example, in the case of so-called 'exhaust' or 'by-product' data that is generated as a result of PSIHs conducting their day-to-day and other activities and duties, the marginal cost of its generation will, by definition, be negligible or very low compared to the activity that caused the data to come about; but the marginal cost of its dissemination to the wider public may be higher and vice versa for some 'purposely collected data'. There will also be additional costs in formatting the data for use and further costs if support is provide to the public in re-using the data. The issue of charging and funding models for public sector information is highly contentious and extremely complex. For example, there remains an element of subjectivity as to what constitutes a dataset and what constitutes a 'value-add' service - with some PSIHs arguing that what is being charged for is not the public sector information itself, rather its interpretation and analysis. As part of this report, a wide range of opinions have been expressed as to whether there is any economic or other justification for charging for public sector information datasets. On the one hand, these arguments include:  charges for datasets create barriers to entry and expansion for SMEs and individuals to develop new products and services;  the **charges prevent SMEs and individuals from 'experimenting' with the datasets** before they purchase to see if they are able to derive value from them, thereby making it hard to develop business cases; and  any lost revenues to PSIHs from releasing datasets for no cost will be recovered by the Exchequer in the long-run through increased tax revenues and more jobs being created. In contrast, arguments have been put forward to support current pricing arrangements include:  aligning a revenue stream with a particular dataset will 'protect' it from any reductions in funding, allowing PSIHs to continue to supply this even if they themselves must make other savings;  a price can be interpreted as a signal of consumers' willingness to pay for a particular dataset's quality and a commitment by the PSIH to maintain this and offer support; and  charging for certain datasets is necessary given they include elements of commercial or international datasets. As the most visible PSIHs that charge for certain public sector information, a great deal of attention has been focused on the four Trading Funds that make up the Public Data Group (PDG): Ordnance Survey, the Met Office, Land Registry and Companies House. The view has been expressed by some stakeholders that these PSIHs hold some of the most valuable datasets and there are strong arguments that these should be treated as **core reference datasets** available to all at no direct cost to the general public. It is not helpful to treat these PSIHs as a single group - indeed, there are a number of other public bodies that charge for access to datasets38 and there are a number of other Trading Funds outside the PDG. The four Trading Funds in the PDG differ in their sources of revenue, their public service duties and whether the public sector information they hold can be classed as '**exhaust'** data or 'purpose-**collected'** data. Further, it should be noted that substantial progress has been made by the four Trading Funds in recent years to make increasing volumes of data available as open data39 and there continue to be moves in this direction. However, despite these positive steps, there remains a perception among many consumers and commentators40 **that they are unable to access certain datasets for reasons of cost** and this is creating a barrier to business growth. A number of studies (e.g. Pollock, 2011 and others - see Appendix 3) have argued that releasing these datasets as open data will have significant welfare benefits. The impact of a cost recovery model for public sector information, compared to the Open Government Licence model, is summarised below. ## Information Market Taxpayer Funded Public Sector Information Public Sector Information Supplied On A Cost Recovery Basis  Access to public sector information involves a cost to the user and may come with restrictions  Public sector information typically made available at no cost to users under the Open Government Licence  There may be strong public policy reasons for having these datasets available at no cost  The costs of collection (rather than dissemination) are significant and cannot be borne by the public purse  May include other data sourced under licence  Will not include other commercial or international datasets  Access to Public sector information is restricted on the basis of cost  The availability of public sector information at no cost to the user can contribute to the transparency agenda by increasing access to the widest possible customer base, irrespective of the ability to pay  Will not typically include other services or any other guarantees  May also include bespoke value-add services and guarantees of data quality and continuity Source: Deloitte analysis It is very difficult to perform a robust cost-benefit analysis of different funding model options for PSIHs, not least because PSIHs differ greatly from one to the next. While some data is available as to the costs incurred from collection and dissemination, this is not typically openly available or apportioned by dataset, nor is data readily available on how their customers are using the datasets and generating revenue and value. More fundamentally, very little data is available on what the benefits might be if charging models were to radically change - as it is very difficult to predict how businesses and individuals might use datasets in the future to generate new products and services and by implication impact economic growth. It is also important to note that, as per the HMT Green Book41 guidance, any benefits from a change in charging structures should include not just increased tax receipts but wider social benefits and costs in terms of organisational impacts. Even in the case of the four Trading Funds that make up the PDG, estimating the effects on Exchequer revenue of releasing all their public sector information as open data is a difficult task, even in spite of the information made available by the Trading Funds as part of the study. There are differing views on precisely which revenues should be considered relevant to PSI, considering factors such as specific revenues from the data, the cost of collecting the data, the extent to which Government 'buys' data from itself and so forth. That notwithstanding, on the basis of the information made available to this study, it is possible to indicatively calculate that the cost effects on Exchequer revenue of continuing to collect and disseminate Trading Funds' public sector information in its current guise without charging for it. This cost is estimated to be in the order of £395 million on an annual basis42. However this figure is without regard to the extent that government pays for public sector information from the four Trading Funds in the PDG (this varies significantly between Trading Funds). On the basis of information provided by sales channel, it can be estimated that the annual loss to the Exchequer would be lower, as government would no longer need to purchase these public sector information datasets - it could use them at no cost. In this scenario, the direct loss to the Exchequer on an annual basis might be of the order of £143 million. This figure may be lower still if there are efficiency savings to be made if fewer dedicated sales and marketing resources are required by Trading Funds. Following the HMT Green Book approach to account for the wider social and economic benefits, it is important to note that in a world without charging, private sector entities (consumers and businesses) that currently pay for access to public sector information provided by the Trading Funds would benefit by this amount - £143 million - and some of this may be recouped in the medium-term as a result of additional economic activity generating tax revenues. An additional group that is currently deterred by having to pay for the data would also benefit as they are able to access the data. Estimating the size of this latter group is difficult but directionally it is clear that removing charging would mean more people and businesses, not fewer, would be able to access and benefit from this data43. Conversely, organisations who are at an advantage in using their own proprietary information for commercial advantage, might find their competitive advantage eroded if more public sector information is released to act as a publically available substitute to that data. The situation is thus complex, and while the above example is stylised, it does suggest the quantum necessary for the associated benefits to outweigh the costs . Without more detailed and accurate data on both costs and benefits (including wider social benefits) it is not possible to reach a clear conclusion on this issue. However, this is not to say there is no room for improvement today in the provision of public sector information that carries a charge and a number of steps are being taken in this respect. These include44:  much more **communication** about what existing licences allow consumers to access and use / re-use the public sector information for, building on existing efforts by the trading funds and other PSIHs to build awareness among the user community;  offering substantial **discounts** to SMEs and individuals;  implementation of a '**royalties'** model for consumers to exploit the value of public sector information up to a certain value before a charge is applied;  greater provision of '**sandbox'** or secure environments in specialised locations across the UK to allow consumers to explore datasets;  greater **provision of out-of-date public sector information** at no cost to the general public to allow consumers to experiment; and  greater use of '**hack days**' to demonstrate the value of particular public sector information datasets. Of course, not all of these initiatives will be applicable to all PSIHs that charge for public sector information - there is no 'one-size-fits-all' model - but they should work with the grain of the market and build on existing initiatives to release more data. In some cases there may be significant logistical or legislative challenges to overcome before the above suggestions are implemented. Insights:  The issue of charging for public sector information datasets and their funding models is complex. While significant progress has been made by a number of major PSIHs in this area in simplifying charging structures and making more public sector information available as open data, there remains a perception that barriers exist and there is scope for improvement.  Ways to improve access could include greater communication on licence conditions, discounts to certain consumers, a royalties model, use of a 'sandbox' model, greater provision of out-of-date information and more hack days.  There is currently a lack of data to definitively conduct a cost-benefit analysis across different funding models across the range of PSIHs currently charging. This is an area for further analysis through primary research with the direct customers of public sector information and a detailed cost apportionment exercise to assign costs to individual datasets. ## Access Barriers The evidence reviewed suggests a number of access barriers to fully maximising the value of public sector information:  difficulties around finding where public sector information is located;  a lack of skills and understanding to fully exploit public sector information;  the format and reliability of public sector information; and  a reluctance to use and share public sector information. Public sector information fragmentation Fragmentation in the supply of public sector information continues to be a problem for many consumers, even following the establishment of a number of data portals. A sample review of websites done as part of this study has found that too often it is difficult to locate a clear point of contact, or establish who has ownership of and responsibility for a particular dataset. Even on data.gov.uk, where contact details are provided, these are often generic enquires email addresses rather than named contact email addresses. In contrast, this report has received feedback that when consumers have found the relevant point of contact in a PSIH their experience has been very positive with a productive dialogue being established. Indeed, some individual PSIHs have established clear procedures for consumers seeking to raise queries or challenge restrictions, although this is not yet happening in all areas of the public sector. Dialogue can also take place between users: data portals such as data.gov.uk and the London Datastore have busy forums and request pages which encourage an active dialogue between information users and re-users and information holders. Public sector information fragmentation can, at best, raise transaction costs from dealing with public sector information and, at worst, deter users and re-users from using public sector information altogether, or make this impossible to achieve. Reducing fragmentation across the public sector could save up over £50 million per annum in terms of reduced transaction costs and time saved for data specialists45. However, it should be noted that the existing fragmentation and opacity of some public sector information datasets has created market opportunities for some intermediaries to develop new products that aggregate datasets and present it in innovative ways. Thus, PSIHs need to consider who is using their data and how, and whether there is a risk of crowding out innovation if they intervene to reduce fragmentation in such a way that duplicates what the private sector can provide. Insights:  Improvements are ongoing to reduce the time taken to locate public sector information datasets. Reducing this can help reduce transaction costs and the overall cost of doing business. Data scientists and the skills gap A number of studies have recently been published contending that advanced economies face a skills gaps in so-called '**data scientists**'. Although statisticians and experts on quantitative analysis have long existed, data scientists differ from these existing professions in a number of important ways. As well as being able to work with large volumes of structured and unstructured data, they are able to translate these analyses into policy and commercial-ready insights and effectively communicate them to a range of stakeholders, often using innovative tools and visualisations. Key to this is the ability to "identify rich data sources, join them with other, potentially incomplete data sources, and clean the resulting set." Data scientists will also be conversant with the vocabulary of public sector information and open data and have the skills to create and manipulate large datasets and linked data. In many ways they therefore resemble scientists more closely than traditional data analysts. There is a fear that a lack of data scientists will reduce the UK's competitive advantage. The evidence received suggests that in the UK:  there is increasing demand for individuals with a portfolio of skills able to manipulate quantitative data, present it in innovative ways and generate commercial and policy insights from it;  many of the individuals performing these roles have no specialised training, but rather have learned on the job and / or have a science/computation/mathematics background;  businesses rarely designate specific 'data scientist' roles; rather, such analyses are done across a combination of professions such as statisticians, economists, researchers, analysts, policy and commercial managers - a dedicated data scientist would embody elements of all these roles;  certain industries such as pharmaceuticals, financial services, professional services and retail are increasingly dependent on these skills sets and a shortage of them would reduce the UK's international competitive advantage. Based on ONS figures for 2011, around 1.5 million workers in the UK, representing around 5 per cent of the active workforce, are employed in job categories that are likely to involve elements of the role of the data scientist, but which individually may not be termed data scientists. The average annual median wage of these workers was over £36,000 in 2011 which is higher to the national annual median wage of £26,000. Economic theory suggests that a skills shortage will manifest itself in the form of large wage differentials between 'data scientists' and other comparable professionals. A recent report found an observable pay premium for 'big data' staff in 2012, with salaries around 20 per cent higher than those for IT staff as a whole.46 This may persist due to lags between training and entering or reentering the workplace, but economic theory suggests it will eventually dissipate in the long-run as supply increases to meet demand and is able to exploit the full value of public sector information. While evidence47 suggests there are a number of sector initiatives to reduce the talent learning curve and establish precedence, these initiatives will take time to work through the system with the interim consequence being that some value of public sector information may remain locked up. The general scarcity and increasing competition for these skilled workers from the private sector makes it harder to construct the infrastructure for world class public sector information. A shortage of data scientists also hinders efforts to scale-up public sector information data analytics. Within the public sector, concerns have been highlighted over a lack of skills and familiarity to work effectively with data. These concerns should not be overstated as public sector officials have a long history of using public sector information to inform policymaking without having dedicated data scientists. What the concerns appear to be directed at are cultural biases against using public sector information from outside home PSIHs, as well as having the necessary skills to combine and manipulate Big Data and Linked Data. One stakeholder has observed that "data [owners] do not fully appreciate the power and potential of open data. There may also be cultural resistance to change: for instance, through not trusting or being able to exploit new, untried and untested third-party datasets in analysis and policy advice." Where public sector employees do not have a numerate background, or are not accustomed to working with large datasets, they could benefit from increased training and support in this area. However, this research reveals understandable concerns over resources at a time when budgets are under considerable pressure. The main report outlines a number of cost-effective routes to build the public sector skills base, which include taking massively open online courses (MOOCS), creating incentives to use public sector information as part of day-to-day business, and convening the public and private sectors to work together to explore public sector information. Insights:  While there may be gaps in the supply of 'data scientists', economic theory suggests that in the medium- to long-term, the number of data scientists will increase, filling the supply gap and reducing the current wage premium.  However, in the short-term, this may mean public sector information is left underexploited and associated value remains locked out. The general scarcity and increasing competition for these skilled workers can make it harder to construct the infrastructure for world class public sector information and scale up efforts to exploit its value.  There are some low-cost solutions that can be explored in order to quickly improve the skills base to be able to effectively manipulate and extract value from public sector information. Format and reliability The release of data in an unfinished form raises concerns for the public sector too because of concerns that the public may be provided with data that is inaccurate and potentially misleading, which can have negative consequences. With respect to the format of public sector information, its importance may vary between customers. For casual consumers, it is clearly of the utmost importance, and they may most value format. In contrast, professional users may be more concerned with consistency of service and data and can accommodate changes to format. Equally, intermediaries may positively value low quality data as they can provide a service to improve the quality and format of public sector information for wider consumption. Evidence as to how significant a barrier this currently forms to the use and re-use of public sector information is mixed. In general, there seems to be steady improvement in all the areas of format, although there remains work to be done - especially with regard to ensuring consistency in format and upgrading the star rating of datasets. Progress is also being made with data being updated more consistently. Examples of this include data released by the Met Office, and transport data released directly by Transport for London as well as through data.gov.uk. The Open Standards Principles48, the Standards Hub49, the Open Standards Board and the public sector will be crowdsourcing, researching and implementing data standards for Government IT systems. The user challenges it will focus on are likely to cover standards relating to formats and meta-data that should help to provide data on reliability. Some of these open data standards may be made compulsory for central government use. However, a minority of stakeholders have complained that datasets released by different PSIHs are not always easy to combine and work across, because of variations either in the content or the format. This is a particular issue with data produced by local authorities, with each local authority often adopting their own standards and procedures. This report recognises that there are on-going efforts, such as e-PIMS, to tackle this issue and secure a greater degree of standardisation across PSIHs. Further, there appears to be scope for improvement is greater certainty and clarity over the publication schedule of public sector information datasets and what users can expect from PSIHS. In particular, stakeholders have noted the value in having a cover sheet setting out the limitations of the data, its release schedule, explaining outliers and providing links to previous analyses (i.e. greater use of **metadata**50). Insights:  Improvements continue to be made on the quality, format and consistency of public sector information.  There is scope for improvement, especially around the greater provision of metadata. ## Summary Of Key Research Questions Answered Further details behind each of the key findings, addressing the Data Strategy Board's overall research questions are summarised in Figure 12 below. ## Figure 12: Key Research Questions Answered Theme Findings Definitions Of Public Sector Information And Its Characteristics  What are the main market segments for public sector information both existing and emerging?  While there is no central figure on the total number of public sector information datasets currently being made available across all parts of the public sector, a review of selected data portals suggests the number could exceed 37,500 from over 750 different publishers with over 2.5 million downloads  The key suppliers of public sector information are public sector bodies. An initial assessment shows that of a total of 781 publishers (as of 27th February 2013 on selected data portals), the top ten suppliers of PSI supplied over half of all datasets published on the website, with the Office of National Statistics, the Department for Communities and Local Government and Health and Social Care Information Centre the three largest suppliers by number of datasets.  What is the composition of these markets in terms of companies, their governance and their outputs  Customers of public sector information including the private sector, civil society, individuals and government itself. Business models include developing apps that use/re-use public sector information, data enrichers, data enablers and data marketplaces.  Analysis suggests the construction; real estate; financial and insurance; public sector; and arts, entertainment and recreation sectors are some of the largest users of public sector information (and public sector open data).  As well as being used for commercial and policy purposes, public sector information can be used for scientific research, data journalism and holding public service providers to account.  Based on ONS figures for 2011, it is estimated that around 1.5 million workers in the UK (5 per cent of the active workforce) are employed in jobs that are likely to involve direct exposure to public sector information and big data. Analysis of ONS data of jobs that involve 'data science' suggests an average annual median wage of over £36,000 compared to the national annual median wage of £26,000 in 2011.  The extent to which public sector information is a key input into companies' products and services will depend on the company in question, with smaller companies likely to be more reliant on it than larger companies, with their products and services more likely to use public sector information as the critical input.  Public sector information acts as an input as either the main or supplementary data point for complex algorithms and analyses used in products and services, as a source of insights (perhaps summarised as data dashboards or visualisations) for business or policy decisions, as API feeds for apps and so forth.  What are the characteristics of the markets for public sector information, including secondary markets?  The supply side of the market is mostly populated with public bodies supplying public sector information - there are few private sector substitutes. ## Theme Fi Dings N  Broadly speaking, public sector information customers on the demand side of the market can be split into seven archetypes: larger data companies, SMEs creating apps, SMEs creating efficiency solutions, not-for-profit organisations, individuals, the public sector and other non-data specialist companies. These companies vary in size (from sole traders to larger multi-national companies), turnover (those having established, profitable businesses and those who have yet to report a profit), the dependency on public sector information and the types of public sector information used.  The demand side of the market for public sector information includes a range of different business models including: data marketplaces/infomediaries, apps-based re-use, data enrichment and data enablers.  Downstream, insights and inputs from public sector information can be found in a range of products and services. Products and services range from credit scoring, economic forecasts, weather apps, transport apps, navigation systems and other mapping tools, research reports, tools to assist choice (e.g. in education, health or housing) etc. Downstream, public sector information can also be used to improve transparency and improve public services and hold providers to account.  What do past studies tell us about the markets and how they function?  There is very little previous literature on the functioning of public sector information markets, possibly due to data limitations around the supply of datasets. The literature has instead focussed on delineating links between public sector information and growth and welfare.  What does the current evidence tell us about the likely evolution of these markets?  The available evidence suggests that as better quality public sector information becomes available and accessible, customers will be able to use it in increasingly sophisticated ways to exploit its value and drive growth outcomes.  The literature suggests the provision of more and better public sector information can raise sales (a 5.7 per cent increase in sales in restaurants displaying 'good' scores), improvements in public health, a productivity boost (around 0.6 per cent of GDP in the case of New Zealand geo-spatial data) and faster growth (firms growing 15 per cent faster in countries where certain data was either free or priced at marginal cost) - see Appendix 3 for more details. These figures are based on particular examples and are not directly transferable to the UK.  Adapting the McKinsey analysis used by Policy Exchange, improvements in efficiency between 1 and 5 per cent caused by better use of public sector information can lead to annual savings of between £1 and 8 billion nationally and around £70 million in local government (on a smaller savings ratio).  Benefits are likely to come from further release of more and better data, but the release of swathes of data in and of itself will not guarantee value, it is how society as a whole innovates with it that counts. ## How Public Sector Information Is Used And Re-Used Inside And Outside Of Government  What are the different types of public sector information and can we estimate the value that they  Public sector information differs by its availability to the public, its format, its complexity and speed of replacement, its content, its channel of distribution and the costs of collection, generation, ## Theme Findings hold for government and the economy? maintenance and dissemination.  This report has estimated that the narrow value of public sector information to consumers, businesses and the public sector in 2011/12 was approximately £1.8 billion (2011 prices). This is a mid-point estimate, with the sensitivity analyses giving a range between £1.2 billion and £2.2 billion  However, the use and re-use of public sector information has much larger downstream impacts affecting all areas of society beyond its direct customers. Case studies examining the downstream impacts created by different organisations using and re-using public sector information have shown the monetary value of some of these benefits can be in the order of millions, if not billions.  For example, publishing data on adult cardiac surgery has estimated to reduce mortality rates, which in turn has an economic value in excess of £400 million per annum and using live data from Transport for London in apps can save users time to the economic value of between £15 million and £58 million per annum.  While an aggregate figure on the social value of public sector information is difficult to reach, on the basis of conservative assumptions, the figure could be in excess of £5 billion in 2011/12 (2011 prices). This figure is likely to increase as public sector information is used more widely and in more impactful ways.  This yields a total economic and social value of the market for public sector information of between £6.2 billion and £7.2 billion in 2011/12.  What does the evidence tell us about the size and potential market for public sector information? Is there reliable data available?  While a complete dataset on the number of public sector information datasets is currently not collected, a preliminary estimated (based on a sample of data portals) suggests the volume of public sector information datasets exceeds 37,500 - but this is likely to be an underestimate.  As discussed above, the narrow economic value of the market can be estimated to be between £1.2 billion and £2.2 billion in 2011/12.  The total economic and social value of the market can be estimated to be between £6.2 billion and £7.2 billion in 2011/12.  There is currently insufficient reliable data to be able to make estimates on the size of the potential market for public sector information in the future. However, the increased availability of better and more public sector information, more linked data and better tools and techniques to exploit it mean the value of the market is likely to grow.  What are the gaps in the evidence base and what can we do in the short term to address them?  The key gaps in the evidence base which, if filled, could lead to more precise estimates on the size, include: (i) the total number of public sector information datasets collected across the public sector; (ii) the individual cost elements behind each dataset and (iii) how public sector information datasets are being used and re-used by customers and others downstream.  In the short term, these gaps could be addressed by (i) a more detailed survey of public bodies to understand what datasets are being held and disseminated; (ii) a survey and consultation of ## Theme Findings customers of pay-for public sector information; (iii) a wider survey of users of open government data or some form of limited tracking of how this information is re-used.  One route to increasing the amount of data on the use and re-use of public sector information would be to foster a climate of greater openness, taking into account commercial sensitivities around how personal sector information is used/re-used. For example, one way of collaborating and fostering more openness in future, providing it can be carried out in a non-too-onerous manner, might be providing data free to third parties on the pre-condition that the information flow becomes a 'two-way street' for Government and policymakers, e.g. "you can have our data, but we'd like to know how it is being used and re-used to give us insight, benefit us and in turn UK society".  Can we assess the current and future for the; UK market, EU market, Global market?  This report has assessed the current market for public sector information in the UK and considered how it might evolve. Many of these insights will be transferable to other markets and, subject to overcoming any data limitations, it would be possible to assess the current and future potential of public sector information markets overseas.  However, we note the potential issues arising from a straight read-across of outcomes from one jurisdiction to another. As well publicised examples, public sector information value creation in Denmark and New Zealand are widely cited as a reason for releasing more data. The UK is a larger and more complex economy and data landscape, and as such the impacts of similar policy-changes might be quite different.  What indicators should we use to measure our success in widening access to public sector information?  Some organisations are already developing Key Performance Indicators around the quality and format of data being made available.  However, success is ultimately determined by the ability of public sector information customers to be able to effectively and efficiently access and exploit datasets as much as would be reasonably expected.  Metrics could be created to measure progress against the barriers identified in this report. ## Challenges To Fully Exploiting The Value Of Public Sector Information, Including Issues Around Competitiveness, Funding And Regulation  What are the strengths and weaknesses of the UK market?  The strengths of the UK market relate to the commitment by government to release more and more public sector information and an emerging eco-system of companies and individuals able to exploit it.  The report has identified a series of barriers around legislation, economics and access which may hinder the growth of the UK market.  What are the key issues affecting the data market?  The report has identified an issue around consumers' and suppliers' perceptions on the availability of certain public sector information datasets. The report has also noted on-going complexities around charging for certain datasets - the paucity of data on the total stock of public sector information being held/collected, the different cost components behind individual datasets and how datasets are being used and re-used by customers and the wider public, makes it difficult to make decisions around the ## Theme Findings provision of public sector information.  This lack of data (see above) is preventing accurate cost-benefit analyses and identifying where scarce resources should be allocated to maximise the benefit from public sector information.  What are the medium and longer term trends in the data market?  It seems reasonable to hypothesise that the larger part of the value to be generated from public sector information lies in the future. Much of this value may come from combining public sector information with information from other sources (e.g. held by the private sector), such as details of consumer spending habits held by supermarkets and other retail firms, or details of domestic and commercial properties.  Further benefits are likely to emerge for private individuals, business and other organisations as methods of exploiting public sector information are developed and improved. More effective ways of data exploitation can include: o greater system-wide analysis through more sharing and combining datasets together to consider policy and business issues from a range of non-traditional perspectives; o unlocking the potential from linked data: and better integrating; and o greater data-mashing with private sector and individual datasets.  In addition, there are likely to be benefits from wholly new uses of public sector information. Numerous additional possibilities for achieving such savings and improving policy may become apparent as more information is made available and expertise in its use increases. The main report summarises some examples of 'blue skies' thinking around public sector information.  How far does regulatory regime enable the market and how far does it constrain it and in what ways?  Existing regulations and legislation governing public sector information do not appear to be acting as actual barriers to realising the full potential value of public sector information. However, the manner in which some of these regulations and legislation are interpreted can lead to overly risk averse behaviour that can create barriers.  What licensing arrangements are currently in place for PSI and how do they enable open data?  The Open Government Licence is widely regarded by stakeholders as an effective means of removing barriers to exploiting the value of public sector information. However, this is not always used and does not cover all public sector bodies.  How does the cost of public sector information affect the data market?  At the broadest level, charging reduces the use of public sector information, but it can also act as a signal of quality for (prospective) users.  The issue of charging for public sector information datasets and their funding models is complex. While significant progress has been made by a number of public sector bodies in this area in simplifying charging structures and making more public sector information available as open data, there remains a perception that barriers exist, with the cost of datasets deterring use.  There is a lack of data (see above) to definitively conduct a cost-benefit analysis across different funding models. This is an area for further analysis via detailed analysis of customer bases, costs and ## Th Me E Findings how data is used.  How clear are the standards that apply to public sector information and how do they affect the market?  Improvements continue to be made on public sector information datasets' format and consistency, with initiatives such as the Open Standards Principles and APPSI definition likely to contribute to this - leading to common understanding and expectations around public sector information.  How can we categorise the innovative potential of the market and how can we unlock that potential?  Given the current trajectory of increasing volumes of public sector information being made available in ever more accessible formats, it seems reasonable to hypothesise that the larger part of the value to be generated from public sector information lies in the future. Much of this value may come from combining public sector information with information from other sources, such as details of consumer spending habits held by supermarkets and other retail firms, or details of domestic and commercial properties.  Many of these future uses may be extensions of the ways in which public sector information is already being used. For example, a recent study calculated that the benefit to the local government sector from the use of geospatial data was £232m over five years, through a variety of measures such as more efficient routes for waste collection. It is to be expected that such uses will become increasingly widespread throughout the public sector at both a local and central level, as more information becomes available, methods of harnessing this information are improved, and best practice becomes more widely adopted, thus increasing the value derived from public sector information.  Further benefits are likely to emerge for private individuals, business and other organisations as methods of exploiting public sector information are developed and improved.  In addition, there are likely to be benefits from wholly new uses of public sector information. Numerous additional possibilities for achieving such savings and improve policy may become apparent as more information is made available and expertise in its use increases. In addition, there are likely to be more 'blue sky' opportunities, such as those identified by the Government Office for Science. These are explored further in Chapter 5, but include improving management and resilience of food supplies, tackling obesity, and detecting and identifying infectious diseases. These require combining public sector information with other sources of information rapidly and making the resulting insights available to decision makers in a timely fashion to allow prompt responses to crises and informed policy decisions.  Addressing the barriers identified in this study will certainly work to unlock this potential, but it is hard to foresee specifically where innovation might take place in the UK. Often innovation takes place in areas which are hard to predict, with first-movers benefitting accordingly. Quite possibly, the next data innovators are already en-route to innovation on the back of public sectot information. ## 1. Introduction And Approach # This Introductory Chapter Sets Out The Scope Of This Report, Sets Out Its Approach And Provides An Outline Of Its Contents. Project Scope And Objectives The Department for Business, Innovation and Skills on behalf of Stephan Shakespeare has commissioned Deloitte51 to undertake an independent assessment of the market for public sector information, in order to establish a robust evidence base on its value and to highlight the policy implications flowing from an examination of how PSI could be utilised further. The Deloitte report forms the evidence base for the Shakespeare Review on public sector information. When published, the Shakespeare Review will consider the full breadth of the public sector information market, both current and future. It will consider how the private sector, civil society and general public uses and re-uses public sector information, as well as the potential benefits for how the public sector can use and re-use its own data.52 The key elements of the Deloitte market assessment include:  a **rapid evidence review** to inform the definition of public sector information, users and reusers and what the market looks like and could look like in the future;  a **desk-based data collection exercise** setting out what the current and latent market for public sector information looks like;  the construction of an **analytical framework tracing** based on the literature charting the routes of impact publication sector information can have;  an **'as is' market analysis of public sector information** in the UK, taking into account the suppliers and competitors, consumers, nature of competition, value chain, regulatory landscape, uses and re-uses of public sector information and identifying instances of market failure;  three case studies examining how public sector information is used and re-used in the private and public sectors. These include the health sector, use and re-use of public sector information within government, and a 'deep dive' into the use of public sector information in the transport sector;  high level quantitative analyses, where the data exist, assigning monetary estimates to the current and potential value of public sector information; and  identifying **policy implications** on the different challenges to maximising the full potential of public sector information. guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see Deloitte MCS Limited is a subsidiary of Deloitte LLP, the United Kingdom member firm of DTTL. This publication has been written in general terms and therefore cannot be relied on to cover specific situations; application of the principles set out will depend upon the particular circumstances involved and Deloitte recommends that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. Deloitte MCS Limited would be pleased to advise readers on how to apply the principles set out in this publication to their specific circumstances. Deloitte MCS Limited accepts no duty of care or liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication. This report takes as its starting point that the public sector is equivalent to Category O of the Standard Industrial Classification (SIC 2007) nomenclature - Public Administration and Defence; Compulsory Social Security. However, when appropriate, public bodies outside this category (e.g. health, transport and education) are considered and included. The report covers all levels of government: UK, devolved, regional and local. Where appropriate, it also considers the international dimension. Approach This report has adopted Deloitte's standard five-stage methodological approach to develop the evidence base. Source: Deloitte This final report concludes the research. Data sources There is a paucity of data around public sector information in the UK making it difficult to generate accurate figures on the size, value and potential of public sector information. This notwithstanding, data on public sector information and other proxies has been collected from the following sources:  web-based PSI portals such as data.gov.uk and local government data stores and other statistical agencies such as National Statistics;  existing literature on public sector information including the Open Data White Paper, Deloitte research, studies by academics and other public bodies such as the Office of Fair Trading (OFT);  conversations with public sector information stakeholders such as the Open Data User Group, the Trading Funds, regulatory bodies, government departments, business users and reusers and consumers;  annual reports of public sector information suppliers such as Trading Funds and departmental open data strategies;  internal Deloitte research that draws on client experience and the use and re-use of public sector information;  international comparisons such as from the EU, Australia and the USA. As set out in Figure 1.1 this data was primarily collected between November and December 201253. The approach to data collection has been to focus on gaining an overview of the public sector information market at the broadest level, covering the widest possible range of issues and underlying trends, noting that primary research was excluded from the project's terms of reference. Accordingly, all model results and data analysis should be read in conjunction with the relevant caveats. Structure of this report This evidence base contains all of Deloitte's analysis for this research project and is structured as follows:  Chapter 1 - Introduction and approach: outlines the scope of this project and Deloitte's broad approach to the research;  Chapter 2 - Public sector information definitions and market definition: considers the different definitions used for public sector information and goes on to discuss how public sector information varies across a number of dimensions;  Chapter 3 - The supply and demand sides of the public sector information market: provides an overview of PSIHs and some statistics on the supply of datasets, before moving to examine how the datasets are used and re-used by businesses, individuals, community groups and the public sector;  Chapter 4 - The regulatory landscape for public sector information: contains an overview of the different regulations, guidelines and pieces of legislation that govern the operation of the public sector information market;  Chapter 5 - The current value of the public sector information market: presents the report's calculations of the economic value of the market currently, as well as a series of case studies that highlight the wider social value of public sector information;  Chapter 6 - Barriers to maximising the value of public sector information and their policy implications: discusses the identified challenges to maximising the value of public sector information in the UK; and  Chapter 7 - Conclusion: contains some closing thoughts on the subject. The report's appendices provide further methodological and analytical background. These are:  Appendix 1 - glossary: setting out the terms used in this research  Appendix 2 - acronyms used in this research  Appendix 3 - literature review: considers previous research in this area;  Appendix 4 - further statistics: in particular on the Trading Funds that make up the Public Data Group;  Appendix 5 - empirical methodology: provides a full description of the assumptions and approaches underpinning quantitative estimates;  Appendix 6 - transport detailed case study: contains additional details on the transport centre case study methodology;  Appendix 7 - other case studies: additional details on various case studies conducted for this research;  Appendix 8 - results from an informal Government Officials survey; and  Appendix 9 - bibliography. ## 2. Public Sector Information Definitions And Market Definition A key foundation stage in any market analysis is to establish which products and services constitute the market under discussion. An effective definition of public sector information and the parameters of the market provide a strong framework for further analysis. Definition of public sector information Since their establishment, public bodies across the world have generated and retained a wealth of data and information. The scale and range of this information can be overwhelming, as the following examples demonstrate54:  HM Revenue and Customs interacts with over 40 million customers;  UK departments, agencies and other public bodies procure over £243 billion worth of goods and services;  around six million people work in the public sector, each of whom has a record on performance, sickness absences, skills and years of service; and  each year nearly 700,000 students make 2.7 million applications to university. This data and information is typically collectively referred to as public sector information. However, definitions of public sector information can, and do, vary. A review of the literature suggests that there are a number of definitions in current use globally. | Definition | Source | |-------------------------------------------------------|--------------------------------------------| | Re-use of Public Sector Information Regulations | 2005 | | (SI 2005/1515), Reg.4(2) | | | 55 | | | | | | Information and data collected, reproduced and | | | disseminated by the public sector covering many | | | areas of activity, such as social, economic, | | | geographical, weather, tourist, business, patent and | | | educational information. | | | OECD, | Recommendation of the Council for Enhanced | | Access and more Effective Use of Public Sector | | | Information | [C(2008)36] | | 56 | | | | | | Information, including information products and | | | services, generated, created, collected, processed, | | | preserved, maintained, disseminated, or funded by or | | | for the Government or public institution, taking into | | | account the relevant legal requirements and | | | restrictions. | | | OFT, | The Commercial Use of Public Information | | (CUPI), [OFT861] | | | 57 | | | | | | Information, data or content collected by and/or held | | | by a public body. The information may or may not be | | | | | | Definition | Source | |----------------------------------------------------------|--------------------------------------------| | Crown copyright information. | | | Office of the Australian Information Commission, | | | Principles on open public sector information: Report on | | | review and development of principles | , (May 2011) | | 58 | | | | | | Material with the essential purpose of providing | | | Government information to the public. Material with | | | the essential purpose of artistic expression is unlikely | | | to be treated as PSI for the purpose of the policy. | | | Pollock, R, | The Economics of Public Sector Information | | (2008) | | | 59 | | | | | | Information held by a public sector organisation, for | | | example a government department or, more generally, | | | any entity which is majority owned and/or controlled by | | | government. | | Note: in some cases the original definition has been summarised for purposes of brevity As Figure 2.1 demonstrates, definitions of public sector information fall across a continuum ranging from all information and data generated, held and disseminated by the public sector (content agnostic) to the definition of public sector information explicitly covering certain types of data and information (content specific). Importantly, all definitions are neutral with respect to the format of public sector, whether it is qualitative or quantitative, structured or unstructured and whether or not it is subject to user fees60. For the purposes of this report, public sector information is defined as covering the wide range of information that public sector bodies collect, produce, reproduce and disseminate in many areas of activity while accomplishing their public tasks. This is consistent with the recently published glossary of terms by the Advisory Panel on Public Sector Information (APPSI)61. This report acknowledges that this definition is not entirely uncontested. In particular, there is debate over when particular public sector information datasets become value-added services rather than information and data. For example, Deloitte has heard views that the above definition of public sector information is too narrow and fails to capture intangible advice given out to customers that draws upon public sector information, but of which no record is kept62. However, these reservations notwithstanding, the above remains a reasonable working definition for the purposes of this evidence base and allows some parameters to be set around the analysis. It is important to note that for the purposes of this report, as is conventional practice, the term information (output of such processes that summarise, interpret or otherwise represent data to convey meaning) is taken to include data unless otherwise specified. Definition of the public sector A corollary of defining public sector information is the need to define what is meant by the public sector itself. At the most simplistic level, the public sector can be defined in reference to the Standard Industrial Classification (SIC) codes; where the public sector is Category O of SIC(2007) covering 'public administration and defence; compulsory social security'63. While this is a useful starting point it does not capture other activities that might reasonably be considered as part of the public sector such as education, health and transport services as well the public funding of other activities such as the arts and other cultural bodies. There is some debate as to whether data and information produced by cultural centres, such as museums and libraries, should be considered public sector information, especially in cases where these receive public subsidy. For the purposes of this report cultural institutions are considered to lie within the public sector, unless otherwise specified64. For similar reasons, while not part of the public sector, private and third sector contractors providing public services may be considered as producers of public sector information. Universities and schools although not within the scope of the PSI Directive are significant in public sector terms and are included in the definition of the public sector for the purposes of this report. Thus, for the purposes of this report, the public sector is taken to refer to include (but not necessarily be limited to):  national and devolved government (Ministerial and non-Ministerial) departments and their executive agencies;  Non-Departmental Public Bodies;  the National Health Service;  the Judicial Service;  the Armed Forces and Police Service;  Public Corporations and Trading Funds;  Independent Panels and Inquiries; and  Local Authorities. In reality it is difficult to clearly define the boundaries of the public sector and the above list is not exhaustive, but is deliberately broad to capture the wide range of public sector actors, ranging from the departments of state, to the BBC and the NHS, through to local borough councils. The nature of public sector information As defined above, the term public sector information captures a vast range of information and data gathered from diverse sources, for a wide range of purposes, and stored in many different formats, with the single unifying feature that it is collected by public sector bodies. It includes data gathered intentionally, the collection of which may be one of the organisation's main tasks; and information gathered incidentally while performing other functions. Public sector information thus has a number of dimensions, as set out below ## Figure 2.2: Public Sector Information Dimensions Public sector information can be categorised along a number of non-competing dimensions:  whether the public sector information is made available to the general public and, if so, under what conditions (if any);  the complexity of the dataset in terms of the number of records and variables, whether it is anonymised or aggregated or is quantitative or qualitative (its verbosity);  how often the dataset is updated or replaced (its velocity);  whether the public sector information is generated or collected as part of an public body's public task or whether its generation is the result of other activities not related to public sector information;  the content of the public sector information dataset;  the electronic or non-electronic format of the dataset;  the ways in which the public sector information dataset is distributed; and ##  The Cost Of Generating/Collecting/Maintaining/Updating The Public Sector Information Dataset. Source: Deloitte analysis The following section defines these dimensions and explores each in more detail. ## The Availability Of Public Sector Information It does not automatically follow that public sector information will always be made available to the public or outside the public sector body that originally collected/generated it. Equally, it may not be made immediately following its collection. For example, some data releases are not made public immediately to avoid risking public safety, e.g. some Met Office data, which must be validated to ensure it is correct; this is contrast to certain economic statistics which can be revised over time. Figure 2.3 below summarises how public sector information can be retained and disseminated. ## Figure 2.3: Public Sector Information In The Uk Source: Deloitte analysis It is important to highlight that public sector information released as open data is a sub-set of the total public sector information market. To recall, public sector open data is data that has been made available free of charge for anyone to use as they wish and meets the criteria of being accessible, in a digital, machine readable format and free of restrictions on use or redistribution. The 'open definition' is "a piece of data is open if anyone is free to use, reuse, and redistribute it - subject only, at most, to the requirement to attribute and/or share-alike" 65. The data portal data.gov.uk contains a wealth of public sector open data66 covering a range of topics ranging from data on tariffs67 to homelessness statistics68. Examples of data only available to the general public under terms and conditions or for a fee include the National Pupil Database and subscriptions to specialist statistics by the Office of National Statistics69. Data currently collected by the public sector, but not made widely available outside the public sector, include many national security information datasets. The Open Government Licence70 sets out the conditions under which individuals and users can use and re-use PSI - though not all data and information available under the OGL this meets the open data criteria (i.e. it may not be in a digital machine readable format). This report discusses the regulations around public sector information in more detail in Chapter 4. ## The Complexity Of Public Sector Information The level of detail of a public sector information dataset is referred to as its verbosity, with more complex, larger datasets being more verbose. Verbosity may be a function of the number of variables contained in the dataset, the number of records it holds and the time period it covers. Public sector information datasets can either focus on aggregated data or be at an individual unit level - the unit can vary between individuals, social groups, businesses, industries, economic sectors and so forth - the more disaggregated, the more verbose. The size of public sector information datasets can also vary considerably, with only a small proportion being truly classed as Big Data, although this may not always be reported in the statistics. For example, the Companies House dataset is substantially larger than, say statistics on football banning orders, but both are counted as a single dataset by the official statistics. Equally, the Met Office supplies around 200Mb data per day to data.gov.uk, but this is contained in just three large datasets. The size of individual datasets also has implications as to how it is distributed (see below). ## The Speed At Which Public Sector Information Is Updated It is important to distinguish between public sector information that exists in a relatively static form, and public sector information which is continually updated. The frequency with which a public sector information dataset is updated is known as its velocity. In some cases, public sector information datasets will only be updated infrequently, perhaps annually or, in the case of the Census, every ten years. Typically, updates are made when an additional cohort of data is available and the original dataset is extended to include this new data. Examples of such datasets include information on departmental expenditure, educational attainment of GCSE students, or numbers of welfare claimants - all of which are updated with supplemental data at certain intervals (the time series expands). Other public sector information datasets may also be updated periodically, but these updates replace existing datasets (there is no time series of data) - such as the case of economic forecasts where the latest forecast supersedes the previous one. Other types of public sector information, however, are updated on a daily, hourly or on an even more frequent basis and the usefulness of the public sector information is directly related to how up-to-date it is. For example, Transport for London provides live travel information meaning that updates on disruptions and delays, as well as bus and tube departure times, are updated in real time. In these instances the need for the data to be regularly refreshed becomes of the utmost importance, as historic data may have relatively little value. The updated dataset further needs to be disseminated to users rapidly and in an appropriate format. This is commonly achieved through an application programming interface, or API, which allows updates to be embedded in a webpage, programme or mobile application. This information can be characterised as having a high velocity. The distinction between the velocity of different public sector information datasets is significant because the speed at which datasets are updated can impact their end use, methods of dissemination and the level of commitment required from the PSIH. High velocity public sector information is often collected by an organisation dedicated to that purpose, as in the case of the Met Office and weather information. Given the time-sensitive nature of high velocity public sector information, users are likely to demand a higher quality of service and assurance that the public sector information will be up-to-date. ## Public Sector Information As A By-Product Or Purpose-Collected In some cases public sector information is generated in the course of a public sector body's other activities, rather than the information being generated or collected as its core activity. This is known as 'by-product' or 'exhaust' data or information. This applies, for example, to the data contained in the National Pupil Database; Home Office statistics on crime; salary information for employees of public sector bodies; and details of public expenditure. The Department for Education collects data on students in the course of its regular activities but the collection of this data is not its primary purpose - it arises from, and facilitates, other activities. The same may be said for salary information published by government departments: the data is generated in the course of employing people to undertake the range of functions required of the department. The fact that this public sector information is a by-product of an organisation's public task does not necessarily imply that its value to users is in any way reduced. Nor does it mean that its collection and dissemination is cost-free. There may be costs incurred in processing, storing and disseminating the public sector information71. However, the cost of collection is generally thought to be lower than purpose-collected data, since the public sector information is generated by activities which would have taken place regardless of whether or not the public sector informat was collecte 72 ion d . In other cases, the collection of public sector information is the purpose of a public sector organisation's activities and even its existence (part of its public service remit). This is the case, for example, with Ordnance Survey. In these cases the public sector information has been identified as desirable in its own right. It is also likely that this public sector information will be highly valued by users, since it has been actively identified as worth the cost of collection. The distinction between public sector information as a by-product of other activities and public sector information that is purpose-collected is therefore significant, since it suggests differing costs of collection and perhaps also different user profiles and, potentially, value. ## The Content Of Public Sector Information Public sector information can also be categorised on the basis of content. These content categories broadly follow the activities of the PSIH in question and cover all aspects of the UK's economic, social and cultural activities. In addition to specific datasets relating to the activities of their staff and agencies, all PSIHs will also be generating public sector information in the form of operational data and information covering the administrative and logistical activities of public sector actors such as budgets, organisational charts, HR statistics and pay scales. Some examples of public sector information content categories are shown in Figure 2.4. Source: Deloitte analysis Where public sector information datasets contain personal information they may be anonymised or non-anonymised - if the latter, they are subject to restrictions on their release. ## The Format Of Public Sector Information Public sector information can be downloaded in a wide variety of electronic file formats. At the time of writing, there were nearly 50 different formats of electronic files available for download at data.gov.uk (a reasonable proxy for public sector information currently available to the general public, although certainly not a comprehensive source) - a number of which are proprietary formats such as .pdf and .xls (even if the software readers are readily available). The ten most popular file formats (constituting around 96 per cent of all datasets) were: | File type | Number of datasets (27 | |----------------|--------------------------| | th | | | February 2013) | Percentage of total (27 | | th | | | February 2013) | | | .csv | 2423 | | .xls | 1624 | | .pdf | 588 | | .html | 461 | | .rdf | 191 | | .xml | 189 | | .zip* | 123 | | .wms | 69 | | .doc | 59 | | .txt | 52 | Source: Deloitte analysis *Once unzipped, the file could be any of the above other files. Figure 2.4 refers to the format of public sector information currently available online at the time of writing on data.gov.uk73. However, it is likely that there is public sector information currently retained (or even collected) by the public sector which has yet to be digitised and is not available electronically (such as archive and historical material74). This public sector information may or may not be accessible to the general public, but can only be provided in hard copy or cannot be removed from site. In addition, much public sector information is released in the form of an API75. This allows developers to embed a data source in a webpage, programme or mobile application, allowing for updates to the data. Prominent examples of public sector information APIs include Transport for London, which provides live travel updates delivered via a webpage or mobile applications, and the Met Office weather information, which is periodically updated with the latest data. Star rating of public sector information Related to the issue of format is the usability of the dataset. There are different ways in which usability can be measured, and they are, to some extent, subjective. One of the more common methods is the Open Data five-star scoring mechanism suggested by Sir Tim Berners-Lee, which is used by data.gov.uk. | Score | |---------------------------------------------------------------------------| | | | Make your stuff available of the Web (whatever format) under an open | | licence | | | | Make it available as structured data (e.g. Excel instead of image scan of | | a table) | | | | Use non-proprietary formats (e.g. CSV instead of Excel) | | | | Use URLs to identify things, so that people can point at your stuff | | | | Link your data to other data to provide content | Source: http://5stardata.info/ At the time of writing data.gov.uk has recently begun to provide data on the proportion of datasets attaining each star rating (currently in beta form). These figures indicate that, at the time of writing, nearly a quarter of datasets have attained a three-star rating. Only one per cent of datasets have been given a five-star rating, indicating they are linked data. Over 50 per cent of datasets have attained no stars - though this is due to many datasets not yet being rated76 or the link referring to data such as live mapping services (for which a rating has not yet been agreed as they are not strictly data). | Score | Description | |--------------------------------------|----------------| | Number of datasets (27 | | | th | | | | | | February 2013) | | | Proportion | | | TBC | N/A | | 842 | 9% | | No stars | | | Unavailable | 5117 | | | | | Unstructured data (e.g. PDF) | 163 | | Structured data but proprietary | | | format (e.g. Excel) | | | 826 | 9% | | | | | Structured data in open format | | | (e.g. CSV) | | | 2004 | 22% | | | | | | | | N/A | N/A | | 77 | | | | N/A | | | | | Linked data - data URIs and linked | | | to other data (e.g. RDF) | | | 107 | 1% | | Source: wwww.data.gov.uk/data/search | | ## The Distribution Channels Of Public Sector Information The analysis undertaken for this report suggests that the key distribution route of public sector information by suppliers (or originators) is through websites78. The next chapter considers in more detail the different websites from which public sector information is assessed, but broadly speaking the ways in which public sector information is accessed and disseminated in the first instance are:  through **viewing** the public sector information online on a webpage;  through **downloading** the public sector information from a webpage;  through an API embedded in an app or webpage;  via secure terminal facilities or **virtual laboratories** to view the data79;  other **published versions** of the work; and  through **requesting** the public sector information via a webpage, telephone or other written request. The public sector information may be sent via email, an encrypted link, CD or DVD or hard copy. Often the latter case is imposed for public sector information datasets that are too large to efficiently host online, that contain sensitive personal data or are subject to copyright conditions and which can only be released upon the receipt signing licensing terms and conditions. For example, given the nature of the data and information contained within it, the National Pupil Database can only currently be shared with researchers following the signing of specific terms and conditions. It should be noted that in any case this data can only be shared where there is a statutory gateway to permit this (as is the case with the National Pupil Database). ## The Cost Of Public Sector Information Public sector information differs in terms of cost. For certain types of public sector information the marginal cost of generation/collection may be relatively high (compared to dissemination) if this data is being collected specifically. Examples of the former include the geospatial data collected by Ordnance Survey, which requires use of aircraft and personnel on the ground. On the other hand the data collected by Transport for London arises from its day to day operations, and producing this data requires relatively little investment of resources beyond the infrastructure already in place to support operations, meaning that there is a low marginal cost of generation - although the costs of dissemination may be higher. The public sector information cost lifecycle components are shown below. Source: Deloitte analysis. Costs of acquisition may also include purchasing third party data that is combined with public sector information Public sector information can be released to the general public at different parts of the cost lifecycle - PSIHs do not necessarily have to wait until the public sector information has been cleansed (data assured) and formatted into refined data before they more widely disseminate it. The marginal cost at each point of the lifecycle will differ, e.g. the marginal cost of dissemination may be very different to the marginal cost of collection. PSHIs can release public sector information prior to cleaning as unrefined or raw data. How public sector information is funded is discussed in more detail in subsequent chapters. Where public sector information datasets do carry charges these can be in form of one-off fees, ongoing subscription fees or a royalty model. Having defined public sector information, the next section considers its market definition. Market definition Before considering the actors on the supply, intermediary and demand sides of the market, a preliminary analytical step is to define what is meant by the market for public sector information. As set out by the OFT in its guidance for market definition80, the process of defining a market typically begins by establishing the closest substitutes to the product or service in question. These substitute products are the most immediate competitive constraints on the behaviour of the organisations supplying the product or service in question81. As highlighted in an earlier chapter, in the case of public sector information the market definition exercise is complicated by the fact that different public sector information datasets vary substantially by content, quality, size and format. As discussed in previously, at a first glance, the overwhelming majority of public sector information is provided by the public sector through PSIHs. However, it is not enough to stop at the PSIHs when considering who the suppliers of public sector information are - there may be substitute suppliers outside the public sector. Figure 2.10 highlights a selection of public sector information datasets, their suppliers and potential substitutes. | Public sector information dataset | Public sector supplier | Potential substitute supplier (if | |---------------------------------------|-------------------------------------|--------------------------------------| | any) | | | | UK mapping data | Ordnance Survey | Google Maps, Open Street Map | | Meteorological data such as weather | | | | forecasts | | | | Met Office | Various private sector suppliers or | | | overseas suppliers and academic | | | | institutes | | | | None currently | Economic statistics | National Office of Statistics, | | Bank of England | | | Source: Deloitte analysis What this short comparison shows is that the presence of alternative suppliers varies with content, with some types of content being more readily substitutable: this could include mapping data or meteorological data. Of course, whether Google Maps is an effective substitute for Ordnance Survey will depend on whether consumers regard them of substitutable quality. This can be tested through the so-called hypothetical monopolist test83. In this case, taking the Met Office as an illustrative example, the question would be whether the Met Office could profitably raise prices for meteorological data by 5-10 per cent above competitive levels. If the answer is yes, then the test is complete and the market for meteorological data solely consists of the Met Office. If the answer is no, then this is due to consumers switching to other substitute products such as rival suppliers of meteorological forecasts (assuming they exist). In this case, the hypothetical monopolist test is repeated, assuming the Met Office also controls overseas suppliers. If it can profitably raise prices by 5-10 per cent then the market is defined; if not, the process is repeated with more substitute suppliers until the market is defined. The ability of this report to carry out an empirical hypothetical monopolist test has been constrained by a lack of elasticity data on potential public sector information substitutes. Further it is not practical to carry out the test for the thousands of different public sector suppliers of public sector information. Accordingly, as a working market definition, this report broadly defines the market for public sector information as including only public sector suppliers, unless there are strong reasons to include other non-public sector suppliers (this may be the case for certain types of geo-spatial and mapping data). The geographic market definition is restricted to the UK. Chapter summary  For the purposes of this report, public sector information is defined as covering the wide range of information that public sector bodies collect, produce, reproduce and disseminate in many areas of activity while accomplishing their public tasks.  For the purposes of this report, the public sector is taken to refer to (but not be limited to): o national and devolved government (Ministerial and non-Ministerial) departments and their executive agencies; o Non-Departmental Public Bodies; o the National Health Service; o the Judicial Service; o the Armed Forces and Police Service; o Public Corporations and Trading Funds; o Independent Panels and Inquiries; o Local Authorities.  Public sector information varies in terms of: o whether it is made available to the general public and, if so, under what conditions (if any); o its complexity in terms of the number of records and variables, whether it is anonymised or aggregated or is quantitative or qualitative (its verbosity); o how often it is updated or replaced (its velocity); o whether it is generated or collected as part of an public body's public task or whether its generation is the result of other activities not related to public sector information; o by its content; o its format; o the ways in which it is distributed; and o the cost of generating/collecting/maintaining/updating it.  This report broadly defines the market for public sector information as including only public sector suppliers unless there are strong reasons to include other non-public sector suppliers. The scope of the analysis is restricted to the UK. ## 3. The Supply And Demand Sides Of The Public Sector Information Market This chapter provides an overview of the supply and demand sides of the public sector information market. It provides statistics around the supply of datasets and profiles the different types of public sector information holders (PSIHs). The chapter then moves to consider intermediaries and the final consumers on the demand side of the market. It looks at the public sector information value chain, different business models in operation and the ways in which public sector information is currently used and re-used. Supply side of the market As highlighted in the preceding chapter, public sector information is collected and/or generated by thousands of organisations across the public sector - so-called Public Sector Information Holders (PSIHs). These PSIHs can be found in UK, devolved, regional and local government, as well as other public sector bodies such as the armed forces, police force, NHS, universities and others named in Chapter 2. ## Supply Of Datasets Nationally When considering the identity of the main suppliers of public sector information it is important to distinguish between PSIHs who hold the most information and PSIHs who make the most information available to the general public. As an example, the Ministry of Defence and the Security Services may potentially hold the largest amounts of public sector information of any PSIH, but they may be one of the smallest suppliers of information to the market (either as open data or under restrictions). Given the lack of robust data as to the overall size of the public sector information market (i.e. public sector open data + public sector information available under restrictions or for a fee + public sector information collected/generated not disseminated to the general public), this report can only seek to make an approximation as to who the largest suppliers of public sector information are in terms of information made available to the public. With respect to open public sector information84, at a national level, much of this public sector information is made available through data portals, specifically data.gov.uk (the single largest source of public sector open datasets). An analysis of this provides a useful, illustrative tool for assessing the most prolific suppliers of public sector information amongst PSIH. An initial assessment shows that of a total of 781 publishers (as of 27th February 2013), the top ten suppliers of PSI supplied over half of all datasets published on the website. The top ten data.gov.uk publishers are as follows: Supplier Number of open datasets (as of 27/02/13) Proportion of all datasets on data.gov.uk Office for National Statistics 84785 12% Department for Communities and Local Government 744 11% Health and Social Care Information Centre 589 9% British Geological Survey 379 6% Department for Environment, Food and Rural Affairs 331 5% Centre for Ecology & Hydrology 307 5% Welsh Government 241 4% Department of Health 240 4% Department for Children, Schools and Families 227 3% Home Office 213 3% Total 4,118 60% Source: Deloitte analysis of data.gov.uk The content of the datasets available on data.gov.uk is also summarised below. Source: Deloitte analysis of data.gov.uk The numbers in Figures 3.1 and 3.2 should be read carefully as they refer to the number of datasets only and by download links86. Furthermore, they do not take account of the velocity and verbosity of the information. As an example, as part of the evidence gathering process for this report, the Met Office has indicated that their daily submission to data.gov.uk amounts to around 200Mb of data, which undoubtedly makes them one of the largest suppliers of public sector information to data.gov.uk. However this importance is disguised by the fact that the data/information is contained in just three datasets87. It is therefore important to treat information on the number of datasets with a degree of caution: it is a reliable guide to neither volume nor value of public sector information. Nonetheless, as a first approximation, the analysis is useful to illustrate the long tail of PSIHs: whereas around half of all PSI datasets come from 10 PSIHs, the remaining datasets come from over 750 PSIHs. Moving away from data.gov.uk, open public sector information is also available from a number of other websites. Deloitte's recent research with the ODI has examined the number of open datasets types (rather than links) available across three major data portals: data.gov.uk, the ONS and data.london.gov.uk - this is shown below. The number of links / datasets in both Figure 3.2 and 3.3 is dominated by government spending information and data. In some senses this is unsurprising as this type of public sector information is likely to have relatively low cost of collection and dissemination for PSIHs, and is relatively easy for them to make available online on data.gov.uk, subject to any data redactions.89 PSIHs have also been incentivised to publish this type of public sector information under the Government's transparency agenda90. Other sources of public sector information available (at the time of writing) as open data include91:  Companies House - with one major free open dataset;  The Met Office - with 118 open data sets (listed on data.gov.uk);  Land Registry - with over 30 open data sets (available through data.gov.uk);  Data.london.gov.uk - with over 550 open data sets;  OS OpenData - with 12 mapping products that can be ordered online;  Open Data Communities - with over 70 open data sets; and  Legislation.gov.uk - with over 78,700 open data sets92. A separate statistics appendix93 provides further detail on datasets held by the four Trading Funds that make up the Public Data Group. Downloads and popularity of datasets Using data.gov.uk statistics again, it is also possible to examine the popularity of different public sector information open datasets in terms of page views. ## Figure 3.4: Data.Gov.Uk Dataset Normalised Page Views To Show Relativity, October 2012 Source: Deloitte analysis The equivalent chart for dataset downloads from a broader group of websites is shown below. As one might expect, business and economy datasets dominate, although this may simply be a function of the supply of these datasets exceeding those of other public sector information types. However, data on social conditions and transport also report high levels of relative popularity. Between July 2012 and January 2013 there were over a million total visits to data.gov.uk and over 3.7 million page views94. While this is a high level of traffic, many of these users would not have downloaded data (see below). In some cases this may simply have been due the visitor deciding they no longer wished to see the data or automated hits from web-trawlers. However, in other cases, this may be because individuals were unable to find the particular dataset they were looking for; or because they encountered broken links; or that they were transferred to the original PSIH's website to download the data rather than download it from data.gov.uk. Without a survey of users it is difficult to know the reasons why a visit ended with no dataset download. However, the National Audit Office found that 82 per cent of users left data.gov.uk directly from the homepage or data page, indicating that they may have not found the information they were seeking.95 Note, this was a snapshot figure in early 2012 and data.gov.uk continues to evolve. Figure 3.6 below indicates the most downloaded datasets from data.gov.uk between July 2012 and January 2013. In total there were over 80,000 downloads of datasets from data.gov.uk during this period.96 While this is a significant number, it means that at most eight per cent of visitors downloaded a dataset - and fewer if some users downloaded more than one dataset, as seems likely. Source: www.data.gov.uk/data/site-usage/dataset Of course, these statistics do not take into account views and downloads from other PSIHs websites and non-public sector PSIHs. Further, these statistics do not include public sector information sent to data.gov.uk but hosted on other platforms. For example, the Met Office data supplied to data.gov.uk is hosted by Microsoft Windows Azure Datamarket98 - approximately 250 million rows of data per hour is hosted on this service and it is estimated that there are currently over half a million transactions per month, on average. Nearly two thirds of these transactions come from outside the UK suggesting UK public sector information can also help generate growth overseas. Taking these into account, the numbers of total downloads of public sector information may be much higher. ## Supply Of Datasets Locally As well as open public sector information being available at the national level, consumers can download and access local open public sector information. The Local Government Association carried out a survey of local authorities in late 2012 ('Local Government Transparency Survey 2012')99 to examine the provision of data at a local level. 113 local authorities responded out of of 128 respondents to the survey (the total surveyed was 346). The chart below shows the types information that respondents reported they currently publish or plan to publish in the future (per cent). Source: LGA, 'Local Government Transparency Survey 2012' The data being made available by local government is often not published through a national data portal such as data.gov.uk. The survey revealed that of 104 respondents to the question, 14 per cent made information available through data.gov.uk and nine per cent through direct.gov. The table below shows the full responses to the question 'Where on the internet do you publish your open data/transparency data?' | Publication channel | Number | |---------------------------------------|-----------| | Per cent | | | responding | | | Dedicated open/transparency data page | 71 | | Directly within topic section pages | 53 | | Data.gov.uk | 15 | | Direct gov.uk (now disbanded) | 10 | | Publication schema | 23 | | Information asset inventory | 0 | Per cent Publication channel Number responding Other 10 9 Source: LGA, 'Local Government Transparency Survey 2012' Because local authority information is published through many different channels, it is difficult to get a sense of the number and types of users of the information that has been released. Nonetheless, the LGA survey offers some insight in this regard. There were 104 responses to the question 'Do others use your open data?' The answers reveal that 16 per cent of local authorities were certain that others used their open data, while nearly half believed they did not. 36 per cent were unsure, indicating that it is often difficult to track how many users of open data there are, especially where this does not require registration by users. 14 local authorities responded that they knew who used their open data. Their answers are shown in the table below, showing that local community groups are particularly significant users of local authority open data. However, given the small sample size, these results should be treated with some caution. | Users of open data | Number | |----------------------------------|-----------| | Local community groups | 7 | | Other councils/public services | 3 | | Individuals | 3 | | Local educational establishments | 2 | | Local charities | 1 | | Local businesses | 1 | Source: LGA, 'Local Government Transparency Survey 2012' ## Trading Funds Trading Funds are among the most visible PSIHs in the wider public sector information landscape, and are often the focus of attention in debates over both the value of public sector information and access for users100. While this report focuses on the wider public sector landscape, of which the Trading Funds are only one component, given the nature of the public sector information that the Trading Funds collect, as well as the debate over issues around access, it would be remiss not to separately consider their role in the supply of public sector information. While no Trading Fund is identical, collectively they occupy a special position in the public sector information landscape as bodies with a statutory requirement to fund their operations and meet their financial objectives from trading income. As such they are subject to a set of guidance documents, legislation and regulations and guidance that differ from most other public sector bodies. The key elements of this framework are described below (this list is not exhaustive and these do not exclusively apply to Trading Funds). | Regulation / guidance | |---------------------------------------------------------------------------------------| | Managing Public | | Money (MPM) | | The PDG Trading Funds are required to comply with the guidance on fees, | | charges and levies in Managing Public Money. The standard approach to setting | | charges for public services (including services supplied by one public sector | | organisation to another) is full cost recovery. This normally means recovering a | | 3.5 per cent real charge for the cost of capital. However, for services supplied into | | competitive markets, charges should be set at a commercial rate. | | Managing Public Money explains that the norm is to charge full cost for publicly | | provided goods and services. For commercial services, charges should be set at | | a commercial rate. Managing Public Money also explains that much information | | about public services should be made available either free or at low cost in the | | public interest. However, there are circumstances where charges are made. | | Public sector organisations can also charge for information which recipients | | intend to re-use. Managing Public Money explains that where data is supplied for | | re-use, the norm is to charge marginal cost. For value added data, and for all | | information supplied by Trading Funds, the norm is to charge at full cost plus an | | appropriate rate of return. | | European Union | | Directive on Re-use of | | Public Sector | | Information | | Under the 2005 legislation, charges for the re-use of information made by public | | sector bodies cannot exceed the cost of collection, production, reproduction and | | dissemination of documents; and a reasonable return on investment. | | The revision of this directive is proposing to move to marginal cost but allows for | | some exceptions. | | Information Fair | | Trading Scheme (IFTS) | | This sets and assesses standards for public sector bodies. It requires them to | | encourage the re-use of information and reach a standard of fairness and | | transparency. The National Archives use the IFTS to monitor the activities of the | | trading funds to ensure that they trade fairly, openly and transparently in | | information. The IFTS also covers other public bodies. | Source: Public Data Group, 'Approach to Charging' (December 2012) For clarity, it should be noted that Trading Funds have their own Trading Fund Order - statutory duties to charge are only in place for the Land Registry and Companies House, but the Trading Fund Order and Trading Fund Act set out the framework for all Trading Funds' operations. It is important to be clear that these guidance documents and regulations, and especially the requirement to recover costs plus 3.5 per cent, constrain the ability of the Trading Funds to change their underlying business models beyond a certain point. There are a number of Trading Funds currently operating in the UK, each arising out of distinctive historical circumstances and each with a very different purpose, remit and business model. Below, an overview of the four Trading Funds that constitute the Public Data Group (PDG) is provided. This draws on the work of the Shareholder Executive, December 2012102. | Land Registry | | |--------------------|--------------| | House | | | Status | | | Trading Fund | | | Statutory Body | | | Trading Fund | | | Statutory Body | | | Competitive | | | Landscape | | | 100% non- | | | competed | | | (statutory | | | monopoly) | | | 98% non- | | | competed | | | (statutory | | | monopoly) | | | Sources of | | | revenue | | | Registration | | | and search | | | customers pay | | | statutory fees. | | | Data users | | | fund | | | dissemination | | | costs. | | | Register users | | | fund data | | | collection through | | | statutory fees. | | | Value added | | | service users | | | fund product | | | development and | | | dissemination. | | | 99% non-HMG | | | 1% HMG | | | Public and | | | private | | | sector users | | | 100% non-HMG | 79% Core HMG | | 4% Competed HMG | | | 17% non-HMG | | (1) PSMA: Public Sector Mapping Agreements; OSMA: One Scotland Mapping Agreement Source: Shareholder Executive As described above, Trading Funds are required to generate their own revenue, which is to say that they do not in general receive centrally allocated funds. They are required to recover the full cost of service provision plus the cost of capital, set at 3.5 per cent. The exception is where Trading Funds operate in competitive markets, in which case they are required to price their services at market rates to avoid distorting competition. Even where Trading Funds provide information or services to public sector organisations, they 'sell' these at agreed rates. This is an important distinction, making the Trading Fund business models qualitatively different to that of other publicly funded PSIHs which provide 'free' services to public sector users (though certain services may be charged for). The Trading Fund model is intended to drive efficiency by forcing Trading Funds to hold down costs in the same way as a commercial business would do. Further detailed statistics on the amount of data being made available and under which charging models is provided in Appendix 4. | Trading Fund | Trading Fund | |-----------------------------|------------------| | Mix of: | | |  | | | | Non-competed and | | competed HMG | | | contracts; and | | | All products and | | | services are traded in | | | competed markets | | | (apart from OS | | | OpenData). | | |  | | | | Widely competed | | commercial (non- | | | HMG) contracts. | | | Data users fund data | | | collection, product | | | development and | | | dissemination. | | | Users of value-added | | | services pay for the | | | bespoke development | | | of services and the | | | transfer price of the | | | data, which is on the | | | same terms for all | | | parties. | | | HMG funds the core | | | underpinning national | | | infrastructure, research | | | and development | | | required for the national | | | weather, core climate | | | services and services to | | | defence. | | | Wholesale data users | | | fund their own data | | | dissemination costs. | | | Users of value added | | | competed services pay | | | for the bespoke | | | development of weather | | | services and the transfer | | | price of the data, which is | | | on the same terms for all | | | parties. | | | 43% PSMA, OSMA | | | (1) | | | | | | 43% other Chargeable | | | incl. Private Sector | | | 14% OpenData™ (for | | | private and public sector | | | innovation) | | ## Attitudes And Policies Of Public Sector Information Holders As part of wide-ranging stakeholder consultations, Deloitte conducted an informal consultation of Government officials across national departments to seek to develop indicative estimates of the amounts of public sector in amounts of public sector information currently held and currently made available and understand some of the challenges currently faced. Full details of the consultation and its results can be found in Appendix 8103. The most important findings from the survey included:  departments currently vary significantly in the amount of public sector information they make available to the public; o around a third of respondents to the informal survey indicated that up to a quarter of public sector information held by the department (and in some cases its executive bodies) was currently being made available to the public. Other respondents were unable to give estimates  of the public sector information made available to the public, all respondents said it was available either entirely free of charge or at least 75 per cent was available at no cost; and  33 per cent of respondents report that less than five per cent of their staff were dedicated to data collection, processing and dissemination (though a much higher proportion would be involved as part of their wider duties), while 50 per cent were unable to estimate the proportion. The exceptions were dedicated statistical bodies, which owing to their nature employ many more staff dedicated to data-related functions. All respondents indicated that their PSIH planned to make more public sector information available to the public over the next 12 months, as set out in departmental open data strategies. The officials consulted in this informal consultation work with public sector information issues on a regular basis and are likely to have had a high degree of awareness of public sector information issues. A recent survey by Listpoint104 surveyed a wider number of civil and public servants to examine levels of awareness of the benefits of open data and public sector information initiatives. The key highlights are shown below:  78 per cent of those surveyed did not know about government plans for open data and the benefits that follow;  57 per cent of those surveyed did not know how to access datasets, how to interpret them or how to best apply data standards;  Over 75 per cent of those surveyed did not know their role in delivering the open data agenda; and  72 per cent recognised that knowing how to access, share and use data will be increasingly important over the next three years. Again, it should be noted that there may an element of self-selection in the survey results. ## Demand Side Of The Market Consumers on the demand side of the public sector information market can be divided into two broad categories based on whether they use or **re-use** public sector information. Use of public sector information refers to exploiting the data and information in a way that is commensurate with the original purpose within which the public sector information was produced. An example might be using economic statistics produced by the ONS to inform economic policymaking and investment decisions. In contrast, re-use of public sector information refers to the use of the dataset in a way other than the initial purpose for which it was collected/generated. An example might be correlating data on environmental and atmospheric conditions to the academic performance of school children. Clearly, the distinction between use and re-use is not hard and fast, as some aspects of use could be interpreted as re-use. Ultimately, when considering final consumers, almost every inhabitant of the UK is, at some point, a downstream user of public sector information in some form or other - often indirectly where the data is an input into another value-added service or product. This might be through a transport information or weather forecasting mobile app, an Ordnance Survey map, or another product that relies on public sector information to function. The different types of consumers of public sector information can be charted to form a circular value-chain. As Figure 3.12 highlights, the role of intermediaries in making public sector information accessible to a wider audience is currently crucial. One might expect that as general awareness of public sector information increases and the capacity to perform analysis directly increases, the role of intermediaries may diminish. Source: Deloitte analysis The supply of public sector information out of PSIHs is not a one-way street - consumers and infomediaries can request more datasets to be released via the data.gov.uk request mechanism105. As discussed above, there is a paucity of statistics on public sector information users and re-users. The following sub-sections present the available statistics on use and re-use in terms of download statistics, consumers perceptions of the market, different business models in operation and a profile of the emerging data scientist role. ## Public Sector Information Use And Re-Use Download and usage statistics One approach to measuring the extent to which public sector information is re-used is to consider the number of apps that take currently available public sector information as an input. Figure 3.13 below charts the number of mobile apps that use public sector information as a direct input from data.gov.uk by content category. One might infer that these apps could not have been created in the absence of these public sector information datasets. Source: Deloitte analysis of data.gov.uk data using Google Analytics What is particularly interesting in Figure 3.14 is that the most viewed datasets on data.gov.uk (as shown in Figure 3.2) do not entirely correspond with those that are most used to develop apps. Figure 3.14 compares page views to dataset apps. Source: Deloitte analysis of data.gov.uk data using Google Analytics Public sector information covering transport is clearly the most popular both in terms of page views and number of apps developed, with government operations data, personal finance information, housing, crime and justice, geospatial and education also attracting high levels of attention. Statistics from data.gov.uk on the page views received by publishers on the site indicate that the Office for National Statistics has received by far the most attention from users, with over three times the views of the next most viewed publisher, DCLG. This is only partially a consequence of the fact that the ONS is the most prolific publisher on data.gov.uk, and suggests that ONS datasets are particularly interesting to users. ## Figure 3.15: Data.Gov.Uk Most Viewed Publishers (July 2012 - January 2013)107 Source: Deloitte analysis of http://data.gov.uk/data/site-usage/publisher Data.gov.uk statistics on the most downloaded datasets give some indication as to which information users believe holds the most value and may also indicate where PSIHs should focus their efforts in improving quality and access. Interestingly, many of the datasets in the list of the top 20 most downloaded fall into one of the areas that this report identifies as areas where public sector information offers particularly promising potential for generating value (see Chapter 5), including:  transport, especially for roads - live traffic data, traffic counts, road safety;  health - the GP prescribing data has obviously attracted a high level of interest following the Mastodon C work;  property - prices and energy efficiency; and  social research - low income students in higher education, social trends, average earnings. Source: www.data.gov.uk/data/site-usage/dataset Again, it should be noted that the analysis refers only to open data available on data.gov.uk and therefore misses public sector information from PSIHs such as the Met Office or Land Registry as well as non-public sector PSIHs. The review of the Trading Funds in the Public Data Group above suggests the different ways their data is used and re-used. Use of public sector information across different sectors of the economy Another way to consider the public sector information demand side is to explore the use of all types of open data (public sector information and private sector and individual open data) across different economic sectors. Building on existing analysis by Deloitte, it is possible to create a data intensity matrix which compares the use of different types of data by industries in the UK109. Figure 3.18 shows this report's estimates as to which economic sectors most consume different types of open data. It shows, as might be expected, that businesses in the agricultural, forestry and fishing sectors are major users and re-users of agricultural open data, but they also use/re-use geospatial, environmental and energy, resources and utilities data. Source: Deloitte analysis The x-axis charts the different sectors of the economic and the y-axis different types of public sector information. The width of each economic sector columns compares the relative 'consumption' of open data of each sector. For example, 'public admin and defence, compulsory social security' (i.e. the public sector) consumes over 10 per cent of all data and of this figure, 5 per cent of its consumption is on transport data, 5 per cent on social conditions data, etc. As Figure 3.17 suggests, the construction, real estate, financial and insurance, public sector and arts, entertainment and recreation sectors are some of the largest users and re-users of open data. While this analysis has been carried out on the basis of open data, one might hypothesise that a similar picture holds for public sector information. ## Consumer Perceptions Of Public Sector Information And Unmet Demand In order to gauge consumer perceptions and the unmet consumer demand for public sector information, Deloitte has undertaken an analysis of publically available requests for information and data on two data portals: data.gov.uk and the London Datastore. Both these portals allow users to lodge requests for additional types of public sector information. For a number of reasons, these results should be treated as indicative only: the sample size is small and inevitably self-selecting. It is likely that there are many more potential users who have not engaged with the data portals. Nonetheless, this analysis provides an indicative insight into the types of public sector information that users are interesting in gaining access to, as well as the uses to which this public sector information might be put. Data.gov.uk requests This analysis is based on 100 requests posted publically on data.gov.uk between 26 September 2012 and 18 November 2012. As of the end of November 2012 there were 472 requests posted publically on data.gov.uk; however, the detail contained in the requests was much reduced after the first 100. For this reason the 100 most recent requests are used as the sample for this analysis. ## Figure 3.18: Usage Categories Cited In Data Requests (%)110 Source: Deloitte analysis of data.gov.uk data requests: based on 100 requests The requests in the sample most commonly cite business use and research as the intended use for the public sector information, at around 50 per cent for each of these categories. In terms of the data categories requested, it is location (or geospatial) data that tops the list of requests. This reinforces the impression that this category of data generates some of the highest levels of value - or at least that this is where users perceive value to lie. Environment, transportation, health and society are also data that attract particularly high levels of requests. Requests for data used to scrutinise and hold government accountable, such as government, finance, policy, administration and spending data are significantly lower, suggesting that this attracts less interest. However, even in these categories the numbers of requests are not insignificant. Of the specific barriers cited in accessing public section information, data format and financial charges are the most commonly mentioned - though these are both behind the 'other' category. The large majority of requests are generated by private individuals and business, at 41 per cent and 39 per cent of the sample respectively. The most commonly cited data holders are 'unknown' and 'other public body', suggesting that users may be unclear where the data they seek is held. Government departments are cited in 19 per cent of requests, although this category covers a large range of PSIHs. Sour The Open Data User Group has recently launched a new dashboard on data.gov.uk, providing a 'roadmap' of data requests. This promises to make the volume and nature of requests more transparent and easier to analyse. As the volume of data on requests increases, this should offer additional insights into the types of data that users and potential users would like to access, and the barriers they face. London Datastore requests A similar analysis is present below using data requests from the London Datastore. The sample size for this analysis is 50 of the data requests with the most 'wants' on london.data.gov.uk, out of a total of at least 870 published requests (as of 14 December 2012). The website allows users to vote for requests by adding 'wants', which function in a similar manner to 'likes' on Facebook. The dates of the requests included in the analysis run from February 2010 to August 2012. The option to submit a request is currently closed: the website notes: "please note we have temporarily suspended the dataset suggestion function as a result of recent spamming activity on the site." Indeed, the majority of the most recent submissions appear to be spam. Many of the datasets requested are now available, suggesting that the London Datastore has been responsive to requests (although it is possible that these requests overlooked already published data, or that its publication was already planned). Although the sample is small and some of the requests are over two years old, these requests provide an indicative insight into the sorts of data to which users and potential users would like to gain access. Note that some of the requests cite more than one usage category and data category, meaning that in these cases the sum of the responses is greater than the sample size. As with data.gov.uk (and reflecting particularities in London), transport is the most commonly requested type of data, at 40 per cent of requests, with demographic data the second most common at 22 per cent. This is likely to reflect the high perceived value of these types of data, particularly on a local level, as witnessed by the rapid increase in the number of mobile apps available that use Transport for London data. Source: Deloitte analysis of London.data.gov.uk data requests When the number of 'wants' received by request is analysed, transport data is even more popular, with 50 per cent of 'wants' in the sample. This is testament to the perceived value of transport data to users - although it may also reflect lack of awareness as to the possibilities offered by other, less obviously valuable types of data. Source: Deloitte analysis of London.data.gov.uk data requests ## Public Sector Information Customer Types While this report has not conducted in-depth primary research to explore the details of how different customers use and re-use public sector information, it is possible to create seven archetypes of customers based on the available evidence111. These groups are summarised in Figure 3.26 below. As noted earlier, almost every aspect of the economy will use public sector information in some respect (either directly as an input into a production process or indirectly as a final consumer using products and services built on or around public sector information); it is therefore probably true to say that these archetypes are not absolutely comprehensive in their coverage of all aspects of public sector information use and re-use. Nonetheless, based on this report's survey of information users, they capture the most important areas where public sector information is used as an input and generates value. Large data services company Companies that offer data services use data from a variety of sources, including public sector information, to deliver value-added products to clients. They are likely to offer some or all of the following services:  Credit Services: helping organisations to evaluate the risks and rewards associated with providing credit to consumers and businesses, enabling clients to make better informed lending decisions.  Decision Analytics: providing the analytical skills and specialist software products that enable organisations to increase the speed and quality of their decision-making, helping clients to optimise their lending strategies and to implement changes quickly.  Marketing Solutions: helping organisations to find new customers and to take advantage of opportunities for expanding existing relationships, enabling clients to communicate with prospective customers in the most effective way and with the most appropriate offer.  Interactive Enabling: allowing consumers to view their credit report online and to monitor changes to their credit records. Depending on the service offered, a range of types of public sector information is likely to be used as an input. This includes information on companies (such as supplied by Companies House), demographic information, and economic forecasts. This information is likely to provide one input among many, and so only a proportion of revenue could be directly traced back to public sector information. In many cases, the products being sold by the large data services company could still be produced, albeit not as effective. In isolated cases, substitutes may also be found to the public sector information, albeit potentially at greater cost or reduced quality. Independent or SME app developer App developers are predominately individuals or small companies112 with the technical skills to create smartphone applications presenting publically available data, including public sector information, to a wider base of non-technical users. They may release these apps free of charge, or for payment; or they may release multiple versions, i.e. a free version to download but containing advertising, and the other requiring payment but no advertisements. An example is the developer Routemaster, responsible for releasing the London Transport Live and London Transport Pro apps using Transport for London data.113 The apps market as a whole is fragmented among many individuals and small enterprises and individual profitability is not easily known. Nonetheless they are an important conduit to a wider range of users and re-users for public sector information. The type of public sector information used varies depending on the nature of the app. For example, transport apps will use road and rail data; weather forecasting apps will use data from the Met Office; property price apps will use data from the Land Registry; etc. In many cases there will be no substitute for public sector information as an input, or any substitute may be prohibitively priced or of lower quality. High quality, reliable and competitively priced or free public sector information therefore underpins many app products, and is likely to play an increasing role as more public sector information become available and the app market matures. SME focussed on policy efficiency solutions SMEs using public sector information and other information sources to develop products that aid policy efficiency can usefully be grouped into a third archetype. An example is ELGIN, which via its service roadworks.org publishes streetworks and other highway information on the web. It is designed to facilitate coordination of activities between neighbouring authorities and statutory service providers, such as utility companies, enabling them to reduce road space occupation and to meet their statutory obligations under the Traffic Management Act.114 The ELGIN business model is a good example of a shared geospatial 'cloud-based' service, where, for a relatively small upfront subscription, joining authorities get access to shared services and obviate developing and supporting their own computer system. The approach also supports interoperability and data sharing, with all information being presented in a common format on a single website. In this instance public sector information (transport information, in this case) is critical to the business model of roadworks.org, without which it could not exist. This is therefore an example of a business that has been enabled through the release of public sector information, and which acts as an 'enabler' to facilitate improved use of this information (see below). s In many cases, business models may rely on combining public sector information with other sources of information. For example, Honest Buildings intends to combine public sector information such as the Energy Performance Certificates database (environmental/energy information) with other sources of information on properties and real estate services, helping property owners to realise energy savings through improvements to their properties.115 In these instances the business could often exist without the public sector information, but the value of its offering i greatly enhanced by access to this information. This is therefore an example of an area where government could add value and aid the development of new markets through targeted release o key public sector information datasets (the Energy Performance Certificates database being a ke current exa f y mple). Individual users Individuals with the technical skills and interest to work with data may decide to use their skills to derive insights from data (research or other purposes) or present it in a form that is more accessible to non-technical users. For example, upon the release of road construction project data by the Department of Transport in Edmonton, Canada, a local application developer decided to create a mobile app for smart phones and similar devices to access the map interface. He saw the data as useful for the population and decided to make a contribution to his new home city, not as a commercial venture. He reported that creating the app was a relatively straightforward task for him, due in part to his extensive development experience and the high quality of the data set and metadata provided by the city, indicating that these individuals often lack the resources to exploit data if it is not presented in a suitable format.116 In these cases, the monetary value generated by the use of public sector information may be small or non-existent, but the product may produce wider social and economic benefits. In general, availability of public sector information appears to be a precondition for the emergence of many of these-user generated products, as alternative sources of information may not exist or may be prohibitively priced. However, this varies on a case by case basis. Not for profit organisations Not for profit organisations may use public sector information for a wide range of purposes, including holding elected officials to account, strengthening civil society, and providing means for citizens to monitor and influence areas of interest to them such as the environment and local services. As such public sector information use or re-use by these organisations does not necessarily have a revenue impact, but is likely to have wider social, economic or public interest benefits. Their task would in many cases be impossible to perform without access to public sector information. The benefits arising from their actions can therefore in many cases be largely attributed to the availability of public sector information. General data user (non-specialist company) Many companies, notably professional services firms, use public sector information as a matter of course as a key source to inform their work. An example of public sector information commonly used by such companies is ONS data on the economy. The conduct of their operations would become more difficult and more expensive were public sector information unavailable. However, while these firms work with public sector information and other data on a day to day business, they differ from data services companies in that they do not explicitly sell data services. The proportion of their revenue attributable to public sector information is therefore likely to be lower than for the data service companies, and it is likely that they could turn to alternative sources of information were the public sector information unavailable. In these cases public sector information generally improves the product or service offered, rather than being integral to its existence. Public sector bodies Public sector bodies not only produce but also use public sector information in their day to day operations. Uses vary widely, ranging from use of address data by local authorities to use of economic data by central government departments. Public sector information use by public sector bodies does not necessarily generate revenue but may assist with achieving more efficient and effective operations, leading to cost savings and improved outcomes. The ways in which these different archetypes generate value from public sector information is shown below. Value can be generated through its independent use or re-use or by combining public sector information with other data sources to become important inputs into products, services, decision-making and other outcomes. As noted above, public sector information acts as an input as a data point for complex algorithms and analyses, as a source of insights (perhaps summarised as data dashboards or visualisations), as API feeds for apps and so forth. Source: Deloitte analysis The following section focused on a particular group of business models used by public sector information intermediaries, who can be found in the SME and large data service companies archetypes. ## Different Business Models Of Public Sector Information Intermediaries The ways in which different intermediaries use and re-use public sector information varies by their business models. To recap, the public sector information value chain includes suppliers (PSIHs), intermediaries (enablers and infomediaries) and final consumers. Figure 3.28 summarises the different business models currently in operation across the public sector information market. ## Figure 3.28: Public Sector Information And Open Data Business Models Source: Deloitte analysis As Figure 3.28 shows, there is clearly overlap in business models that rely upon open data more generally with those that rely specifically on public sector information (either as open data or otherwise). The business models here are a way of deriving economic benefit out of public sector information and open data. Many of these might be interrelated, such as, in some cases, Open API is the data feed for Apps based reuse, and hence an Enabler. The following sections briefly outline each business model, as well as the economic impact arising from each (the relationship between economic growth and public sector information and open data is explored in much more detail in the next chapter). PSIHs as public sector information suppliers - business models The collection, retention and distribution of public sector information is not without cost - though the level of cost will vary by dataset and PSIH. In some cases, PSIHs will seek to recover these costs from intermediates and final consumers - indeed, they are often incentivised to do so in terms of legislative requirements or other business objectives. The different ways in which public sector information can be monetised are shown below. ## Figure 3.29: Public Sector Information Monetisation Models Source: Adapted from Programmerweb, http://programmersweb.blogspot.co.uk/ The choice of which monetisation model to use will depend on each PSIH's strategic objectives and the type of public sector information in question. For example, Trading Funds are explicitly required to make a return on data collected, retained and disseminated. There are a number of benefits to releasing public sector information for PSIHs regardless of the monetisation model. Through open application programming interfaces (APIs) PSIHs can improve their brand visibility, explore new distribution channels, extend innovative external product development, and tap into new communities. ## Intermediaries As Data Marketplaces - Business Models Intermediaries acting as data marketplaces or infomediaries have very successfully monetised public sector information and other open data as a third-party reuse, mostly through freemium model or advertisement revenues. Figure 3.30 provides some examples of different business models. ## Figure 3.30: Data Marketplaces Business Models | Website | Data Domain | |---------------------------------|-------------------| | Factual | | | Open data sources, | | | community | | | contribution, web | | | crawling | | | High quality local data | | | Travel, finance, sports, autos, | | | movies, music, TV, books, | | | health, food, politics, | | | education, science, arts | | | Currently free | | | Pay-per-use pricing for every | | | API call with subscription | | | Integrate third party deals in | | | apps | | | Infochimps | | | General public sector | | | information | | | Charge data sellers | | | Charge data buyers | | | User submitted data | | | Data from public | | | sources | | | Datasets from public | | | sources | | | Datamarket | | | Public sector information | | | Statistical data | | | Charge data sellers | | | Charge data buyers | | | User submitted | | | datasets | | | Community curated | | | data | | | Freebase | | | General public sector | | | information | | | Paid for higher volumes of | | | data calls | | | Public datasets | | | imports | | | Kasabi | | | Charge data consumers | | | All-purpose public sector | | | information, including BBC | | | linked data, Geonames | | | Public datasets | | | User submitted | | | datasets | | | Public sources of | | | economic data | | | Timetric | | | Public sector information | | | economic data | | | Free public datasets | | | Paid exclusive datasets | User uploaded | | datasets | | | Xlgnite | | | Financial data | Paid subscription | | Aggregate data from | | | leading financial data | | | sources, public | | | datasets, and user | | | uploaded data | | Source: Deloitte analysis Chapter Five discusses the ways in which the use and re-use of public sector information can generate impact, but focusing just on data marketplaces and infomediaries, one can see how other businesses, individuals and the public sector benefit from their products and services - not just the data marketplaces and infomediaries themselves, through increased profits. Source: Deloitte analysis Apps based re-use - business models App developers take advantage of refined public sector information and other open data processed by infomediaries and enablers to produce apps for end-users - either for their smart phones, tablets, laptops or other devices. The barriers to entry into the app development market are very low and there are a range of established distribution channels available. Some apps are made available for free, while others are available upon a fee or on a freemium basis. Consumers' willingness to pay for apps will ultimately depend on their expected utility from using these apps. For example, though people can access *The Guardian* as a mobile site on their iPhone, The Guardian iPhone app is among the top paid application. Similarly, citizens in San Francisco pay for more reliable and more interactive iBARTLive (Bay Area Rapid Transit System), although it is available as a mobile site, and is integrated with Google Maps. It may also be that willingness to pay for apps exceeds willingness to pay for websites, owing to the greater convenience. Source: Deloitte analysis Figure 3.33 above shows the value-chain for app development from public sector information and other open data. Clearly, there are significant benefits to be had from app-based public sector information and open data re-use. Beginning with narrow effects, businesses creating apps can create new jobs and generate wealth. This in turn can generate supply-chain or indirect impacts: changes in the number of jobs and income in associated industries that supply inputs to organisations developing apps. Finally, there will be induced or consumer impacts through spending by households associated with businesses creating apps and the supply chain that results in changes to jobs and income. Additionally, there may be broad effects such as apps facilitating greater participation in policymaking or more informed choices. ## Figure 3.33: Impact Of App Re-Use Source: Deloitte analysis Public sector information and open data backed 'Apps' have already reduced fact-checking costs/time considerably, and led to increase in citizen awareness and partnership, with the case study below providing an example of this. ## Figure 3.34: London Olympic Games - Public Sector Information App Use The proportion of the UK population using smart phones has risen from 30 per cent in 2010 to 44 per cent in 2012 - it is estimated 4 in 10 adults use their phone to go online. The presentation of London Olympic Games-related public information in app format led to more usage than the mobile web - indicating that citizens found this more useful accessing information via a webpage. Chart showing 20% mobile web usage versus 80% app usage Source: Adult Media Use and Attitude Report, 2012, Ofcom; Neilson Data enrichment - business models Data enrichment refers to those consumers who take advantage of public sector information to improve and expand their existing products and services. In its broadest sense this could be improved decision-making with reference to the latest economic and demographic statistics published by the ONS, or more specifically, it could be the embedding of newly available Week before Olympic Games: 1599 app usage versus 78 mobile web usage Week 1 post Olympic Games: 4727 app usage versus 185 mobile web usage Week 2 post Olympic Games: 2997 app usage versus 115 mobile web usage educational datasets to refine existing educational products focusing on those features that truly improve outcomes. The types of business which 'enrich' data and their end consumers are summarised below in Figure 3.35. ## Figure 3.35: Data Enrichers Source: Deloitte analysis As can be seen from Figure 3.35, data enrichers can be found across all aspects of the economy. Data enablers - business models The final category of business model this report has identified is data enablers, who are another group of intermediaries. Data enablers are businesses that facilitate the public sector information and open data environment through:  data storage infrastructure;  platform, hosts, network provider;  consulting /advisory services;  software provision;  providing devices where apps can be accessed, - mobile phone companies, operating platforms provider; and  the developer community. Through their work, enablers allow other businesses, government and individuals to more readily exploit public sector information. Source: Deloitte analysis ## Data Scientists Individuals using and re-using public sector information on behalf of their organisation or for personal use are likely to have a range of analytical skills and abilities. The types of roles that are developing around information and data exploitation are well demonstrated by the example of the emerging role of the 'data scientist'. ## Figure 3.37: Profession Profile: Data Scientists A key profession in the world of open data, public sector information and data analytics is the 'data scientist', which was recently described by The Harvard Business Review as "the sexiest job of the 21st century". The data scientist is described as "a high-ranking professional with the training and curiosity to make discoveries in the world of big data." Although statisticians and experts on quantitative analysis have long existed, data scientists differ from these existing professions in a number of important ways. As well as being able to work with large volumes of structured and unstructured data, they are able to translate these analyses into policy and commercial-ready insights and effectively communicate them to a range of stakeholders, often using innovative tools and visualisations. Key to this is the ability to "identify rich data sources, join them with other, potentially incomplete data sources, and clean the resulting set." In many ways they therefore resemble scientists more closely than traditional data analysts. Data scientists are generally drawn from the ranks of graduates in numerate and scientific fields, including mathematics, economics, and computer science. Scientific qualifications with a less immediately obvious relevance to data science, such as ecology and astrophysics, have also generated successful data scientists, as many of the core traits of practitioners in these fields are similar: an ability to generate and test hypotheses and the curiosity to penetrate to the heart of a problem. The data scientist is a best thought of as a "hybrid of data hacker, analyst, communicator, and trusted adviser." Keys skills required for the role of data scientist include:  The ability to write computer code  A foundation in maths, statistics and probability  Skill in communicating the 'story' the data tells to a non-technical audience  Ability to display complex information visually The key traits of a typical data scientist may include:  Curiosity  Empathy and a feel for the key issues  Creativity and imagination Source: Harvard Business Review, 'Data Scientist: The Sexiest Job of the 21st Century' (October 2012); Examples of businesses directly employing data scientists include:  GE uses data science to optimize the service contracts and maintenance intervals for industrial products;  Google uses data scientists to refine its core search and ad-serving algorithms;  Zynga, a games company, uses data scientists to optimize the game experience for both longterm engagement and revenue; and  Kaplan, a test preparation company, uses its data scientists to uncover effective learning strategies. Based on ONS figures for 2011, around 1.5 million workers in the UK, representing around five per cent of the active workforce, are employed in job categories that are likely to involve elements of the role of the data scientist117. These figures are indicative only, owing to limitations with the ONS data and the use of SOC occupational classifications, but indicate how widespread the requirement for data analysis skills has become. The importance of these workers to the UK economy is likely to be greater than the numbers indicate as they are usually employed in high-skilled, highproductivity, and high-paid job categories. A recent report118 has estimated current and future demand for staff with data skills. It found that data scientists, while important, accounted for less than 1 per cent of all advertised positions for big data staff in the third quarter of 2012. However, when the analysis expanded to consider other roles not labelled data scientists, but likely to perform related roles (i.e. developers, IT architects and analysts), these were among some of the most commonly advertised roles. ## Figure 3.38: Most Commonly Advertised Big Data Roles, Q3 2012 (% Of Total) Source: 'Big Data Analytics' (January 2013) The report found an observable pay premium for big data staff, with salaries around 20 per cent higher than those for IT staff as a whole. This reflects the rapid increase in demand for big data staff and a potential shortage of skills: the report found that demand has risen by 912 per cent over the last five years. This includes a 350 per cent rise in demand for data scientists. This growth is projected to continue: depending on the growth scenario adopted, the report anticipates growth in demand for big data staff of between 13 per and 23 per cent per annum. Taking a midpoint of 18 per cent would mean the generation of 28,000 gross job opportunities per annum by 2017, with 132,000 gross job opportunities created between 2012 and 2017. Analysis of ONS SOC occupations that involve an element of data science for this report found that the average annual median wage of these 'data science' workers was over £36,000 in 2011 which compared favourably to the national annual median wage of £26,000 in 2011. Chapter summary  While data on the total number of public sector information datasets is not recorded, a review of selected data portals suggests the number could exceed 37,000.  Some of the key suppliers of public sector information, in terms of number of datasets, include the Office for National Statistics, the Department for Communities and Local Government and the Health and Social Care Information Centre. Collectively, the top ten publishers of public sector information make up 60 per cent of all datasets on data.gov.uk.  Datasets on government spending are among the most available datasets.  Levels of awareness of public sector information vary across staff in PSIHs. Over 50 per cent of civil and public servants, according to one survey, did not know how to access datasets, how to interpret them or best apply data standards.  The demand side of the market includes infomediaries and final consumers. Business models include developing apps that use/re-use public sector information, data enrichers, data enablers and data marketplaces.  Building on existing analyses, it is possible to create a data intensity matrix to compare how different types of datasets are used by different economic sectors in the UK currently. The analysis also shows that the construction, real estate, financial and insurance, public sector and arts, entertainment and recreation sectors are some of the largest users and re-users of open data.  Dataset types most commonly being used include demographics, economic, environmental and geo-spatial and housing data.  From an analysis of data.gov.uk dataset requests, the most popular dataset category requested is location (or geospatial) data. This reinforces the impression that this category of data generates some of the highest levels of value. Environment, transportation, health and society are also data that attract particularly high levels of requests.  As well as being used for commercial and policy purposes, public sector information can be used for scientific research, data journalism and holding public service providers to account.  Some of the most viewed and requested datasets relate to geospatial and transport information. Of the named barriers identified as preventing access to public sector information, data format and financial charges were among the most commonly mentioned. ## 4. Public Sector Information Regulatory Landscape This Chapter Provides An Overview Of The Key Stakeholders Involved In The Governance And Policy Direction Of Public Sector Information, As Well As The Main Regulations And Legislation Influencing Its Delivery. It Is Not Intended To Be An Exhaustive Survey Of The Regulatory Landscape But Provides A High Level Overview Of The Salient Points. Policy And Regulatory Stakeholders The public sector information market is complex and evolving. The market also continues to be the subject of a number of policy and other regulatory and legislative initiatives. Many of the policy questions around public sector information link to wider agendas on transparency, accountability and growth - within which there are a range of initiatives. Some of these currently include:  a number of consultations covering a range of issues from Freedom of Information, data release guidelines, the **right to data** and **intellectual property**;  a number of forums considering public sector information and transparency issues including the Data Strategy Board, **Transparency Board,** the **Public Data Group**, the Open Data User Group, the **Administrative Data Taskforce**, the Advisory Panel on Public Sector Information and others; and  updating existing policies on data and transparency for bodies such as the Research Councils. A full list of contemporary initiatives in this area can be found on the Cabinet Office website119. These initiatives notwithstanding, it is possible to sketch out a provisional schematic for the market that captures the different players and their roles and responsibilities. As well as PSIHs, there are a range of actors involved in the governance of public sector information and open data policy and regulations - all of which have a bearing on how the market develops. The highly simplified schematic in Figure 4.1 illustrates the number of different policymakers and others involved in shaping the public sector information landscape. Within each PSIH there will be staff directly involved in public sector information policymaking and others more focused on delivery. In a number of cases, policy shapers will also be part of the public sector information supporting infrastructure and may also be public sector information suppliers and consumers. Source: Deloitte analysis. * Some policy shapers will also have operational duties, e.g. Cabinet Office is responsible for data.gov.uk ## As The Market Evolves, One Might Expect Increasing Numbers Of Supporting Public Sector Information Agencies To Emerge, As Well As Organisations In The Private And Voluntary Sectors, As In The Case Of The Open Data Institute. The Legal Framework For Publishing And Sharing Public Sector Information120 The ability or inability of government departments and other PSIHs to publish and share public sector information they hold is dependent on their possessing one or more of the following:  express statutory powers: these are powers specifically given through legislation;  implied statutory powers: these are powers not specifically given in legislation but which can be implied from it because without these powers the public body would be unable to carry out its functions as specified in legislation; or  common law powers: these are powers that exist outside of legislation. The Ram Doctrine (after Sir Greville Ram, 1945) states that a Crown government department has all the powers of a natural person and does not need to demonstrate any statutory power or authority to carry out an action, unless that action is expressly or implicitly precluded by statute121. There are notable cases where statutory powers restrict or supersede common law powers. For example, the Department of Education shares individual pupil data under the Education Act 1996, which sets the limits for sharing this data.122 However, it continues to share some of its aggregated data under common law powers. Consequently there are statutory restrictions on the sharing of individual pupil data which do not necessarily apply to the sharing of the same data in aggregate form. This level of complexity means both that it is not always clear whether existing legal powers (statutory and common law) are sufficient to allow a particular instance of data sharing; and also that even where there is a legal basis to permit sharing or release of data, there can be uncertainty over the legal position leading to public sector bodies 'playing it safe' and restricting data sharing. Given that unlawfully sharing information relating to an identifiable person or legal entity is an offence that can carry a prison sentence of up to two years,123 this caution is understandable. Nonetheless, it can create additional barriers to sharing of information even where it is permitted under statute or common law. Where two or more public sector bodies attempt to share information, the level of complexity is even greater. It may be that one body is legally permitted to share its information but the other is not. In this case the second body may be able to carry out the linking work, but this still raises the question of whether the resulting analysis can legally be shared with the first body. The level of complexity only increases as the number of public bodies involved rises - and many of the most interesting opportunities for linked data may involve information held across the full spectrum of the public sector. In specific cases a 'legal gateway' may be created through legislation in order to explicitly allow the sharing of information. An example is data collected under the Statistic of Trade Act 1947, which may be provided to local authorities owing to subsequently created legal gateways, the Employment and Training Act 1973, as amended by the Employment Act 1988. These allow the sharing of relevant information with the persons listed under section 4(3) of the 1973 Act. However, as is indicated by the above example, these legal gateways are complex and timeconsuming to set up - it has been reported it can take as long as two years, by which time the window of opportunity to enhance a policy through sharing information may well have passed. Having been created, the legal gateway only applies to a very specific instance of information sharing, while the proliferation of such gateways continually increases the legal and regulatory complexity of the public sector information landscape. In order to be clear as to whether a particular instance of information sharing is permitted, an employee of a public sector body requires a substantial knowledge and understanding of legally complex gateway arrangements. In its recent report the Administrative Data Taskforce recommended the creation of "a generic legal gateway for research access to and linkage between administrative data."124 The rationale is to create a more consistent, efficient and timely legal framework for sharing information, so as to enhance policymaking with evidence-based insights and to ensure that information holders have clear guidance as to when it is appropriate to share information. ## Public Sector Information Licensing And The Regulatory Framework The UK Government Licensing Framework Public sector information provision is governed by the UK Government Licensing Framework (UKGLF), overseen by The National Archives. It provides "a policy and legal overview of the arrangements for licensing the use and re-use of public sector information both in central government and the wider public sector."125 The key licences comprising the UKGLF are summarised below. ## Open Government Licence The Open Government Licence (OGL) was introduced in 2010 as a licensing mechanism to facilitate the use and re-use of public sector information. It is designed to impose as few conditions as possible on users, permitting them to:  Copy, publish, distribute and transmit the information;  Adapt the information; and  Exploit the information commercially, including by combining it with other information and including it in a product or service. Notably, information published under the OGL does not require users and re-users to register or pay any charge. The main condition of use for information published under the OGL is that users must acknowledge the source of the information by providing any attribution statement specified by the information provider. Other conditions and limitations are that:  Users may not use the information in a way that suggests official status, or that they have the endorsement of the information provider;  Users may not mislead others, nor misrepresent the information or the information provider; and  Users must ensure that their use of the information does not breach the Data Protection Act 1998 or the Privacy and Electronic Communications Regulations 2003 (EC Directive). The OGL also limits the liability of the information provider by specifying that the provider is not liable for any errors or omissions in the information, and does not guarantee the continued supply of the information. The OGL replaces the previous Click-Use Licence as the default licence for a wide range of information owned by the Crown, including information previously made available under the Click-Use Licence and source code and software originated by the Crown under Framework 1 of the NESTA agreements. It is designed to be interoperable with other widely used models including the Creative Commons Attribution Licence and the Open Data Commons Attribution Licence. It is increasingly widely used across the entire public sector, and its use is not confined to Crown bodies. For example, over 270 local authorities currently use the OGL. Source: The National Archives ## Non-Commercial Government Licence Although the default position is that information should be published under the OGL, there are circumstances under which it is not appropriate to allow commercial use of information. In these circumstances information providers can publish under the Non-Commercial Government Licence. This licence allows the use and re-use of information free of charge, permitting users to:  Copy, publish, distribute and transmit the information;  Adapt the information; and  Combine the information with other information. The main restriction on the use of information published under this licence is that it may not be used for purposes intended to confer commercial advantage or private monetary compensation. These restrictions also apply to any onward licensing of the information, for example when combined with other information. As with the OGL, users are required to acknowledge the source of the information. Source: The National Archives In certain circumstances public sector bodies are permitted to charge for use and re-use of information on the basis of cost recovery and a reasonable rate of return. The most notable examples of this are the Trading Funds, although they are not the only examples. In such cases, the specific terms of the licence vary depending on the requirements for the product or service in question. However, the National Archives is in the process of developing a standard charged licence under the UKGLF, currently in beta version and undergoing development at the time of writing. The aim is to "provide a straightforward set of terms which deliver an effective standard approach."126 This is intended to provide greater consistency and transparency around licensing conditions where information is charged for, both for the purchaser and the provider of the information, and thereby reduce costs for the provider and increase the accessibility of the information for users. An additional licence is the Open Parliament Licence, which is designed to enable parliamentary material to be shared and used in a manner consistent with the principles of the OGL.127 Crown copyright and the Information Fair Trader Scheme The National Archives manages Crown copyright by licensing material, and by granting delegations of authority to certain public sector bodies for certain information to allow them to license the material they hold. Delegations are only offered to certain organisations, notably trading funds; other organisations must write a business case setting out why this is appropriate. This is regulated through the Information Fair Trader Scheme (IFTS), which is designed to ensure that re-users of information are treated fairly by public sector information providers. IFTS accreditation is based on a full audit of information trading activities and is intended to show that "their processes and policies are compliant and consistent with government policy on information trading and that they meet the needs of existing or potential customers." All public sector bodies that license information can apply to join the IFTS. Organisations currently accredited include Land Registry, Ordnance Survey, the Met Office and Companies House, among other trading funds.128 The IFTS is based on the following principles:129  Maximisation: the default position should be that information can be re-used, in the absence of strong reasons to the contrary;  Simplicity: regarding processes, policies and licences;  Innovation: actively facilitate the development of new and innovative forms of re-use;  Transparency: regarding terms of re-using, charging details, and what information is available;  Fairness: re-users should be treated in a non-discriminatory way, and information holders should not use their position to compete unfairly; and  Challenge: a robust complaints process. Exceptions to marginal cost pricing As discussed above, most public sector information is made available at marginal cost, which in practice usually means free of charge, especially where the information is provided online. However, there are exceptions to this. Where a PSIH wishes to charge above marginal cost for information, it must make a business case to the Office of Public Sector Information130 under the exceptions process. An application will generally be made if an information holder has added value to the information and therefore wishes to treat it as a commercial product. The case for an exception is judged on the following criteria:131  Is it essential to produce the information as part of government's core duties and therefore vital to the workings of government?  Is the information directly funded by the taxpayer, either through it being collected for the purposes of government or produced with the purpose of informing the public?  Is the Department or Agency the sole producer of the information or can the information be obtained from other sources?  What effect would charging for the information have on the level of re-use?  Is the Department or Agency able to provide a statement of commitment to Information Fair Trader principles signed by its Permanent Secretary or Chief Executive? These criteria are designed to ensure that charging above marginal cost does not compromise the core principles of public sector information policy, especially:  maximisation of access, re-use and innovation;  openness and accountability; and  competitive neutrality. The below schematic illustrates the exceptions application process. Source: adapted from www.nationalarchives.gov.uk/documents/information-management/how-we-deal-with-exception-application.pdf ## The Data Protection Act The Data Protection Act 1998 (DPA) was enacted to bring UK law into line with the EU Data Protection Directive 1995, which required Member States to protect citizens' rights and freedoms, including their right to privacy, with regard to the processing of personal data. As such it plays a significant role in the public sector information landscape, particularly with regard to sharing and publishing data which may have personal privacy implications. The DPA covers any data which concerns a living and identifiable individual. Anonymised or pseudonimised data is not considered personal data and is therefore not covered by the DPA - in this respect the UK differs from several other EU Member States. Where anonymisation is reversible, however, the data does fall within the scope of the DPA. The individual who is the subject of the data that is held or processed is entitled to:  view the data for a 'subject access fee';  request that incorrect information be corrected;  require that data is not used in any way that could cause damage or distress; and  require that their data is not used for direct marketing purposes. The subject of the data must consent to the collection and storage of their information. The data holder has an obligation to inform the data subject the purposes for which it is being used and to whom it has been disclosed, and the data subject may be able to withdraw consent. In any event, consent is not assumed to last forever - in general it is assumed to last for as long as the data needs to be processed. In some cases the DPA may be seen as a barrier to the release or sharing of information, or it may be that information holders are unsure of their obligations and therefore err on the side of caution and resist releasing information even where this is permitted. However, from conversations with stakeholders in the information and regulatory communities, notably The National Archives and the Information Commissioner's Office, it seems clear that while the DPA requires information holders to handle information with care: it should not be a barrier to its use and re-use. For example, if the information undergoes appropriate anonymisation its use and re-use is no longer constrained by the DPA, because anonymised information is not considered personal information. It should be noted that the reform of the EU legal framework on the protection of personal data, proposed by the European Commission in 2012 and currently undergoing negotiation, may eventually replace the DPA with a new EU regulation. The impact on the UK regulatory landscape is currently unclear since the details of any new regulation are as yet unknown. The case study below is an example of the anonymisation process to which data can be subjected, in order to ensure that it does not contravene the principles of personal privacy or fall within the remit of the DPA. ## Case Study: Avoiding The 'Jigsaw Effect' Anonymisation of datasets is a key plank of the transparency agenda. It is particularly relevant where datasets are of high value for researchers, policymakers and the wider public, but also contain personal and potentially confidential details of individual citizens. Publication of such personal details would be a breach of privacy. In order to make these datasets available without compromising privacy, key individual identifiers (names, dates of birth, addresses and so forth) are removed prior to release. High profile examples of these types of datasets include the National Pupil Database, court sentencing data, and data on offenders and reoffenders. However, it is sometimes possible to 'de-anonymise' data through a process called 'jigsaw identification'. This involves assembling information from other sources which allows re-identification of an individual through a process of triangulation. This process becomes easier the more information is readily available, which is a matter of concern given the ever-expanding volumes of information available through the Internet, especially with the rise of social media and indeed the growth of government transparency programmes. In addition, the growing level of computational power at the disposal of individuals brings the resources required within the reach of an ever greater number of people. The authors of a recent paper132 therefore describe 'best practice' for the anonymisation of sensitive datasets, based on the experience of the Ministry of Justice in anonymising its data on reoffending. As a first step, the data was anonymised by Ministry of Justice statisticians, who aggregated the data into ranges for each characteristic as follows: gender, age, offence, establishment/trust, previous offences, whether reoffended and number of re-offences. This data was then passed to academics and postgraduate students with relevant experience at the LSE, Royal Holloway and Southampton University. They were asked to identify the anonymised subjects. One disclosure resulted from this process, out of over 200,000 cases. This was possible thanks to the profile of an offender named on a local news site. In response to this, the MoJ statisticians further aggregated the data by removing information about the offence committed. The data was then passed to data security specialists Detica, where a team confirmed that the data was secure against the jigsaw effect. By involving three diverse groups of testers, the effectiveness of the anonymisation process was tested more robustly and the MoJ was able to release the anonymised data with high level of confidence that individual privacy had been respected. The involvement of the students was seen as a particularly important element of the test, as their approach resembled that of hackers and they subjected the data to unorthodox approaches, highlighting any unforeseen risks or weaknesses in the anonymisation process. As a consequence, the MoJ statisticians acquired more detailed knowledge of the properties of the data a greater understanding of the level of aggregation required to preserve the anonymity of the subjects. ## Case Study: Avoiding The 'Jigsaw Effect' The authors suggest that this method could usefully be applied across government, as a way of ensuring that transparency is accompanied by robust methods and a respect for privacy in which the public can have confidence. Source: Kieron O'Hara, Edgar Whitley and Philip Whittal, 'Avoiding the jigsaw effect: experience with Ministry of Justice reoffending data' (December 2011) ## The European Dimension In addition to UK statute and common law, the European Union (EU) also plays a significant role in the legal and regulatory framework for public sector information. The main relevant regulations are the European Union Directive on the Re-Use of Public Sector Information (the 'PSI Directive'), and the European Union Data Protection Directive (see box-outs below). It should be noted that both of these are undergoing revision, with the revised versions likely to be adopted during the course of 2013. These debates are ongoing, and whichever of these dynamics becomes the dominant trend at the European level may have a significant effect on the development of the public sector information landscape in the UK. ## The European Directive On The Re-Use Of Public Sector Information The breakout box below summarises the current PSI Directive and the proposals for its revision. ## The European Directive On The Re-Use Of Public Sector Information And The Proposed Changes To It In 2003 the European Union introduced the Directive on Re-use of Public Sector Information (2003/98/EC) which introduced a common legislative framework regulating how public bodies should make their information available for re-use, including removing barriers and improving transparency. This required public bodies to:  be transparent on conditions of re-use;  avoid any form of discrimination between users, including a re-use by the public sector body itself;  deal with applications for re-use within a set maximum time; and  not enter into exclusive arrangements, except under exceptional circumstances. In December 2011 the European Commission, as part of an Open Data package, presented proposals to revise the 2003 Directive.133 These revisions are likely to create a presumption of openness on public sector information, with key changes, according to the EC, including:  bringing new bodies under the scope of the Directive, including cultural bodies such as museums, libraries and archives;  limiting the fees that can be charged by public authorities at marginal cost as a rule;  introducing independent oversight over re-use rules in member states; and  making machine-readable formats the norm for information held by public authorities Negotiations are continuing at the time of writing. The revised Directive is expected to be adopted in Europe in the course of 2013 and come into force through regulations in UK law in 2014-15. ## The Proposed European Data Protection Regulation The breakout box below summarises the proposed regulation on data protection. ## The Proposed European Data Protection Regulation In January 2012 the European Commission published a draft General Data Protection Regulation. If adopted, this would replace the current Data Protection Directive (95/46/EC) and any relevant member state legislation, including the UK's Data Protection Act. Unlike a Directive, a Regulation takes direct effect with no need to be transposed into law for each member state. There are aspects of the Regulation, in its initial draft form as proposed by the European Commission, that have caused concern among holders and users of public sector information. In particular, the draft was seen to favour the right to privacy of individuals and one possible outcome of this is that the Regulation may impose restrictions and conditions on the linking of datasets and use of 'big data', where this involves personal data. In its proposed form the Regulation introduces new procedures for the processing of personal data. These may increase the bureaucratic burden on organisations and could disincentivise the release of public sector information where this becomes too burdensome. This is significant since the use of anonymised personal data is among the most potentially valuable exploitations of public sector information, both for improving policy and for wider welfare gains. The Regulation appears to provide derogations from particular requirements for the use of personal data for historical, statistical and scientific research purposes. To qualify for these derogations, personal data must be processed in accordance with Article 83: personal data should be used only if anonymous data is insufficient, and where possible identifying information should be kept separate from other information. This may make the use of public sector information for research and policy purposes easier, although other areas of the proposed Regulation may continue to pose challenges. The Regulation is currently undergoing consideration and amendment by the European Parliament and Council of Ministers, with adoption likely either during the course of 2013 or possibly in 2014. ## The Inspire Directive The Inspire Directive (2007/2/EC), which came into force in May 2007, is intended to enhance availability, access and sharing of spatial information across EU member states. It is undergoing implementation in stages, with full implementation required by 2019. The essential objective is to enable sharing of geospatial information among public sector organisations, and improve public access to this information. The information to which the regulation applies falls with 34 'themes'.134 INSPIRE is based on the following principles:  data should be collected only once and kept where it can be maintained most effectively;  it should be possible to combine seamless spatial information from different sources across Europe and share it with many users and applications;  it should be possible for information collected at one level/scale to be shared with all levels/scales; detailed for thorough investigations, general for strategic purposes;  geographic information needed for good governance at all levels should be readily and transparently available; and  easy to find what geographic information is available, how it can be used to meet a particular need, and under which conditions it can be acquired and used.135 This is an example of data sharing best practice which could productively be replicated for other types of public sector information. However, it also indicates the difficulties involved in achieving such agreement. It took six years for the Regulation to be agreed upon; and full implementation was not scheduled until a further 12 years after the date of agreement, in 2019. Chapter summary  Despite the public sector information market being relatively young and still maturing, there are a number of key policymakers and policy 'shapers' supporting and influencing its evolution.  The ability and inability of PSIHs to publish and share public sector information is influenced by express statutory powers, implied statutory powers and common law powers.  The UK Government Licensing Framework provides the policy and legal overview of the arrangements behind the use and re-use of public sector information and includes an Open Data-style licence.  The Information Fair Trader Scheme (IFTS) accreditation scheme, which is open to all public sector bodies, has been designed to ensure that re-users of public sector information are treated fairly by PSIHs, and contains principles around complaints handling, transparency and simplicity.  Exceptions to marginal cost pricing for public sector information can be made in certain cases where specified criteria are fulfilled.  The Data Protection Act 1998 does not apply to truly anonymised or pseudonimised data and there are a number of examples of how this can be done.  The key European regulations affecting public sector information in the UK are currently being revised with final versions expected to be adopted later in 2013. ## 5. The Current Value Of The Public Sector Information Market There is no single recognised methodology for estimating the value of public sector information and previous estimates vary considerably. Further, the lack of data on the number of public sector information datasets, consumers' willingness to pay and usage statistics makes any estimate subjective due to the need to make a number of modelling assumptions. Nonetheless, based on the available information and following a number of informed, conservative assumptions developed with stakeholders and on the basis of previous research, this report has applied a pragmatic approach to estimate the value of public sector information market in the financial year 2011/12. While it adapts a previously used methodology, it makes a number of changes to reflect the need to capture the entire public sector information market rather than just an individual segment. This means that the estimates presented here are not readily comparable with previous estimates of the value of public sector information in the UK136. The primary focus of the estimation exercise has been to calculate the so-called narrow economic value of public sector information, which captures the direct value to consumers and PSIHS as well as the supply-chain and consumer spending value impacts. However, given that public sector information is known to have significant broader, social value impacts, case study analyses have been used to illustrate this current value. In some instances, these case studies are augmented with ad hoc calculations that provide an indication as to what the broader societal value of public sector information might be in financial terms. ## Understanding The Value Of Public Sector Information At the outset, it is important to clearly define what is understood by the term value137. Previous studies have considered value in terms of market value (defined as either total turnover or profits accruing to consumers of data and PSIHs), consumer138 and producer139 welfare and broader (non-monetary) value. Having reviewed the evidence, it appears appropriate to disaggregate value into four distinct components which can capture elements of market, consumer, producer and wider value:  the direct value of public sector information to producers and suppliers (the PSIHs): these are the benefits accruing to producers and suppliers of public sector information through the sale of public sector information or related value-added services;  the indirect value of public sector information arising from its production and supply: the benefits accruing up the supply chain to those organisations interacting with and supplying PSIHs (but not directly using or re-using public sector information), and the benefits accruing to those organisations where employees of PSIHs and supply chain organisations spend their wages;  the direct use value of public sector information to consumers of public sector information: the benefits accruing to businesses, civil society, individuals and the public sector from directly using and re-using public sector information for a variety of purposes; and  the wider societal value arising from the use and re-use of public sector information: the benefits to society of public sector information being exploited, which are not readily captured elsewhere. The first three types of value can be termed economic value or narrow economic value and can be measured using standard economic methodologies to derive a monetary estimate for value and the associated employment figure (see below). The final type of value is harder to measure as it captures wider benefits arising from the use of public sector information - these are typically not measured in monetary terms. The literature discusses a number of ways in which public sector information can have broader impacts:  increasing democratic participation: giving citizens and businesses access to public sector information allows them to perform their own analyses of salient issues, make more informed choices about public service providers and interact with policymakers to challenge their assumptions and improve the policymaking process;  promoting greater accountability: for example through the scrutiny of costs of public service provision and benchmarking comparable services;  greater social cohesion: for example, by providing more information on the provision and distribution of services, public sector information can be used to dispel myths on who receives certain public services;  generating environmental benefits: such as reducing congestion and pollution through the release of better traffic and transport data which helps drivers to better plan journeys; and  identifying previously unknown links between different policy areas: through data-mash ups it may be possible to develop system-wide solutions that holistically seek to address the root of policy challenges. Thus, for the purposes of this report, the total value of public sector information is defined as the benefits accruing to the suppliers, users and re-users (i.e. consumers) of the information and data in terms of profits generated, jobs created and supported (narrow economic value) and the wider benefits to society arising from the exploitation of public sector information. It is important to clarify that value defined in this way is not directly the same as the market value of public sector information. Market value typically refers to the volume of sales multiplied by the price of the product. In this way it includes labour costs, capital costs and the intermediate costs of production which are not included in the Deloitte definition. Conversely, market value will not capture indirect effects and wider societal benefits. Modelling approach and assumptions Appendix 5 contains full details of the modelling approach and assumptions used. This report adopts a three-stage approach to valuation of public sector information for the financial year 2011/2:  Stage 1: estimating the value of public sector information to PSIHs and the value to direct consumers (users and re-users) of public sector information using a bottom up approach that quantifies consumer and producer surplus; and  Stage 2: estimating the value of the associated indirect and induced impacts to PSIHs using Input-Output multipliers.  Stage 3: estimating a 'ready-reckoner' value of wider value based on other available research. The report does not seek to systematically quantify the value of the broader social impacts of public sector information. There is a lack of reliable evidence on the linkages (correlated and causal) between the consumption of public sector information and democratic, social, environmental and political impacts. However, notwithstanding this caveat, a third stage of the approach includes a number of case study analyses to illustrate the types of impacts that public sector information can have - and in some cases these include ad hoc calculations to give an indication of the quantum of value that is being generated. This is then used in conjunction with 'uplift' ratios taken in other studies to allow us to generate a broad, order-of-magnitude estimate for wider, and thus the total value of public sector information in the UK. Again, it should be stressed that the lack of reliable data on public sector information140 makes the quantification of value difficult and heavily reliant on assumptions. To reflect this inherent uncertainty the estimates contain upper and lower bounds. Further research (and especially data collection) is required to develop more comprehensive estimates. ## Stage 1: Consumer And Producer Surplus Approach - The Welfare Approach The report uses the so-called bottom-up approach developed by the OFT/DotEcon (2006)141. As the OFT/DotEcon report discusses, a bottom-up approach is preferable to a top-down approach given the latter's tendency to over-attribute causality and generate biased estimates. This 'welfare' approach seeks to quantify the consumer surplus142 derived from the use and re-use of public sector information and the producer surplus143 accruing to PSIHs from the generation, collection and dissemination of public sector information in the financial year 2011/12. Following the DotEcon approach, the welfare approach can be estimated from summing the current net surplus with the total producer surplus from the supply of public sector information. There are standard formulae to calculate consumer surplus and producer surplus (see Appendix 5). The calculations use data on revenues attributable to public sector information, number of known public sector information datasets and available download data. Assumptions are made relating to:  price elasticity of demand for different dataset categories;  the proportion of users going on to actively use and re-use downloaded/viewed datasets; and  the shape of the demand curve. The shape of the demand curve has an important bearing on the size of the consumer surplus. While it may be the case that there are linear demand curves for public sector information that carries a fee, the demand curves may exhibit non-linearities and discontinuities when the public sector information is available free of charge - the level of consumer surplus may be much larger or smaller when the demand curve is not linear. This modelling exercise has sought to recognise these uncertainties and the upper and lower bounds alter our assumptions across the three above variables. Further details of the modelling approach taken can be found in Appendix 3. ## Stage 2: Indirect And Induced Value Of Public Sector Information The indirect value of public sector information refers to the value generated in associated industries that supply inputs into PSIHs. The induced value of public sector information refers to the value generated when households spend wages paid out by PSIHs and industries involved in the supply chain. The report estimates the size of these value impacts using the UK Domestic Use Matrix for 2005 (latest available) sourced from the ONS and the direct use estimate derived above. Appendix 5 contains more details of the approach, but broadly speaking it has involved taking the direct use estimate of producer surplus from Stage 1 (analogous to operating profit) and converting this into gross output (GO) and gross value added (GVA) on the basis of available data. GO TYPE I and TYPE II multipliers are then used in an Input-Output setting to consider the upstream business-to-business purchasing effects (indirect) and consumer spending effects (induced). The GO multiplier used in this process was estimated to be 3.0. To allow a comparable estimate of value to the original producer surplus (and thus allow aggregation), the results are converted back into GVA and then operating profit, by definition, providing a comparable surplus estimate. The 'surplus multiplier' - the ratio of indirect and induced surplus to the direct use surplus - was estimated to be 1:2.4 (3.4 in total). In other words, for each £1 generated as producer surplus in direct use, a further £2.40 is generated via indirect and induced effects. Per worker productivity estimates are used in conjunction with estimates of GVA to provide an indicative level of employment supported in organisations supplying inputs to the public sector information supply chain and supplying goods and services to consumers. ## Narrow Economic Value Estimates Taking account of the above caveats and limitations, the estimates of the current value of public sector information in the UK in 2011/12 are shown below. | Value category | Central scenario | High scenario | Low scenario | |-------------------------|---------------------|------------------|-----------------| | Direct consumer surplus | £1.6 billion | £2.00 billion | £1.00 billon | | Producer surplus | £0.1 billion | £0.1 billion | £0.1 billion | | £0.1 billion | £0.1 billion | £0.1 billion | | | Indirect and induced | | | | | value (supply chain and | | | | | consumer spending) | | | | | Total | £1.8 billion | £2.2 billion | £1.2 billion | Source: Deloitte analysis. Note these figures are not comparable with other estimates of the value of public sector information (such as the previous DotEcon estimates) due to differences in the scope of analysis and methodology used. Note the calculated values for producer surplus and indirect and induced impacts do not alter between scenarios as the data is more robust and fewer assumptions are made. Changes to elasticity, demand curves and data only affect direct consumer surplus estimates. As noted in the introduction, these figures are not comparable with previous estimates of the value of public sector information as earlier attempts have focused on specific datasets or sought to include selected social impacts. As the review of evidence has shown, public sector information can generate value across a much wider range of indicators - suggesting that the total current value of public sector information far exceeds £1.8 billion. The following section considers the wider social value of public sector information in the UK. Wider societal value estimates The use and re-use of public sector information can generate a range of benefits, which in turn can create value for consumers and producers alike. Some of the types of benefits that have demonstrable and, in some cases, calculable financial implications include:  the value of **reduced carbon emissions, reduced fuel use and time saved** due to reduced congestion through using apps and other tools that rely on live public sector information APIs, for example to give live transport updates;  the value of efficiency savings in the public sector144 through identifying cost savings arising from analysis of different public sector information datasets;  improvements to decision making and choice due to new insights from public sector information which, in turn, helps reduce barriers to entry for new entrants to different markets, helping generate economic growth;  promoting **greater accountability in public services and public life** through the availability of public sector information datasets that help individuals rate performance and pursue accountability; and  better policy making using public sector information datasets that improve value for money and the efficacy of policy. To illustrate the ways in which public sector information currently generates value, the report presents a number of case studies in industries already exhibiting some of the benefits of using and re-using public sector information:  the healthcare and life sciences sectors;  the transport sector145; and  the public sector. Where appropriate, indicative estimates of the financial value being generated by public sector information are provided. It is not, of course, always possible to measure benefits in financial terms. Figure 5.2 on the following page offers an indication of the types of benefits and impacts. Note that this includes only the benefits from the discussed case studies, and should be treated as indicative of the much larger total value of the wider societal value of public sector information. A summary of the case studies is also included on the following pages; see the appendices for further detail on the sources and any empirical methodologies used for these. Whilst these individual estimates of social value from the different case studies cannot simply be summed (some are cost-savings, some are time-savings some are economic value and some are non-quantifiable), they suggest that the total social value of public sector information is likely to be significantly greater than the narrow economic value presented here. A conservative estimate of the wider social value of public sector information suggests a value at least three times the size of the £1.8 billion economic value may be appropriate146, i.e. **over £5 billion p.a.** This chapter concludes with some 'blue skies' opportunities for the use and re-use of public sector information, which are not currently producing tangible benefits but which studies indicate may prove valuable opportunities in the future. The health sector As is well-known, the health sector collects a wealth of data on patients and patient outcomes. The case studies below highlight some of the opportunities that can arise out of analysing public sector information datasets, but also some of the challenges around making this data more widely available. ## Publication Of Mortality Rates Following Cardiac Surgery Case study summary: Publishing data on mortality rates following adult cardiac surgery appears to be associated with a decline in mortality. There are various theories as to why this is the case, including competitiveness among surgeons which leads to a rise in performance, increased awareness among healthcare professionals, and public pressure for higher standards. However, there are also concerns that the apparent decline in mortality may reflect 'gaming' of the mortality data. Size of the prize: A decline in mortality rates is, in itself, desirable. The economic value depends on the value attributed to a statistical life and the costs of providing treatment under various outcomes/pathways. Taking a median value from a range of recent studies, the value of lives saved among those undergoing adult coronary artery surgeries in NHS centres in north-west England in 2005 was around **£55 million.** This suggests that the total value of lives saved per annum could **exceed £400 million** for England and Wales, if similar benefits were observed in all regions. ## Mastodon C - Identifying Nhs Prescription Savings From Big Data Case study summary By using data on prescribing practice across England, variations in spending on different classes of drugs can be identified. It is then possible to calculate the potential savings to be achieved by moving from prescribing branded to generic drugs. Size of the prize For statins alone, the study found that the NHS could save around **£200 million per year** by reducing prescriptions of branded in favour of generic versions. When extended to all classes of drugs, the total potential savings could amount to £1.4 billion per year, according to work by the British Medical Journal. ## A Patient Database For The Nhs - The Challenges To Extracting Value From Large Datasets Case study summary: A central NHS patient database could offer significant savings to the NHS as well as improving standards of care and the patient experience. However, there are significant technical, privacy and cultural hurdles to overcome if this is to be made a reality. This case illustrates both how attractive the prize of harnessing the power of large public sector information datasets can be, but also the difficulties these can present. Size of the prize: Difficult to estimate, but if the system is delivered as planned the savings are likely to run to billions of pounds. An initial illustrative estimate identified **£4.4 billion of potential savings**, although these are not all directly related to the patient database. The transport sector The transport sector is an example of rich data with a high velocity. The case studies below show how this data is being used to generate both narrow economic value and wider societal value. The break-out box below illustrates some of the areas of research and policy where sharing of data could generate new insights and lead to improved policy outcomes.147 ## Transport For London Data Case study summary: Transport for London has released considerable volumes of information on the London transport network, including live network updates. This case study assesses the value of time saved due to avoidance of disruption on the transport network by travellers, using data published by Transport for London and accessed via mobile apps. Size of the prize: The value of time saved due to avoidance of disruption in 2012 is estimated at between £15 million and £58 million, depending on the modelling assumptions used. This is likely to be a conservative estimate: for example, the figure would be higher if a higher value for working time were used instead of a valuation based on commuting. It also omits other aspects of value generated by Transport for London data, for example in routine (non-disrupted) journeys by allowing travellers to plan their journeys more efficiently. Nonetheless, this order of magnitude represents a significant annual time saving. By way of comparison, the HS2 impact assessment calculates operational time savings equivalent to £440 million per year in 2012 values. Therefore releasing relatively low-cost data, which is in many cases a by-product of other activities, may generate time savings versus a nominal baseline valued in excess of 10 per cent of the time savings resulting from a major national infrastructure project such as HS2. ## Traffic England Case study summary: Traffic England offers live traffic data to road users, enabling users to plan their journeys so as to avoid congestion, roadworks and other conditions likely to cause delays. They are thereby able to save time and reduce fuel waste. Size of the prize: As a high level estimate, if 50 per cent of monthly users save ten minutes each on their journeys over the course of a month, the value of time saved could equate to **£6.5 million per year**. This is likely to increase as more road users become aware of the service, and as increasing congestion on the UK road network increases the value of live traffic information. ## Improving Access To Fragmented Information - Roadworks.Org Case study summary: By providing a platform that combines information on planned and on-going roadworks into a single database, roadworks.org provides a resource for road users that allow them to easily see potential disruptions to their journey. It also reduces costs to local authorities from their own bespoke platforms, and improves communications between utilities companies and local authorities. Size of the prize: A recent ELGIN report estimated the total benefits at around **£25 million per annum**. This includes 'tangible savings' of £6.3 million to local authorities as a result of efficiency savings, and 'intangible benefits' of £19 million due to reduced congestion. ## The Public Sector The Final Set Of Case Studies Examine How The Public Sector Itself Is Beginning To Exploit Public Sector Information To Drive Efficiencies, Improve Public Services And Enhance Policymaking. | Description | |--------------------------------------------------------------------------------| | policy | | Social mobility | | Linking data on education, training, employment, unemployment, income and | | benefits | | Linking data on education, health, employment, income and wealth | | Causal pathways over the | | life course | | Support for the elderly | | Comparative analysis of access to and provision of social care support for the | | elderly | | Poverty | | Linking data on housing conditions, health, incomes and benefits | | Social care for children | | Linking indicators of parental employment, social background and childcare | | Offence and re-offence | | Linking data on offending and re-offending behaviour, income, benefits, health | | and mental health | ## An Example Of Data Sharing At A Local Level - Families With Complex Needs Examples of data sharing between local councils and other public bodies are proliferating across the UK. These are often responses to the twin pressures of deep funding cuts and intractable problems involving multiple agencies. An example of this sort of problem is the case of families with complex needs, often referred to in the press as 'troubled families'. These families may combine issues such as mental health problems, children out of school, and long term worklessness and benefit dependency, meaning that they fall within the remit of multiple public sector bodies including social services, the Police, and the local and national welfare services. These services are estimated to cost around £75,000 per family per year.148 Increased coordination between local councils and other local partners may prove both more cost efficient and more effective in resolving the problems faced by such families. The councils of Greater Manchester, Leicestershire and Bradford are working together to improve information sharing and management in this area. The project aims to develop a single toolkit for information sharing, combining existing guidance and approaches. This is intended to be applicable to both the councils and the agencies working with families with complex needs. In addition the project is intended to lay the foundations for a culture more conducive to information sharing, addressing issues such as different professional cultures of sharing, lack of training and expertise, and differing interpretations of legislation. In practice, the steps needed to achieve this can appear prosaic but are nonetheless potentially powerful enablers of an environment in which information can more easily be shared within and between organisations. As the project is still ongoing it is too early to judge its effects, whether in terms of reduced costs or improved outcomes. Nonetheless, this appears to be a positive example of the potential of greater sharing and exploitation of data between councils and other public sector bodies in response to a policy problem which has proved unresponsive to a siloed approach. ## The Justice Data Lab It is currently difficult for many providers of offender services, particularly in the voluntary and community sector, to access re-offending data relevant to the offenders they work with. As a consequence, organisations may encounter significant difficulties in measuring the effectiveness of their rehabilitation work with respect to a reduction in re-offending. The lack of access to high-quality re-offending information has also prevented some organisations learning from and improving the services they deliver; and has made it difficult or impossible for them to demonstrate their impact to commissioners. In order to address this problem the MoJ has set up the Justice Data Lab, announced by Secretary of State, the Right Honourable Chris Grayling MP in December 2012. It is currently in a pilot phase running for a year from April 2013. The Justice Data Lab will provide organisations with aggregate re-offending data specific to the offenders they have been working with, and that of a matched control group. This is intended to allow them to understand their specific impact in reducing re-offending. The intention is that supporting organisations by providing easy access to high-quality re-offending information will allow them to focus only on what works, better demonstrate their effectiveness, and, it is hoped, ultimately cut crime in their area. Participating organisations will supply the Justice Data Lab with details of the offenders they have worked with and information about the services they have provided. The Justice Data Lab will supply aggregate one-year proven re-offending rates for that group, and a matched control group of similar offenders. The re-offending rates for the organisation's group and the matched control group will be compared using statistical testing to assess the impact of the organisation's work on reducing re-offending. The results will then be returned to the organisation with explanations of the key metrics, and any caveats and limitations necessary for interpretation of the results. This is an example of how data of a personal, sensitive nature may be used to inform those who have a specific need for this data. It indicates that these barriers can be overcome in a manner that does not compromise ethical considerations around data protection and the right to privacy, while still allowing the data to be used to improve policy and service delivery including by third parties. It also demonstrates the notion of data being a 'two-way street' between PSIH and user, noted elsewhere in the study, which can lead to improved outcomes for both parties. However, this example also indicates that some investment into data analysis capability is likely to be required on the part of the public sector information holder (in this case the MoJ) - in other words, there is a cost involved. Depending on the success of this pilot over the course of 2013-14, it may be that this provides a model for granting controlled access to similar datasets held across the public sector. Source: www.justice.gov.uk/downloads/justice-data-lab/justice-data-lab-user-journey.pdf ## 'Blue Sky' Opportunities In addition to the specific examples already discussed, there are many areas in which public sector information may have a positive impact in the future. Foresight, part of the Government Office for Science,149 has carried out a number of studies which highlight the role public sector information could play in improving our understanding of and ability to respond to the challenges our society confronts. These are summarised below.150 ## Detection And Identification Of Infectious Diseases (2006) Novel Information Technology for the Early Detection of Infectious Disease events. This project identified a 'Grand Challenge' around using modern information and communication technology systems to gather and interpret timely and relevant data, and to deliver it to those managing an outbreak. ## Tackling Obesity (2007) On-going data collection and evaluation relating to the effect of different interventions was proposed as a core principle in tackling obesity. This was seen as a particularly important in view of the uncertainties surrounding the efficacy of certain interventions. The project stimulated the creation of the National Obesity Observatory - but much more remains to be done. Mismatches between policy and research timescales remains a fundamental challenge. ## Global Food And Farming (2011) Policy makers are hampered by conflicting results from different models associated with the food system. The project argued the need to substantially improve datasets that provide the basis for model calibration and comparison. The project brought together a forum of modellers to help take this forward. ## Computer Based Financial Trading (2012) Improving collection and access of financial transaction data was a key recommendation: a trusted 'European Data Centre' was proposed. Such data would be a crucial new tool for regulators in identifying abuse spanning different markets. Also, if made easily available, it could unlock the resources of the scientific community to better understand evolving markets, and so help policy makers in the 'arms race' with algorithmic trading developers. ## Reducing The Risks Of Future Disasters (2012) The report argues the need to improve the infrastructure for data collection for hazards: e.g. better coordinated effort on satellites and sensors. It also proposes establishing a much needed database of evidence on the costs and benefits of interventions to reduce disaster risk. Importantly, the data in such a repository would need to be quality assured, and easily accessible to decision makers at different levels in different countries. ## The Future Of Identity (2013) The report considered how notions of personal and social identity in the UK might change over the next ten years. Policies will need to take into account the multiple nature of identities and how policies might affect groups differently, or individuals' different times and places. The report explicitly considers the commercial value of identity through the use of 'Big Data'. This is likely to become crucial to private sector organisations, but also has the potential for criminal exploitation, for example through opportunities for identity theft. ## Chapter Summary  The value of public sector information can be disaggregated into four broad categories according to the beneficiary: o the direct value of public sector information to producers and suppliers (the PSIHs): these are the benefits accruing to producers and suppliers of public sector information through the sale of public sector information or related value-added services; o the indirect value of public sector information arising from its production and supply: the benefits accruing up the supply chain to those organisations interacting with and supplying PSIHs (but not directly using or re-using public sector information), and the benefits accruing to those organisations where employees of PSIHs and supply chain organisations spend their wages; o the direct use value of public sector information to consumers of public sector information: the benefits accruing to businesses, civil society, individuals and the public sector from directly using and re-using public sector information for a variety of purposes; and o the wider societal value arising from the use and re-use of public sector information: the benefits to society of public sector information being exploited, which are not readily captured elsewhere.  The first three value categories can be grouped together as narrow economic value and have been estimated at £1.8 billion p.a. for the year 2011/12.  The wider societal value of public sector information is harder to estimate. Public sector information can benefit society through a number of routes including: o increasing democratic participation: giving citizens and businesses access to public sector information allows them to perform their own analyses of salient issues, make more informed choices about public service providers and interact with policymakers to challenge their assumptions and improve the policymaking process; o promoting greater accountability: for example through the scrutiny of costs of public service provision and benchmarking comparable services; o greater social cohesion: for example, by providing more information on the provision and distribution of services, public sector information can be used to dispel myths on who receives certain public services; o generating environmental benefits: such as reducing congestion and pollution through the release of better traffic and transport data which helps drivers to better plan journeys; and o identifying previously unknown links between different policy areas: through data mash-ups it may be possible to develop system-wide solutions that holistically seek to address the root of policy challenges.  This value is potentially significant and is likely to have a major influence on overall societal wellbeing. A conservative estimate of the wider social value of public sector information suggests a value at least three times the size of the £1.8 billion economic value may be appropriate, i.e. over £5 billion p.a.  Adding this wider social value estimate to the calculated value of public sector information to consumers, businesses and the public sector, gives an aggregate estimate of between £6.2 billion and £7.2 billion in 2011/12 (2011 prices). ## 6. Barriers And Policy Implications Using a taxonomy originally developed by the Data Strategy Board, this chapter considers the current barriers to the UK in fully realising the benefits and value of public sector information. The analysis is based on discussions with stakeholders and a review of the evidence. The chapter also considers the policy implications of each barrier. The Shakespeare Review will be making its own recommendations on which barriers and associated challenges it believes are the most important and the steps that can be taken to address these. ## Generating Value Having reviewed the literature and evidence, it is apparent that the two main ways in which value is being generated currently, which will likely remain the case in the future, is through data discovery and data exploitation. The former relates to making better and, in some cases more, public sector information available and making it more accessible - what might be loosely term supply-side considerations. The second dimension relates to using and re-using public sector information better - demand-side considerations. This might be through reducing consumer risk aversion to using public sector information, improving data exploitation techniques, changing cultures and improving data analysis skills (which, in turn can improve competiveness). The light blue boxes (which are not to scale) represent the value that is currently being generated from public sector information, with the first light blue box on the left showing the current value from data discovery and the second light blue box the current value through data exploitation and data science. The dark blue boxes illustrate the additional value that could be achieved if (i) better quality public sector information was released, (ii) more was made more easily available; and (iii) more public sector information datasets were released. While, in some cases, more public sector information being available can also increase value, it is important to note that there is not a linear relationship between quantity of public sector information and its value. What is key is the quality of this data and its amenability to data analytics. Simply releasing more datasets, irrespective of their quality, is likely to only have a minimal value impact. More effective ways of data exploitation can include:  greater system-wide analysis through more sharing and combining datasets together to consider policy and business issues from a range of non-traditional perspectives;  unlocking the potential from linked data: and better integrating; and  greater data-mashing with private sector and individual datasets. Value is thus generated through exploring existing datasets to identify insights through statistical analysis, 'data-mashing' and visualisations. The value of public sector information in the UK can therefore be increased both by increasing the quality, and in some cases quantity, of datasets available/accessible (increasing the potential for data discovery) or by better using existing and new datasets (increasing data exploitation). This raises the question of what the barriers to the UK fully exploiting the value of public sector information are, and what the size of this potential value may be. A taxonomy of barriers This report adopts a taxonomy originally developed by the Data Strategy Board, which illustrates the four main areas where challenges or barriers may currently exist. This taxonomy of barriers is shown in Figure 6.2 below. ## Source: Adapted From Dsb Legislative barriers include whether certain acts of legislation and other regulations reduce the usability of public sector information datasets by consumers. There are also further questions over whether current assurance/accreditation standards for public sector information remain effective and whether there is scope for existing licensing arrangements to be improved. Economic barriers include questions as to which datasets to release (which datasets yield the highest value) and how their costs (if any) should be covered. Access barriers to maximising the value from public sector information can include:  a reluctance to publish or share datasets;  a bias against using non-traditional datasets;  a reluctance to use public sector datasets because of concerns around quality, reliability and on-going support; and  a lack of skills to fully exploit the value of public sector information. It should be noted that the extent of these barriers may differ between public sector information datasets and also between the different types of users. Each of these barriers is discussed in more detail below, alongside the relevant policy implications. Note, due to the overlap in some of the taxonomy areas, the narrative below does not always follow Figure 6.2 exactly. ## Legislative Barriers Privacy and the impact of current regulations and legislation The review of available evidence suggests that, by and large, the current legislative and regulatory environment around public sector information is not acting as a barrier to generating value and market development. While a full legal analysis has been beyond the scope of this study, particular acts and regulations such as those covering Data Protection and Human Rights legislation have not emerged as preventing the development of new products or services using public sector information151. The majority of stakeholders consulted have not reported that these generic legislative acts are currently preventing them from using and re-using public sector information, but, in some cases specific legislation controlling a particular data collection exercise do. However, the evidence received does suggest there are some current challenges around perceptions and attitudes towards data release. In particular:  regulations such as Data Protection are sometimes used as a shorthand justification for not sharing public sector information within the public sector, with PSIHs not always able to translate their awareness of their rights and duties into scenarios where public sector information is released or shared, causing a barrier; and  when a policy decision is taken not to release public sector information datasets to the general public, the reasons are often not well articulated or the conditions attached to access are overly restrictive. Some stakeholders have cited examples where the Data Protection Act (and other legislation) has been used as a reason for a PSIH to withhold information from the general public. However, as noted in previous chapters, in reality, the Act should rarely be a barrier to sharing information. Where public sector information datasets do contain personal details, these may need to be aggregated or anonymised. Where this is done effectively the Data Protection Act, in most cases, no longer applies to the information and it can be made available. This is not to downplay data protection issues. The impact of breaches leading to release of personal information can be extremely serious. Further, even if data is anonymised, PSIHs may be reluctant to release it if they believe it can have wider consequences, e.g. reporting crime data may adversely affect house prices152. These issues notwithstanding, PSIHs are beginning to use innovative methods to test different ways of anonymising datasets - for example the Ministry of Justice worked with statisticians, the private sector and the academic community to avoid the 'jigsaw effect'153 occurring from the release of offender data (see Chapter 5). ## Access To The General Public With respect to other access restrictions to public sector information datasets (such as the datasets only being available to researchers or in secure environments) arising from specific pieces of legislation, in many cases the rationale for these restrictions are clear. The rationale may cover national security reasons or genuine data protection concerns. In many cases this data is released only to licensed researchers, and some stakeholders questioned the value of making it available to the wider public since its applicability is to a specialised area of research. However, other stakeholders have reported that in some cases, the rationale for restrictive access to certain datasets is not always clear, overly restrictive or no longer relevant. For example, some start-up companies have reported difficulties in accessing different versions of the National Pupil Database as non-research organisations (see case study below). While restrictions on access are in this case clearly needed to protect sensitive and personally identifiable information; there is a valid question as to whether there are ways that some or all of this information could be made available to commercial organisations to develop new products and services to help parents, teachers and other stakeholders to improve decision-making, increase accountability and identify good practice. Without this, opportunities for innovations using this and other datasets are likely to be missed, meaning loss of the value that they could potentially create. ## Case Study: The National Pupil Database The National Pupil Database (NPD) was created under the School Standards and Frameworks Act 1998, which instituted a legal gateway permitting the collection of personal data about students without their consent or the consent of their guardians. The information was to be drawn directly from school management systems. Until the late 2000s students and parents were not informed that this information was being collected and stored. Since 1998, the National Pupil Database has expanded to contain ever more information about students. From initially being an annual census, information is now collected every term, and has expanded to include preschools, any provision of childcare that is funded by the state, exclusions of students and the reasons for exclusion, recipients of free school meals, and the mode of travel to school., among other fields. Because the initial gateway offered something approaching carte blanche in terms of the information that could be collected, it has been gradually expanded according to the needs of policymakers. This means that the NPD is tremendously rich as a source of data. It also means that it contains a wide range of potentially sensitive and personally identifiable information. This information is stored permanently, often without the knowledge and in any case without the consent of the subject. The NPD therefore creates a dilemma. On the one hand, the insights that could be derived from this information, especially when combined with other sources of information, are tantalising. For example, it offers researchers and policymakers a route into understanding the drivers of educational attainment, behavioural problems among children, and social mobility in later life. This information could also be used to generate a range of value-added services and products by private companies. On the other hand, there are clear risks associated with the holding and sharing of such a quantity of sensitive personal information. For example, information about exclusions of pupils, including the reason, is stored indefinitely. If this information were to be released in an identifiable manner it could have a compromising effect on the individual in later life, for example when applying for work. The Department for Education currently has a well-developed process in place for access to the information to safeguard against negative outcomes. Those who require access are required to demonstrate that this information is necessary research into the education achievements of pupils. The requests are processed by the DfE Data and Statistics Division (DSD), with requests for Tier 1 data (information that is both identifiable and highly sensitive) referred to the DfE Data Management and Advisory Panel. Where access is approved, ## Case Study: The National Pupil Database the DSD manages the supply of data. In November 2012 the DfE launched a consultation on widening access to the NPD, with a view to granting access to: "persons (i) conducting research or (ii) providing information, advice and guidance or (iii) data based products and services for the purpose of promoting the education or well-being of children in England and who require individual pupil information for that purpose." However, these changes may still preclude some potentially valuable uses of the NPD. Restricting access along the lines children's 'well-being' potentially forecloses innovative non-educational analyses. For example, a researcher exploring links between educational performance and culture or the environment would have to seek to justify their use of the NPD in 'well-being' terms - this may not be straightforward. Equally, always having to specify a reason for requesting the NPD may prevent speculative research or 'randomised' data-mash-ups. Despite this, the personal nature of the information inevitably makes this a sensitive topic, as it may be felt that widening access increases the risk of accidental disclosure of the information, as well as allowing information to be used in ways the data subjects have not consented to. In its response to the consultation the ODI cited a number of uses to which aggregations of data from the NPD could be used as inputs to products and services developed by start-up business, but stated that "the aggregations these applications require could be generated by the Department for Education. None of these services require access to individual-level data."154 This case therefore illustrates the complexity of the barriers to access in cases of sensitive, identifiable information, and the tension that may arise between the right to personal privacy and the potentially rich uses of datasets containing personal information. At the time of writing, the DFE NPD consultation had closed with a response expected soon. Source: partially based on an ODI talk, 'Getting to grips with the National Pupil Database, 15th February 2013. Slides available at www.scribd.com/doc/125638490/Getting-to-grips-with-the-National-Pupil-Databasepersonal-data-in-an-open-data-world See also www.education.gov.uk/researchandstatistics/national-pupil-database/b00212283/national-pupildatabase The case study below illustrates the case where the value of public sector information remains locked not for reasons of restricted access or cost, but simply because a given dataset is not being made available. ## Honest Buildings - 'Linkedin For The Real Estate Market' Honest Buildings is a start-up that originated in the United States but is now expanding into the UK, and to this end is currently working with the ODI in London. It provides an example of how greater availability of public sector information can be combined with private sector and crowd-sourced information to generate new efficiencies in an industry sector. The real estate sector - covering owners and occupiers of buildings, as well as providers of building services and improvements - currently depends on a relatively cumbersome approach for most interactions between parties. For example, businesses searching for new premises, or for improvements to their property are forced to enter into a potentially lengthy and resource-intensive process of inviting potential suppliers to tender for work. Honest Buildings offers a platform similar to LinkedIn for the real estate industry, providing profiles for buildings, organisations, projects and people. The idea is to build up a transparent, searchable network of information on buildings, their owners and occupiers, suppliers of services and their project histories. This should make the process of interactions between these parties much more efficient, as potential buyers of services will be able to receive more relevant, informative tenders and suppliers will be able to adopt a more focussed approach to business development. Michael Adler, former CFO and executive vice president of the travel website Expedia.com, has said: "Honest Buildings is bringing the same type of efficiencies to the real estate market that ## Honest Buildings - 'Linkedin For The Real Estate Market' Expedia And Trip Advisor Did To The Travel Industry."155 Much Of The Information On This Platform Will Be Crowd-Sourced From Building Owners, Occupiers And Service Providers, But Honest Buildings Also Supplements This With Public Sector Information In Order To Add Additional Value. This Includes Property Prices, Rates, Details Of Building Specifications And Energy Efficiency Details. Honest Buildings Source: http://www.honestbuildings.com/ Honest Buildings already have a presence in nine cities in the United States. In addition to their wider social networking platform they have also found success providing platforms for energy efficiency programmes in New York State and Connecticut. They are hoping to get involved with analogous initiatives in the UK like the Green Deal, GLA's RE:FIT programme, Cambridge Retrofit along with other major public/private sector led building initiatives. The Green Deal allows consumers to have a range of energy savings improvements made to their homes and then pay for the work through additions to their energy bill. This would allow the government and suppliers to more efficiently target those buildings with an Energy Performance Certificate (EPC) of F or G, the lowest ratings and therefore the highest priority for energy saving upgrades. RE:FIT and Cambridge Retrofit provide a framework focused for non-domestic buildings to be upgraded in the public sector in London and in the public and private sector in Cambridge respectively. The potential economic benefits of widespread uptake of the Green Deal are significant. For example, this could generate large savings on domestic energy bills. The Energy Saving Trust calculate that loft insulation of 270mm could save the average three bedroom house up to £180 per year on their energy bill, and double glazing could save around £170 per year.156 If 20 per cent of the UK's approximately 25 million households were able to achieve these combined savings of £350 per year, this would equate to an annual saving on domestic energy bills of £1.75bn. In addition, and more directly relevant to the current focus of Honest Buildings, there is also the potential for savings on the energy bills of commercial properties. The scale of the potential savings is more difficult to ## Honest Buildings - 'Linkedin For The Real Estate Market' estimate as there exists no comprehensive register of the UK's commercial property stock. In addition commercial buildings are more heterogeneous in nature, meaning that it is more complex to assess the benefits of energy saving measures. As an indication, the 2010 DECC impact assessment for the Green Deal calculated potential energy savings of between £170 million and £330 million, based on an additional uptake of energy saving measures of 10 to 20 per cent above a business as usual scenario. However, these savings are set against capital costs of between £75 million and £140 million.157 These are indicative estimates, but demonstrate the scale of the potential saving from widespread uptake of the Green Deal. They also omit the downstream impact, including improved energy security due to less reliance of imported energy, reduced carbon dioxide emissions and other negative environmental externalities, and greater consumer spending power due to reduced energy bills. In addition, there is likely to be a wider economic uplift due to the generation of green jobs, support for the construction industry, and increased demand for raw materials, many of which can be sourced within the UK and would therefore not need to be imported. A recent study on the non-domestic Green Deal indicated a potential market size, for SME uptake of Green deal measures, of between £470 million and £800 million by 2020, depending on the rate of uptake.158 This would provide a substantial economic stimulus to this sector of the economy. There is, in addition, a potential legislative imperative to upgrading building energy efficiency. It is proposed to ban the rental of buildings gaining an F or G EPC rating. According to Honest Buildings this applies to an estimated 20 per cent of the UK's building stock, and at the current time such a ban would therefore throw the real estate market into crisis. Upgrading this stock is for this reason likely to become a priority over the next decade, and a task of this magnitude will require an efficient and transparent approach, with property owners fully aware of their supplier options and the relative costs and benefits of each. Honest Buildings therefore appear to be an example of innovation using public sector information which could generate a range of tangible economic benefits, from energy savings and job creation to reducing transaction costs across an entire sector. However, there are barriers to accessing the information required. Most importantly, EPC register, administered by Landmark Information Group, is not currently accessible. Honest Buildings report that Landmark claim they are unable to give access to the database due to their contractual obligations to CLG. The EPC register is an example of 'by product' data - although there might be a small cost associated with making it publically available (due to hosting requirements and user support), there would be no additional collection costs as this is data that is collected in the course of the normal operations of the EPC scheme. Release of this data therefore appears to be a win-win option which could unlock considerable potential value without leading to a loss of revenue or incurring significant costs to the information holder. More generally, Honest Buildings has identified issues with fragmentation and disconnect across the public sector's approach to information. It has frequently found it difficult to find the information needed, and that where this has been possible to locate, access has sometimes been stymied by confusion over permissions and ownership, meaning that information holders do not feel empowered to release the information. This reinforces the argument for greater coordination and clarity in the public sector's approach to information, with an 'open by default' assumption for information and a clear framework defining the rules around information release. Support for providing information about what data is available, whether through centralised catalogues or decentralised search, would also help guide potential users to the information they need. In addition to the barriers discussed above, there has been much discussion about core reference datasets in the context of the debates about releasing the Postcode Address File159. ## Access Within The Public Sector Within the public sector, there are also questions surrounding the legal ability of different public bodies to share datasets with one another. These have been explored in depth in the recent report by the **Administrative Data Taskforce**160. It notes that as regards the legal gateways established to allow departments and other public sector bodies to share information without obtaining the consent of the data subjects, "recent experience demonstrates that link-specific gateway legislation is both cumbersome and inefficient." As a solution to this the Taskforce recommends the creation of a generic legal gateway to reduce this barrier to the exploitation of public sector information and clarify the legal position around sharing data. Note that this applies to sharing of data within the public sector and with certain accredited third parties such as researchers, rather than publication for use by the general public. Insights  Existing regulations and legislation governing public sector information do not appear to be acting as actual barriers to realising the full potential value of public sector information. However, the manner in which some of these regulations and legislation are interpreted can lead to overly risk averse behaviour and can create barriers.  Increasingly effective anonymisation techniques and an approach across the public sector that emphasises granting access to as much data that is compatible with privacy and security has the potential to improve access to public sector information.  The eligibility restrictions imposed around certain datasets are typically due to reasons of national security, data protection and other sensitivities.  The rationale behind these restrictions is not always clearly articulated and may, in some cases, no longer apply. In some cases, this may be preventing opportunities for innovation to take place. Licences Licensing conditions play an important role in facilitating (or preventing) the full exploitation of the value of public sector information. The ideal standard widely acknowledged by stakeholders is licensing public sector information under the Open Government Licence (OGL), and increasing amounts of public sector information are being made available as open data under this licence, even by organisations that have traditionally charged for data. For example, Ordnance Survey has released 11 datasets as open data, there are over 6.000 downloads of Land Registry's linked data each month and the Met Office and Companies House have also each opened up some of their data. There is therefore a visible trajectory towards a world in which increasing volumes of high quality data are available at low cost or for no charge to users. Nonetheless, some groups of stakeholders have argued that if the OGL were used for all public sector information, this could substantially increase the openness of the UK's public sector information and could remove many of the barriers to use and re-use that currently inhibit the realisation of the full value of public sector information. The Open Data User Group, as a strong advocate of the OGL, has noted that "it needs to become widely adopted to make the right to data a reality. Conversely, if publishing under the OGL does not become the default action for public bodies, the right to data will remain an aspiration."161 Indeed, it can be argued that should the OGL become the standard licence across all public sector bodies, this could substantially increase the openness of the UK's public sector information and could remove many of the barriers (both in terms of charges levied and restrictive copyright and reuse conditions) that currently inhibit the realisation of the full value of public sector information. However, others have argued that the public sector information landscape is characterised by its diversity, and for this reason a 'one-size-fits-all' solution is unlikely to be practical or necessarily desirable. For cases where the release of information under the OGL is not considered appropriate and cost recovery is justified, the introduction of a generic charging licence could, in principle, address the current complexity of charging arrangements for public sector information, completing the UK Government Licensing Framework and simplifying licensing arrangements for users. Some stakeholders pointed out that by having a charge, users and re-users can be re-assured of the quality of data and be able to expect a certain level of service (this is discussed in more detail below). However, one concern raised was that such a licence could encourage some PSIHs who are not covered by the OGL to charge for certain datasets. Insights:  Making public sector information available under the Open Government Licence is seen by a large number of stakeholders as an effective means of removing barriers to exploiting the value of public sector information.  If there are instances where a generic Government Licence for charging for public sector information are applicable, such a Licence would need to be drafted in a way to avoid incentivising charging when there is no strong justification or leading it to become the default alternative to the Open Government Licence. ## Economic Barriers The evidence reviewed suggests a number of key economic barriers around maximising the value from public sector information in the UK. Primarily these relate to the value and cost of datasets, which can be grouped into two key themes:  which datasets are made available to the general public; and  which datasets consumers have to pay to access for (funding models). Data gaps There is currently no national or local information asset register covering the amount and type of public sector information datasets held162 (irrespective of whether it is being released to the public) or the detailed costs of collection and dissemination. Similarly, there is little evidence as to how consumers themselves are using and re-using particular datasets. While this has meant this report has been forced to make a number of assumptions in order to reach quantitative estimates, there is a more significant impact on PSIHs themselves. By not being able to accurately ascribe value to different datasets, PSIHs are generally unable to reach evidence-based decisions as to which datasets to publish, how to publish them and what support to provide. One consequence of this is that the costs (which are readily measurable *a priori*) of making particular public sector information datasets available may appear to be much larger than the benefits - as the benefits case cannot be clearly set out due to a lack of evidence. Indeed, as part of this report, a sample of government officials have been consulted over the reasons why public sector information datasets are not released: over 50 per cent of those responding identified resources as an issue preventing the release of more public sector information, with the following response being typical: "in a time of diminishing resources and the need to make best use of the resources we have, the time and the cost of ensuring data validity before release is an issue." This was one of the most common reasons given for why data is not released, but not the only one - others include data protection and legislation. Stakeholders have identified particular datasets (such as an aggregate Energy Performance Certificate database) that are currently not available to them (either for free or for a fee) that they could use to generate new products and services. By not making these datasets more widely available (or articulating the reasons they are not available), PSIHs may, whether knowingly or not, be acting as a barrier to realising the full potential of public sector information. There are various routes to address these data gaps. One route might involve conducting a public sector-wide audit of public sector information (which also covers the customers using and re-using it). This would involve both primary research to determine the stock of public sector information held across all PSIHs and also identifying how this data is being used commercially across different economic sectors and actors. This would help match costs and benefits to individual datasets and building this report to identify those datasets that can generate the most value for the UK. The costs of doing such an audit would not be insignificant and for it to be effective, it would need to be repeated in future years (though the on-going costs may be lower than the one-off startup costs). However, the benefits of doing such an audit could be outweighed by the benefits of PSIHs having a much better sense of which datasets are creating the most value which can guide future policy decisions around releasing data. Other routes to addressing data gaps might involve better tracking of usages (perhaps through measuring how often data is re-used in other sources), requiring all new public sector information datasets to be logged centrally, or crowdsourcing an audit across the public sector. Another potential route for the long-term, at least conceptually, might be a true single conduit for the access of all public sector information. The Open Data User Group (ODUG) has been set up as an advisory group to Government and provides a channel through which the potential users of data, from all areas of the community, can identify their need for data and set out the benefits they expect this data to deliver. This will help PSIHs understand in more detail the potential benefits which the release of individual datasets can be expected to deliver. Through the completion of data gaps, it would be possible for government to articulate what is meant by the term core reference dataset (beyond the definition contained in the Open Data White Paper). The issue of core reference datasets is also raised in recent work by APPSI on the national information framework for public sector information and open data. 163 Consideration could include:  the features of a particular dataset that make it a core reference dataset;  the funding arrangements of core reference datasets (see below);  the obligations of suppliers of core reference datasets; and  the rights of citizens to core reference datasets. Insights:  There are significant data gaps when it comes to public sector information. This lack of data can, in some cases, lead to inertia with certain public sector information datasets not be released or conversely, undue attention being given to datasets that are unlikely to generate significant value but have a low cost of dissemination.  There are a number of routes to addressing these data gaps. These range from a detailed, regular audit of public sector information to improved tracking of current usage. Funding models Related to the question of making the business case for more public sector information being released is the issue of how the cost of generation, collection, retention and dissemination of the datasets should be funded. This also leads to questions around pricing for access to public sector information. This is a complex issue and data on costs (and benefits) is not readily available. Further, one must take account of different costs being incurred across the different stages of the data lifecycle. For example, in the case of so-called 'exhaust' or 'by-product' data that is generated as a result of PSIHs conducting their day-to-day and other activities and duties, the marginal cost of its generation will, by definition, be negligible or very low compared to the activity that caused the data to come about; but the marginal cost of its dissemination to the wider public may be higher and vice versa for some 'purposely collected data'. There will also be additional costs in formatting the data for use and further costs if support is provide to the public in re-using the data. The issue of charging and funding models for public sector information is highly contentious and extremely complex. For example, there remains an element of subjectivity as to what constitutes a dataset and what constitutes a 'value-add' service - with some PSIHs arguing that what is being charged for is not the public sector information but its interpretation and analysis. As part of this report, a wide range of opinions have been expressed as to whether there is any economic or other justification for charging for public sector information datasets. On the one hand, these arguments include:  charges for datasets create barriers to entry and expansion for SMEs and individuals to develop new products and services;  the charges prevent SMEs and individuals from 'experimenting' with the datasets before they purchase to see if they are able to derive value from them, thereby making it hard to develop business cases; and  any lost revenues to PSIHs from releasing datasets for no cost will be recovered by the Exchequer in the long-run through increased tax revenues and more jobs being created. In contrast, arguments have been put forward to support current pricing arrangements include:  aligning a revenue stream with a particular dataset will 'protect' it from any reductions in funding, allowing PSIHs to continue to supply this even if they themselves must make other savings;  a price can be interpreted as a signal of consumers' willingness to pay for a particular dataset's quality and a commitment by the PSIH to maintain this and offer support; and  charging for certain datasets is necessary given they include elements of commercial or international datasets. As the most visible PSIHs that charge for certain public sector information, a great deal of attention has been focused on the four Trading Funds that make up the Public Data Group (PDG): Ordnance Survey, the Met Office, Land Registry and Companies House. The view has been expressed by some start-up companies that these PSIHs hold some of the most valuable datasets and there are strong arguments that these should be treated as core reference datasets available to all at no direct cost to the general public. It is not helpful to treat these PSIHs as a single group - indeed, there are a number of other public bodies that charge for access to datasets164 and there are a number of other Trading Funds outside the PDG. The four Trading Funds in the PDG differ in their sources of revenue, their public service duties and whether the public sector information they hold can be classed as 'exhaust' data or 'purpose-collected' data. Further, it should be noted that substantial progress has been made by the four Trading Funds in recent years to make increasing volumes of data available as open data165 and there continue to be moves in this direction. However, despite these positive steps, there remains a perception among many consumers and commentators166 that they are unable to access certain datasets for reasons of cost and this is creating a barrier to business growth. A number of studies (e.g. Pollock, 2011 and others - see Appendix 3) have argued that releasing these datasets as open data will have significant welfare benefits. The impact of cost recovery model for public sector information, compared to the Open Government Licence model, is summarised below. ## Information Market | Taxpayer funded public sector information | |----------------------------------------------| | recovery basis |  Access to public sector information involves a cost to the user and may come with restrictions  Public sector information typically made available at no cost to users under the Open Government Licence  There may be strong public policy reasons for having these datasets available at no cost  The costs of collection (rather than dissemination) are significant and cannot be borne by the public purse  May include other data sourced under licence  Will not include other commercial or international datasets  Access to Public sector information is restricted on the basis of cost  The availability of public sector information at no cost to the user can contribute to the transparency agenda by increasing access to the widest possible customer base, irrespective of the ability to pay  Will not typically include other services or any other guarantees  May also include bespoke value-add services and guarantees of data quality and continuity Source: Deloitte analysis It is very difficult to perform a robust cost-benefit analysis of different funding model options for PSIHs, not least because PSIHs differ greatly from one to the next. While some data is available as to the costs incurred from collection and dissemination, this is not typically openly available or apportioned by dataset, nor is data readily available on how their customers are using the datasets and generating revenue and value. More fundamentally, very little data is available on what the benefits might be if charging models were to radically change - as it is very difficult to predict how businesses and individuals might use datasets in the future to generate new products and services, and by implication impact economic growth. It is also important to note that, as per the HMT Green Book167 guidance, any benefits from a change in charging structures should include not just increased tax receipts but wider social benefits and costs in terms of organisational impacts. Even in the case of the four Trading Funds that make up the PDG, estimating the effects on Exchequer revenue of releasing all their public sector information as open data is a difficult task, in spite of the information made available by the Trading Funds as part of the study. There are differing views on precisely which revenues should be considered relevant to PSI, considering factors such as specific revenues from the data, the cost of collecting the data, the extent to which Government 'buys' data from itself and so forth. That notwithstanding, on the basis of the information made available to this study, it is possible to indicatively calculate that the cost effects on Exchequer revenue of continuing to collect and disseminate Trading Funds' public sector information in its current guise without charging for it. This cost is estimated to be in the order of £395 million on an annual basis168. However this figure is without regard to the extent that Government pays for public sector information from the four Trading Funds in the PDG (this varies significantly between Trading Funds). On the basis of information provided on sales channels, it can be estimated that the annual loss to the Exchequer would be lower, as government would no longer need to purchase these public sector information datasets - it could use them at no cost. In this scenario, the loss to the Exchequer on an annual basis might be of the order of £143 million. This figure may be lower still if there are efficiency savings to be made if fewer dedicated sales and marketing resources are required by Trading Funds. Following the HMT Green Book approach to account for the wider social and economic benefits, it is important to note that in a world without charging, private sector entities (consumers and businesses) that currently pay for access to public sector information provided by the Trading Funds would benefit by this amount - around £143 million - and some of this may be recouped in the medium-term as a result of additional economic activity generating tax revenues. An additional group that is currently deterred by having to pay for the data would also benefit as they are able to access the data. Estimating the size of this latter group is difficult but directionally it is clear that removing charging would mean more people and businesses, not fewer, would be able to access and benefit from this data169. Conversely, organisations who are at an advantage in using their own proprietary information for commercial advantage, might find their competitive advantage eroded if more public sector information is released to act as a publically available substitute to that data. The situation is thus complex, and while the above example is stylised, it does suggest the quantum necessary for the associated benefits to outweigh the costs. Without more detailed and accurate data on both costs and benefits (including wider social benefits) it is not possible to reach a clear conclusion on this issue. However, this is not to say there is no room for improvement today in the provision of public sector information that carries a charge and a number of steps are being taken in this respect. These include:  much more communication about what existing licences allow consumers to access and use / re-use the public sector information for, building on existing efforts by the trading funds and other PSIHs to build awareness among the user community;  offering substantial discounts to SMEs and individuals;  implementation of a 'royalties' model for consumers to exploit the value of public sector information up to a certain value before a charge is applied;  greater provision of 'sandbox' or secure environments in specialised locations across the UK to allow consumers to explore datasets;  greater provision of out-of-date public sector information at no cost to the general public to allow consumers to experiment; and  greater use of 'hack days' to demonstrate the value of particular public sector information datasets. These options have not been costed or their benefits estimated. A number of these initiatives are already being pursued and there appears scope and benefit to their wider roll-out. Of course, not all of these initiatives will be applicable to all PSIHs that charge for public sector information - there is no 'one-size-fits-all' model - but they should work with the grain of the market and build on existing initiatives to release more data. In some cases there may be significant logistical or legislative challenges to overcome before the above suggestions are implemented. For example, under the IFTS differential charging is prohibited; and a single sandbox model may not effectively meet the needs of all developers. There are also questions whether PSIHs can effectively separate communication and marketing efforts promoting the use of their public sector information from marketing to promote their value-added services which may be in direct competition with the private sector. Insights:  The issue of charging for public sector information datasets and their funding models is complex. While significant progress has been made by a number of major PSIHs in this area in simplifying charging structures and making more public sector information available as open data, there remains a perception that barriers exist and there is scope for improvement.  Ways to improve access could include greater communication on licence conditions, discounts to certain consumers, a royalties model, use of a 'sandbox' model, greater provision of out-of-date information and more hack days.  There is currently a lack of data to definitively conduct a cost-benefit analysis across different funding models across the range of PSIHs currently charging. This is an area for further analysis through primary research with the direct customers of public sector information and a detailed cost apportionment exercise to assign costs to individual datasets. ## Access Barriers The evidence reviewed suggests a number of access barriers to fully maximising the value of public sector information:  difficulties around finding where public sector information is located;  a lack of skills and understanding to fully exploit public sector information;  the format and reliability of public sector information; and  a reluctance to use and share public sector information. Public sector information fragmentation Fragmentation in the supply of public sector information continues to be a problem for many consumers, even following the establishment of a number of data portals. A sample review of websites done as part of this study has found that too often it is difficult to locate a clear point of contact, or establish who has ownership of and responsibility for a particular dataset. Even on data.gov.uk, where contact details are provided, these are often generic enquires email addresses rather than named contact email addresses. In contrast, this report has received feedback that when consumers have found the relevant point of contact in a PSIH their experience has been very positive with a productive dialogue being established. Indeed, some individual PSIHs have established clear procedures for consumers seeking to raise queries or challenge restrictions, although this is not yet happening in all areas of the public sector. Dialogue can also take place between users: data portals such as data.gov.uk and the London Datastore have busy forums and request pages which encourage an active dialogue between information users and re-users and information holders. Public sector information fragmentation can, at best, raise transaction costs from dealing with public sector information and, at worst, deter users and re-users from using public sector information altogether, or make this impossible to achieve. Reducing fragmentation across the public sector could save up over £50 million per annum in terms of reduced transaction costs and time saved for data specialists170. However, it should be noted that the existing fragmentation and opacity of some public sector information datasets has created market opportunities for some intermediaries to develop new products that aggregate datasets and present it innovative ways. Thus, PSIHs need to consider who is using their data and how and whether there is a risk of crowding out innovation if they intervene to reduce fragmentation in such a way that duplicates what the private sector can provide. Insights:  Improvements are on-going to reduce the time taken to locate public sector information datasets. Reducing this can help reduce transaction costs and the overall cost of doing business. Data scientists and the skills gap A number of studies have recently been published contending that advanced economies face a skills gaps in so-called 'data scientists'. Although statisticians and experts on quantitative analysis have long existed, data scientists differ from these existing professions in a number of important ways. As well as being able to work with large volumes of structured and unstructured data, they are able to translate these analyses into policy and commercial-ready insights and effectively communicate them to a range of stakeholders, often using innovative tools and visualisations. Key to this is the ability to "identify rich data sources, join them with other, potentially incomplete data sources, and clean the resulting set." In many ways they therefore resemble scientists more closely than traditional data analysts. There is a fear that a lack of data scientists will reduce the UK's competitive advantage. The evidence received suggests that in the UK:  there is increasing demand for individuals with a portfolio of skills able to manipulate quantitative data, present it in innovative ways and generate commercial and policy insights from it;  many of the individuals performing these roles have no specialised training, but rather have learned on the job and / or have a science/computation/mathematics background;  businesses rarely designate specific 'data scientist' roles; rather, such analyses are done across a combination of professions such as statisticians, economists, researchers, analysts, policy and commercial managers - a dedicated data scientist would embody elements of all these roles;  certain industries such as pharmaceuticals, financial services, professional services and retail are increasingly dependent on these skills sets and a shortage of them would reduce the UK's international competitive advantage. Data scientists will also be conversant with the vocabulary of public sector information and open data and have the skills to create and manipulate large datasets and linked data. Based on ONS figures for 2011, around 1.5 million workers in the UK, representing around 5 per cent of the active workforce, are employed in job categories that are likely to involve elements of the role of the data scientist, but which individually may not be termed data scientists. The average annual median wage of these workers was over £36,000 in 2011 which is higher to the national annual median wage of £26,000. Economic theory suggests that a skills shortage will manifest itself in the form of large wage differentials between 'data scientists' and other comparable professionals. A recent report found an observable pay premium for 'big data' staff in 2012, with salaries around 20 per cent higher than those for IT staff as a whole.171 This may persist due to lags between training and entering or reentering the workplace, but economic theory suggests it will eventually dissipate in the long-run as supply increases to meet demand and is able to exploit the full value of public sector information. Evidence suggests the market is beginning to address skills shortages172 through:  sector specific leading practices, lowering complexity and the subsequent talent learning curve (including setting legal precedents for legal liability and compliance); and  universities are having new certifications for big data disciplines. However these initiatives will take time to work through the system with the interim consequence being that some value of public sector information may remain locked up. The general scarcity and increasing competition for these skilled workers from the private sector makes it harder to construct the infrastructure for world class public sector information. A shortage of data scientists also hinders efforts to scale-up public sector information data analytics. Within the public sector, concerns have been highlighted over a lack of skills and familiarity to work effectively with data. These concerns should not be overstated as public sector officials have a long history of using public sector information to inform policymaking without having dedicated data scientists. What the concerns appear to be directed at are cultural biases against using public sector information from outside home PSIHs, as well as having the necessary skills to combine and manipulate Big Data and Linked Data173. Comments from stakeholder conversations and the government official's informal consultation reinforce this concern - the following being representative:  "There is currently a lack of awareness and skills in blending and combining multiple datasets. This will need to be addressed if we are to fully exploit the power and potential of integrating disparate sources over the web."  "Data users do not fully appreciate the power and potential of open data. There may also be cultural resistance to change:, for instance, through not trusting or being able to exploit new, untried and untested third-party datasets in analysis and policy advice."174 Where public sector employees do not have a numerate or scientific higher education background, or are not accustomed to working with large datasets, they could benefit from increased training and support in this area. However, there are understandable concerns over resources at a time when departmental budgets are under considerable pressure. The danger, therefore, is the training in this area is viewed as a 'nice to have' which is not currently a budgetary priority and is therefore neglected. Were this to happen, much of the effort to open up public sector information and facilitate sharing across the public sector would be poorly spent, as public sector employees would lack the skills to exploit the available data - the PSIHs would only be able to operate on the supply of the market, lacking the skills to be innovative public sector information consumers. There are a number of routes around these budgetary concerns. One example is the use of massively open online courses (MOOCs) to enhance skills sets and increase expose to data manipulation techniques. These courses are free of charge to the user and include offerings from a number of prestigious higher education institutions. For a limited time commitment over a period of weeks, generally between three and six hours, students receive online material from academics, as well as access to a range of study material, online forums, and in some cases certification following course completion and assessment. Using estimates of public service wage levels and assuming an eight week long course of six hours of study a week, the opportunity cost value of taking a MOOC during office hours is in the order of £500 per participant, although the benefits from improved skills are likely to be much higher. In practical terms, measures could be taken via internal communications to raise awareness of the benefits of taking these courses. In addition it would be helpful if completion and accreditation of relevant courses was viewed favourably in performance assessments, which would act as an incentive. A commonly used approach to in transformation programmes is to identify 'champions' across all grades who can be encouraged to take the courses and then act as advocates among their colleagues; once a critical mass of understanding and enthusiasm is attained, this becomes self-reinforcing and employees should start taking the courses as part of their continuing training and development. A selected list of relevant MOOCs, available at the time of writing, is included below for guidance.175 | Web link | Course name | MOOC | |--------------------------------|-------------------------------|---------------| | provider | | | | Higher | | | | Education | | | | Institution | | | | Estimated | | | | time | | | | commitment | | | | Passion driven | | | | statistics | | | | Coursera | Wesleyan | | | University | | | | www.coursera.org/#course/pdst | | | | atistics | | | | 3-4 hours per | | | | week (6 | | | | weeks) | | | | Web intelligence and | | | | big data | | | | www.coursera.org/#course/bigd | | | | ata | | | | Coursera | IIITC | 2-3 hours per | | week (10 | | | | weeks) | | | | Introduction to data | | | | science | | | | Coursera | University of | | | Washington | | | | 10 weeks | www.coursera.org/#course/data | | | sci | | | | Statistics: making | | | | sense of data | | | | Coursera | University of | | | Toronto | | | | www.coursera.org/#course/intro | | | | stats | | | | 6-8 hours per | | | | week (8 | | | | weeks) | | | | Data analysis | | | | Coursera | John Hopkins | | | University | | | | www.coursera.org/#course/data | | | | analysis | | | | 3-5 hours per | | | | week (8 | | | | weeks) | | | Availability of the above courses may alter over time as the majority of the courses listed are to commence in Spring employees. We have selected the courses based on a combination of our personal experience and our assessment of the range of data analysis needs that may be useful for a public sector employee, but we are unable to offer any comment or assurance as to the quality of the course content or delivery, or the continuing availability of any of these courses. | Course name | MOOC | |--------------------|---------------| | provider | | | Higher | | | Education | | | Institution | | | Coursera | University of | | Washington | | | Computational | | | methods for data | | | analysis | | | Computing for data | | | analysis | | | Coursera | John Hopkins | | University | | Note: no analysis has been done as to the quality of the above courses' content, which could vary significantly. Traditional training will of course continue to play an important role, as well as interactive and workshop sessions, such as mash-up days, especially those involving external developers. These are useful for sharing knowledge and expertise and creating an environment which is conducive to experimentation and innovative thinking. In addition, it may be that public sector organisations will wish to increase their recruitment of those with a scientific or numerate higher education background, so as to expand the pool of relevant talent upon which they are able to draw. This will vary according to the organisation in question and the appropriate skills mix for the performance of their public task; for this reason we do not make an across the board recommendation regarding recruitment. However, it is likely to be helpful for public sector organisations to consider the alignment of their current and future skills based with the increasing availability and use of information from across the public sector. There will also be a role for Cabinet Office and other public sector organisations to build on notable achievements176 in public sector information provision to foster a more conducive culture within the public sector to using public sector information innovatively. The benefits accruing from improved use of information within the public sector are likely to outweigh these. Adapting the McKinsey analysis used by Policy Exchange177, improvements in efficiency of between 1 and 5 per cent can lead to annual savings of between £1 and £8 billion nationally and around £70 million in local government (on a smaller savings ratio). Insights:  While there may be gaps in the supply of 'data scientists', economic theory suggests that in the medium- to long-term, the number of data scientists will increase, filling the supply gap and reducing the current wage premium.  However, in the short-term, this may mean public sector information is left underexploited and value remains locked. The general scarcity and increasing competition for these skilled workers can make it harder to construct the infrastructure for world class public sector information and scale up efforts to exploit its value.  There are some low-cost solutions that can be explored to quickly improve the skills base to be able to effectively manipulate and extract value from public sector information. Web link Estimated time commitment 10 weeks www.coursera.org/#course/com pmethods www.coursera.org/#course/com pdata 3-5 hours per week (8 weeks) Format and reliability The release of data in an unfinished form raises concerns for the public sector too because of concerns that the public may be provided with data that is inaccurate and potentially misleading, which can have negative consequences. With respect to the format of public sector information, its importance may vary between customers. For casual consumers, it is clearly of the utmost importance, and they may most value format. In contrast, professional users may be more concerned with consistency of service, commitment to on-going supply of data and data and can accommodate changes to format. Equally, intermediaries may positively value low quality data as they can provide a service to improve the quality and format of public sector information for wider consumption. Evidence as to how significant a barrier this currently forms to the use and re-use of public sector information is mixed. In general, there seems to be steady improvement in all the areas of format, although there remains work to be done - especially with regard to ensuring consistency in format and upgrading the star rating of datasets. Progress is also being made with data being updated more consistently. Examples of this include data released by the Met Office, and transport data released directly by Transport for London as well as through data.gov.uk. Land Registry's release of PPI data is an example of good practice. The data was released in CSV (3 star format) then upgraded to linked data (4 star standard). The quality of the data was also added the organisation's list of Key Performance Indicators and anyone publishing the data is asked to include a link to a dedicated Land Registry team for reporting any inaccuracies in the data. With respect to format, it is well established that data which is released should, wherever possible, be in machine-readable formats. Format is therefore linked to usability. For a commercial service to be based on an data source, there must be confidence that the data will be maintained and kept up to date. The ODI notes that "the sustainability of data publication is all important for those who build services on top of that data. So long as it is machine-readable (2-star) and openly licensed…the frequency, consistency and accuracy of the publication of a dataset is more important than the format in which it is published."178 The reasons for this are easy to understand: if a business offers a service to customers, it cannot afford for that service to be unpredictably cut off or to offer out of date information. This is especially true of time-sensitive (volatile) informatio such as travel updates and weather forecasts. As highlighted in an earlier chapter, the working assumption of this report is that around 50 per cent of datasets are three stars or above (based on a review of data.gov.uk datasets and other sources including the data released by local government). The question is then whether this current level of usability acts as barrier to use and re-use of public sector information. Conceptually, datasets that fail to meet the required standard may be constraining the ability to generate value from public sector information datasets in a number of ways:  requiring users and re-users to have specialist propriety software to view public sector information datasets. Examples include the early release of the COINS database, which due to its size and nature was difficult for users to manipulate;  preventing users and re-users from exploiting the benefits of semantically linked datasets; and  restricting access to certain public sector datasets and limiting their uses / re-uses. Five star data offers significant advantages to users in terms of combining datasets together, which is one of the areas where this report has identified large potential benefits to be generated. However, moving towards a five star standard could involve significant cost to PSIHs. Following discussions on the merits of having all data meeting this standard with members of the start-up community and other stakeholders, it appears that while it is considered desirable, the consensus seems to be that as long as data is machine-readable the lack of a five star rating is not currently a significant barrier for users and re-users. There is concern that pushing too hard for all data to be upgraded to five star status could dissuade information holders from releasing data at all, given the cost. In general, users have expressed a preference for data to be released earlier with a lower star rating, and then upgraded when possible. In addition, consistency of format across comparable datasets is important, as this affects how easily they can be compared and combined. This is a particular issue where there are many organisations with their own outputs, such as local authorities and the NHS. Of course, as noted earlier, a higher star rating cannot be viewed as a simple proxy for higher data quality. A dataset may be in a machine readable format and available as linked data, but still contain inaccurate or incomplete data. In general, stakeholders have reported that the quality (including reliability of delivery [see below] and accuracy) of the data is of a higher priority that upgrading it beyond two or three stars, since the quality affects the fundamental usefulness of the data. The Open Standards Principles179, the Standards Hub180, the Open Standards Board and the public sector will be crowdsourcing, researching and implementing data standards for Government IT systems. The user challenges it will focus on are likely to cover standards relating to formats and meta-data that should help to provide data on reliability. Some of these open data standards may be made compulsory for central government use. However, it should be noted that a minority of stakeholders have complained that datasets released by different PSIHs are not always easy to combine and work across, because of variations either in the content or the format. This is a particular issue with data produced by local authorities, with each local authority often adopting their own standards and procedures. This report recognises that there are on-going efforts, such as e-PIMS, to tackle this issue and secure a greater degree of standardisation across PSIHs. Further, there appears to be scope for improvement is greater certainty and clarity over the publication schedule of public sector information datasets and what users can expect from PSIHS. In particular, certainty for businesses making investment decisions to use public sector (and other) information datasets could be improved through:  having a clear articulation of each dataset's publication schedule;  having a cover sheet setting out the limitations of the data, explaining outliers and providing links to previous analyses (greater use of metadata181);  having a clear indication of when any given dataset may be discontinued; and  the level of PSIH support that will be provided (perhaps at a charge). The levels of support and explanations of the dataset could vary by dataset type. Clearly there will be a cost involved in this for PSIHs (one-off and on-going), but the benefits to businesses from increased certainty could be significant. Insights:  Improvements continue to be made on the quality, format and consistency of public sector information.  There is scope for improvement, especially around the greater provision of metadata. ## Chapter Summary  This chapter has summarised the main barriers to the release, use and re-use of public sector information. These include o Legislative barriers: while current legislation, guidance and regulations are not hindering the public sector information market themselves, there is often a perception (wrongly or rightly) that some legislation, guidance and regulations prevent datasets from being released and shared thereby reducing the availability of datasets. The Open Government Licence is widely seen as an effective means of improving the availability of public sector information; o Economic barriers: there are significant data gaps around exactly what public sector information exists, making it difficult to reach decisions around its optimal provision. The issue of charging and funding models for public sector information is complex, with the lack of data making it hard, at present, to accurately conduct cost-benefit exercises on the extent that charged-for data might be delivered for free in future; and o Access barriers: improvements continue to be made to reduce fragmentation and improve the consistency of public sector information; however there remains scope for improvements in the accessibility of public sector information datasets to the general public. Equally, in some parts of the private and public sector, there is a skills shortage preventing the effective extraction of value from public sector information. ## 7. Conclusion This report has considered, for the first time, in its entirety, the public sector information market in the UK. It has provided details on the supply and demand sides of the market, the legislative and regulatory framework, the current value of the market and identified a number of barriers that are preventing the UK from maximising the full value of public sector information. This report forms the evidence base for the Shakespeare Review, which is making recommendations to Government. This concluding chapter sets out some closing thoughts on the subject of public sector information in the UK. Closing thoughts  Through a review of the literature and real-life examples of its use and re-use, it is clear that public sector information is generating significant value for the UK currently - in terms of financial, economic value and employment benefits, but also wider social benefits.  The increasing availability and better quality of public sector information can lead to even more value being generated in the UK and also overseas through network effects.  By being a global leader in the release of public sector information, the UK government is helping create an environment that is conducive for innovation and the development of new skills that could give UK businesses a competitive edge overseas182.  This report has highlighted that while the availability and quality of public sector information has improved in recent years, which has helped the market evolve and grow, there remain certain barriers that may hinder or constrain the continued growth of the market. The policy insights raised suggest that, in some cases, there may be a role for Government to step in and address market failures.  In addressing market failures, Government will need to balance the interests of different stakeholders, but equally it should not necessarily be constrained by the current fiscal environment in order to consider a much longer time-horizon of benefits and costs.  However, it should not be forgotten that public sector information is only one component in the wider data landscape - the increased availability of more and better private sector data (open or otherwise) will also have significant benefits.  Indeed, a key barrier identified has been the lack of information on how businesses use public sector information. Fostering a culture of greater openness and collaboration around data and its use will benefit all parties. For example, one way of collaborating and fostering more openness in future, providing it can be carried out in a not-too-onerous manner, might be providing data free to third parties on the pre-condition that the information flow becomes a two-way street for Government and policymakers, e.g. "you can have our data, but we'd like to know how it is being used and re-used to give us insight, benefit us and in turn UK society". ## Appendix 1: Glossary These glossary definitions have been taken from a variety of sources including the Open Data White Paper183 (June 2012), the Advisory Panel on Public Sector Information (APPSI) Glossary website184 and the OFT Commercial use of Public Information report185 (the 'CUPI' report, December 2006). As noted in that document, given the relatively nascent nature of the market and rapidly changing landscape, these definitions will have an element of. At the time of writing (January 2013), Cabinet Office is consulting to gain a collective view on definitions to be used in forthcoming Transparency and Open Data publications. This is to be done via a 'wiki' site hosted by the APPSI186. For reference the source for each glossary term is listed. Where there is no term this refers to cases where the term has been defined specifically for this research. For reference the source for each glossary term is listed. Where there is no term this refers to cases where the term has been defined specifically for this research. Aggregated data A form of anonymisation of unit records involving combinations such that individual records are not disclosed. Source: APPSI Glossary Anonymised data Data that has been adapted so that individual businesses, individuals and other organisations cannot be identified from it. Source: adapted from APPSI Glossary Application programming interface A specification intended to be used as an interface by software components to communicate with each other. An API may include specifications for routines, data structures, object classes and variables. Source: adapted from APPSI Glossary Attribution licence A licence that requires that the original source of the licensed material is cited. Source: Open Data Handbook Asset list A register of data and information items held by a PSIH which are of interest or value to the PSIH itself, and potentially to others. Source: OFT CUPI Authoritative Able to be trusted as saying something. Some information can be accurate but not authoritative, but it will be both if it comes from a source with authority to provide it. Source: APPSI Glossary Big Data Gartner187 describes Big Data as data defined as high volume, velocity and variety information assets that demand cost-effective, innovative forms of information processing for enhanced insight and decision making. Source: Gartner By-product data Data that is generated through the performance of regular or oneoff activities, where the generation of the data was not the primary objective of the activity or part of its Public Task. Also referred to as 'exhaust data'. Class licence A licence that sets out standard terms and obligations, enabling the re-use of a particular class or category of material. Source: OFT CUPI Click-use The online licensing system for Crown and Parliamentary copyright information developed by the Office of Public Sector information in 2001. This has subsequently been superseded by the Open Government Licence and Open Parliament Licence, but remains historically significant. Source: UK Government Licensing Framework Commercial use / re-use Use or re-use that is intended for or directed towards commercial advantage or private monetary compensation. For clarity, commercial advantage applies either to reselling the data through products in any form or to internal use or re-use to improve business effectiveness. Source: The National Archives Information Management Glossary with APPSI Glossary addition Consumer surplus The value or benefit consumers of a product or service enjoy over and above the price they paid for it. It is the difference between the price consumers pay and the price they are willing to pay. Copyright Part of the family of intellectual property rights including trademarks, designs and patents. Copyright applies automatically when a work is created in a material form. Copyright applies to literary works, such as website articles/annual reports; artistic works maps, drawings, paintings and photographs; films; sound recordings; broadcasts; dramatic and musical works and typographical arrangements. The first owner of copyright will normally be the artist/author or organisation that created the work (except for Crown copyright). Copyright subsists in a work regardless of the level of artistic or literary merit. The standard term of copyright is the life of the author plus 70 years. Source: The National Archives Information Management Glossary Core reference data Authoritative or definitive data necessary to use other information produced by the public sector as a service in itself due to its high importance and value. Source: Open Data White Paper Crown body An organisation which acts on behalf of the Crown, meaning the sovereign acting in a public or official capacity. This includes most central government departments including government Trading Funds. In many cases the Crown status or otherwise is specified within the context of legislation. Source: OFT CUPI Crown copyright Crown copyright covers material created by civil servants, ministers and government departments and agencies. It is legally defined under section 163 of the Copyright, Designs and Patents Act 1988 as works made by officers or servants of the Crown in the course of their duties. Copyright made by Her Majesty or by officers can also come into Crown ownership by means of an assignment or transfer of the copyright from the legal owner of the copyright to the Crown. Source: APPSI Glossary Crown copyright waiver Categories of material on which the Crown asserts its copyright but waives it and which is not subject to formal licensing or payment. Source: The Future Management of Crown Copyright White Paper Customer insight Data Data or information recording users' accounts of their experience, with an assessment of public service providers. Source: Open Data White Paper Data (singular or plural) Qualitative or quantitative statements or numbers that are assumed to be factual and not the product of analysis or interpretation. Data can be structured or unstructured. The term structured data refers to data that is identifiable because it is organised into a recognisable structure. The most common form of structured data (structured data records (SDR)) refers to a database where specific information is stored based on a methodology of columns and rows. In contrast, unstructured data has no identifiable structure. The terms data, information and knowledge are frequently used for overlapping concepts. The main difference is in the level of abstraction being considered. Data is a broad term, embracing others, but is often the lowest level of abstraction, information is the next level and, finally, knowledge is the highest level. Source: adapted from APPSI Glossary and Open Data White Paper Data controller A person who (either alone or jointly with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. Data discovery benefits Benefits (economic or otherwise) that arise from the analysis of data and information itself. Data enabler An intermediary that facilitates public sector information or open data initiatives without actually publishing or consuming data themselves, usually through software, platform, data centre infrastructure etc. Service types include platform-as-a-service, infrastructure-as-a-service, and Software-as-a-service. Data exploitation benefits Benefits (economic or otherwise) that arise from using data and information as inputs into products and services. Data holder The public sector body holding public sector information. Also referred to as Public Sector Information Holders. Data infomediary An intermediary that aggregates, scrapes or collects publicly available data or data stores that enhance the raw data with visualization, completeness, accuracy, analysis, or accessibility. Data mash-up Combining different and distinct datasets to create new datasets and generate new insights. Data owner The data owner (organisation or individual) is responsible for understanding what information is brought into a system, assigning meanings to data collections and constructing and modifying data models. Data processor With respect to personal data, this refers to any person (other than an employee of the data controller) who processes the data on behalf of the data controller. Data protection The Data Protection Act 1998 defines the ways in which data and information on living persons may be legally used and handled. The Act sets out the fundamental principles with which personal data much satisfy, including: (a) be processed fairly and lawfully; (b) be obtained only for lawful purposes and not processed in any manner incompatible with these purposes; (c) be adequate, relevant and not excessive; (d) be accurate and current; (e) not be retained for longer than necessary; (f) be processed in accordance with the rights and freedoms of data subjects; (g) be protected against unauthorised or unlawful processing and accidental loss, destruction or damage; and (h) not be transferred to a country or territory outside the European Economic Area unless that country or territory protects the rights and freedoms of the data subjects. Source: adapted from Data Protection Act Data scientist An analytical role that is built on three core skills: data management, data analysis and business and policy insight. While the formal training of data scientists is typically in statistics, mathematics or computer science, they will also have strong communication skills and business/policy acumen. They have been described as "part analyst, part artist" by IBM. Data sharing The transfer of data between different organisations to achieve an improvement in efficiency and effectiveness. This document assumes that data sharing will continue to operate in line with current domestic legislation and the UK's international obligations. Source: Open Data White Paper Data subject Under the Data Protection Act 1998, this refers to an individual who is the subject of personal data. Dataset As defined in the Protection of Freedoms Act 2012: " 'dataset' means information comprising a collection of information held in electronic form where all or most of the information in the collection: (a) has been obtained or recorded for the purpose of providing a public authority with information in connection with the provision of a service by the authority or the carrying out of any other function of the authority, (b) is factual information which - (i) is not the product of analysis or interpretation other than calculation, and (ii) is not an official statistic (within the meaning given by section 6(1) of the Statistics and Registration Service Act 2007), and (c) remains presented in a way that (except for the purpose of forming part of the collection) has not been organised, adapted or otherwise materially altered since it was obtained or recorded." It is important to note that when one talks about accessing public sector information or open data, a single page on a data portal such as data.gov.uk does not necessarily link to one item of data or dataset - there can be multiple datasets. Source: adapted from Data Protection Act and APPSI Glossary De-anonymisation The process of determining the identity of an individual to whom a pseudonymised dataset relates. Source: Open Data White Paper Derived data A data element adapted from other data elements using a mathematical, logical or other type of transformation. Source: OECD Glossary of Statistical Terms Disclosive Data is potentially disclosive if, despite, the removal of obvious identifiers, characteristics of this dataset in isolation or in conjunction with other datasets in the public domain might lead to identification of the individual to whom a record belongs. Source: Open Data White Paper Executive agencies A diverse group of organisations delivering a variety of services to internal and external customers. They are part of the Crown and do not usually have their own legal identity, but operate under powers that are delegated from Ministers and Departments. Source: OFT CUPI Exhaust data Data that is generated as a 'by product' of an organisation's activities, i.e. where data has been generated as a result of other activities but not as the primary purpose of these activities. Full cost pricing A pricing policy in which charges are set to recover the full resource costs of the activity. Source: OFT CUPI Free at point of use Where there is no charge or fee to the end-user for the use or reuse of information. Source: A Consultation on Data Policy for a Public Data Corporation - glossary Freemium A business model by which a product or service is provided free of charge, but a premium is charged for advanced features or functionality. Source: APPSI Glossary Geospatial data Data or information that identifies the geographic location of features and boundaries on Earth, such as natural or constructed features, oceans and more. Source: adapted from APPSI Glossary Identifier A particular element or reference in a dataset that allows individuals' or businesses' identity to be known. Information Output of such process that summarises, interprets or otherwise represents data to convey meaning. Source: Open Data White Paper Information asset register Registers specifically set up to capture and organise metadata about the vast quantities of information held by government departments and agencies. A comprehensive IAR includes databases, old sets of files, recent electronic files, collections of statistics, research and so forth. Source: OFT CUPI Open Data Handbook and Open Data Manual Information fair trader scheme A scheme to set and assess standards for public sector bodies in allowing the re-use of their information. Any public sector body may apply to become IFTS accredited. However, all Crown bodies that hold a delegation of authority from the Controller of HMSO must become IFTS accredited. IFTS measures members' performance against the six principles of maximisation, simplicity, transparency, fairness, challenge and innovation. It considers both the commercial re-use of public sector information and noncommercial citizen access to information. Source: The National Archives Information Management Glossary Intellectual property A set of property rights that grant the right to protect the materials created by them. Intellectual property comprises among other things copyright, designs, patents, database rights, certain confidential information and trademarks. Source: Open Data White Paper and OFT CUPI Licence Permission by the copyright holder to reproduce or re-use material protected by copyright. Source: OFT CUPI Linked data The term used to describe the recommended best practice for exposing, sharing and connecting items of data on the semantic web using unique resource identifiers (URIs) and resource description framework (RDF). Source: APPSI Glossary Market failure An instance where a market is not efficiently allocating goods and services. Market failures can include information asymmetries, non-competitive markets, principal-agent issues and externalities / public goods. Marginal cost pricing The cost of supplying another unit. Long run marginal cost is the full extra cost (both fixed and variable) of providing a further unit of output. Short run marginal cost measures how variable costs change when output alters. In practice, marginal costs are difficult to observe, and average variable costs are used as a substitute for the concept of marginal costs. Source: OFT CUPI Metadata Data that describes or defines other data. Anything that users need to know to make proper and correct use of the real data, in terms of reading, processing, interpreting, analysing and presenting the information. Thus metadata includes file descriptions, codebooks, processing details, sample designs, fieldwork reports, conceptual motivations, etc., in other words, anything that might influence the way in which the information is used. Source: OCED Glossary of Statistical Terms and www.sasc.co.uk/Guides/metadata.htm Mosaic effect The process of combining anonymised data with auxiliary data in order to reconstruct identifiers linking data to the individual it relates to. Also referred to as the 'jigsaw effect' or 'crossreferencing'. Source: adapted from Open Data White Paper Non-commercial government licence A legal solution to enable the provision and use of public sector information under a common set of terms and conditions at no charge for non-commercial use only. The main requirement for reusers is to attribute the information provider and source. Source: UK Government Licensing Framework Non-departmental public body A body which has a role in the process of national government, but is not a government departments or part of one, and therefore operate to an extent at arm's length from Ministers. Source: OFT CUPI Open access At its most narrow, this refers to the provision of free access to peer-reviewed academic publications and other information data to the general public. Source: modified from Open Data White Paper Open data Data that meets the following criteria: (a) accessible (ideally via the internet) at no more than the cost of reproduction, without limitations based on user identity or intent; (b) in a digital, machine readable format for interoperation with other data; and (c) free of restriction on use or redistribution in its licensing conditions. Open data can be provided by the public and private sector as well as individuals. Source: adapted from Source: APPSI Glossary and Open Data White Paper Open government data Public sector information that has been made available to the public as Open Data. Source: Open Data White Paper Open Government Licence The Open Government Licence (version 1.0), which forms part of the UK Government Licensing Framework, offers a legal solution to enable the provision and use of public sector information under a common set of terms and conditions. It enables any public sector information holder to make their information available for use and re-use under its terms. Source: modified from UK Government Licensing Framework Personal data As defined by the Data Protection Act 1998, personal data means "data which relate to a living individual who can be identified - (a) from those data; or (b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller, (c) and/or includes an expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual. Source: adapted from Open Data White Paper Price elasticity of demand A measure of the responsiveness of the quantity demanded of a product or service following a change in its price. Producer surplus The value accruing to producers of goods and services when their output is purchased by consumes. In traditional supply and demand analyses, producer surplus is calculated as the difference between the lowest amount the producer would be willing to sell the good/service for and the price the producer actually sold it for. In many cases this is equal to profit. Processing Under the Data Protection Act, processing in relation to information or data, means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including - (a) organisation, adaptation or alteration of the information or data; (b) retrieval, consultation or use of the information or data; (c) disclosure of the information or data by transmission, dissemination or otherwise making available; or (d) alignment, combination, blocking, erasure or destruction of the information or data. Pseudonymised data Data relating to a specific individual where the identifiers have been replaced by artificial identifiers to prevent identification of the individual. Source: Open Data White Paper Public domain Works that are publicly available and in which the intellectual property rights have expired or been waived. Source: APPSI Glossary Public good A good or service provided by Government for public consumption to combat an actual or perceived market failure. Whilst these are generally free-at-the-point of use, for a good to be public it has to be non-excludable and non-rivalrous. The former meaning that no party can be excluded from the benefits conveyed, whilst the latter means that one person's consumption does not prevent other persons from benefitting. PSI may be considered a public good in certain instances. Public sector body The State, regional or local authorities, bodies governed by public law and associations formed by one or several such authorities or one of several such bodies governed by public law. (Directive 2003/98/EC on the reuse of public sector information, Art 2). Source: OFT CUPI Public sector information Public Sector Information covers the wide range of information that public sector bodies collect, produce, reproduce and disseminate in many areas of activity while accomplishing their public tasks. Source: adapted from BIS and APPSI Glossary Public sector information holder A public sector body that collects and/or holds information, data or content (as defined). Source: OFT CUPI Public task Public task information is that which a public sector body must produce, collect or provide to fulfil its core role and functions, whether these duties are statutory in nature or are established through custom and practice. The term 'public task' features in the Re-use of Public Sector Information Regulations 2005 (SI 2005 No. 1515) and the INSPIRE Regulations 2009 (SI 2009 No. 3157). The National Archives provides guidance that assists public sector bodies to define and publish a statement of their respective public tasks. Source: The National Archives Raw data In the context of public sector information, raw data is data collected which has not been subjected to processing or any other manipulation beyond that necessary for its first use. Raw data, i.e. unprocessed data, is a relative term; data processing commonly occurs by stages, and the 'processed data' from one stage may be considered the 'raw data' of the next. Source: A Consultation on Data Policy for a Public Data Corporation - glossary Refined data This is where unrefined information has been enhanced, manipulated and/or added to other inputs to create a retail product for businesses or consumers. The process of refining information can be undertaken by a PSIH, or viably in a commercial market by the private sector. Re-use Use of information other than for the purpose it was originally produced. This use could be for commercial or non-commercial purposes. (Re-use of Public Sector Information Regulations 2005 (SI 2005/1515), Reg.4(2)). Source: adapted from EU PSI Regulations Resource description framework A W3C standard that is the foundation of several technologies for modelling distributed knowledge and is meant to be used as the basis of the Semantic Web. Source: APPSI Glossary Semantic web A web of data that can be processed directly and indirectly by machines. Source: APPSI Glossary Sensitive personal data This refers to personal data consisting of information as to a person's: (a) racial or ethnic origins; (b) political opinions; (c) religious beliefs or other beliefs of a similar nature; (d) whether they are a member of a trade union (within the meaning of the Trade Union and Labour Relations (Consolidation) Act 1992); (e) physical or mental health condition; (f) sexual life; (g) the commission or alleged commission by them or any offence; or (h) any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceeding or the sentence of any court in such proceedings. Standard Industrial Classification First introduced in the UK in 1948, this is a framework for classifying business establishments and other statistical units by the type of economic activity in which they are engaged. There are a number of levels of the classification, with subsequent levels becoming more detailed. A common classification framework of occupational information for the UK on the basis of skill level and skill content. Standard Occupational Classification Star Rating In UK Linked Data, a system of ranking data sources that indicates ease of machine readability. APPSI subjective score for quality of a definition (qv). Source: APPSI Glossary Trading Fund A government department, executive agency, or part of department, established as a Trading Fund by a Trading Fund Order made under the Government Trading Funds Act 1973. A Trading Fund has authority to use its receipts to meet its outgoings. Source: adapted from HM Treasury Glossary (Managing Public Money) Unrefined data This is data which cannot be substituted directly from other sources. It relates to a PSIH's monopoly activities, where competition is very unlikely. Once a PSIH does something with the data which could be performed viably in a commercial market by the private sector it becomes refined information. Value-added data Raw data to which value has been added to enhance and facilitate its use and effectiveness for the user. Value can be added in a number of different ways including further manipulation, compilation and summarisation into a more convenient form for the end-user; editing and/or further analysis and interpretation; and commentary beyond that required for policy formulation by the relevant government department with policy responsibility. Source: adapted from A Consultation on Data Policy for a Public Data Corporation - glossary Verbosity The level of detail of a given dataset. Velocity How often data or information in a given dataset changes. ## Appendix 2: Acronyms Used In This Report API Application Programming Interface APPSI The Advisory Panel on Public Sector Information BIS Department for Business, Innovation & Skills CUPI Commercial Use of Public Information DfE Department for Education DfT Department for Transport DSB Data Strategy Board EC European Commission EU European Union HMG Her Majesty's Government HMT Her Majesty's Treasury IAR Information Asset Register IFTS Information Fair Trader Scheme MoJ Ministry of Justice NDPB Non-Departmental Public Bodies NHS National Health Service ODI Open Data Institute ODUG Open Data User Group OFT Office of Fair Trading OGL Open Government Licence OS Ordnance Survey PSI Public Sector Information PSIH Public Sector Information Holder SIC Standard Industrial Classification SOC Standard Occupational Classification SSNIP Small but Significant and Non-transitory Increase in Price TfL Transport for London ## Appendix 3: Literature Review # This Appendix Surveys The Literature That Has Analysed The Role Of Public Sector Information In Economic Growth, Both In The Uk And Internationally. Key Themes Are The Direct Economic Value Of Public Sector Information, The Less Tangible Impacts On Economy And Society, And Debates Over The Most Effective Pricing Models For Public Sector Information. Overview "A new market for public service information will thrive if data is freely available in a standardised format for use and re-use...At present the market for information on public services is highly underdeveloped. Open Data across government and public services would allow a market in comparative analytics, information presentation and service improvement to flourish. This new market will attract talented entrepreneurs and skilled employees, creating high value-added services for citizens, communities, third sector organisations and public service providers, developing auxiliary jobs and driving demand for skills."188 In so saying, the Government's *Making Open Data Real* consultation laid out the argument for the economic impact of increasingly the availability of public sector information for use and re-use. The argument is that for public and private sectors alike, more widespread availability of public sector information will drive efficiencies, boost innovation, lower barriers to entry and enable new insights into old problems. In so doing it holds the potential to reduce public expenditure, promote economic growth and make life more convenient for citizens. The objective of this Appendix is to review the arguments and evidence around this view. There is a considerable body of literature supporting the view that opening public sector information to public use will boost innovation and economic growth. In this context, opening up public sector information is often synonymous with making it available free of charge. However, while the logic behind this argument is reasonably clear, the evidence to prove the point is often incomplete. As discussed in the main report, this paucity of evidence arises for two principal reasons. The first is the complexity of measuring the impact of information, which permeates the economy in so many ways. The direct revenue generated though sale of public sector information may be measurable, where the data is available, but assessing the impact further downstream in the value chain is much more complex and inevitably rests on a range of more or less defensible assumptions. Where public sector information is released free of charge there is no direct revenue to measure. The question becomes still more complex when factoring in possible substitutes for public sector information. The second reason is the difficulty of quantifying innovation. Part of the rationale for making public sector information publically available is that this will in effect 'crowd source' innovations, as thousands or even millions of users, it is hoped, experiment with new ways of using the data. This process is expected to generate innovative new products and services that will benefit individual users and society as a whole. While this has demonstrably taken place, and continues to occur, as ever greater volumes of public sector information are made available to users, the process of innovation is by its very nature unpredictable and, more often than not, there is a significant time lag between data release and crystallisation of benefits. It is therefore difficult to quantify the benefit, in terms of enhanced innovation, that is likely to arise from making any unit of public sector information available to the public. The purpose of this literature review is to provide an overview of the key literature on public sector information, including:  attempts to size the economic contribution of public sector information;  assessments of the less tangible social, environmental and political value of public sector information;  studies on the optimal pricing of public sector information; and  a series of case studies to illustrate these points. ## The Economic Impact That a link exists between public sector information and economic growth is widely accepted. A recent review of the literature on public sector information ('Review of recent studies on PSI reuse and related market developments') concluded that "knowledge is a source of competitive advantage in the "information economy", and for this reason alone it is economically important that public information is widely diffused," listing benefits from public sector information including:  development of new products built directly on public sector information;  development of complementary products such as new software and services;  reduction of transaction costs in accessing and using information;  efficiency gains in the public sector itself; and  the crossing of different public and private information to provide new goods and services189. The economic importance of public sector information is seen to have increased radically with the spread of new communication technologies, most notably the internet, and the development of a 'knowledge economy' in which value is generated through innovation in information and services. These changes have had the effect of allowing the rapid diffusion of information to a large number of end users, who not only benefit (individually and as communities) from the educational, political and social advantages conferred by this information, but are also empowered to use it to create innovative value-added goods and services. Furthermore, barriers to entry are reduced for startups when they enjoy free or cheap access to a wealth of data as well as the tools to easily reach their target market. Although innovation cannot be manufactured by government, the conditions for it to emerge and flourish can be created: this means that "enlarging and systematically inviting serendipity can be argued to be an aim of government information policy making access to public sector information an important cornerstone in a comprehensive digitally driven innovation policy190." Conceptually, one can see how public sector information can drive economic growth and wider prosperity. The simplified framework, shown below, illustrates the long-term drivers of economic growth. Measurable outputs (such as GVA, employment and productivity) as well as less easily measured outcomes (such as happiness and sustainability) are determined by a number of inputs to the economy. In the long-term and considering the supply side of the economy only, the economic output of the UK is a function of only two things: the number of people engaged in gainful employment and the amount each person in employment is capable of producing. Source: Deloitte analysis based on HMT and BIS analysis. See www.hm-treasury.gov.uk/d/ACF1FBD.pdf for more details. Drawing on the HMT's research into the Five Drivers of Productivity191, the amount each worker produces is determined by skill levels; the extent of innovation in products and processes; the degree of investment in capital; entrepreneurial activity; and, lastly, levels of competition. Underpinning employment and productivity are seven necessary enablers. These are related to the infrastructure required to facilitate long-term economic growth. A deficit in these enablers will equate to a supply-side constraint on economic growth in the long-run. This could be caused either by limiting the growth in working population (through insufficient housing capacity or supporting utilities) or by acting as a drag on productivity growth (through below-par ICT connectivity or a sclerotic transport system). Expanding and enhancing these enablers can therefore positively impact employment and productivity, which in turn generate economic growth and greater prosperity. As Figure A3.1 shows, improvements in the availability and quality of public sector information can impact across all infrastructure enablers and productivity drivers - the following sections explain how. ## The Economic Contribution Of Public Sector Information Despite this consensus around the importance of public sector information in a modern 'knowledge economy', however, there is little agreement when it comes to quantifying the economic benefit contribution of public sector information. Attempts have varied widely both in the methodologies employed and in the conclusions reached, with the value added by public sector information assessed at figures ranging from millions to hundreds of billions of pounds. This is unsurprising given the difficulties mentioned in the introduction to this chapter: the ubiquitous presence of public sector information, making its impact difficult to disentangle from other factors; and the challenges in predicting and quantifying innovation. Several recent studies have attempted to tackle this challenge. They have examined three levels of economic value generated by public sector information:  direct value: i.e. revenue generated by government from selling access to public sector information;  commercial value: i.e. the revenue generated by private companies through the use of public sector information; and  downstream value: i.e. the value to users of products and the wider economic, social and environment benefits generated. Assessing direct value is the most straightforward. A 2006 study by the Office of Fair Trading (OFT) **('The Commercial Use of Public Information'**) estimated the direct revenues from around 400 UK PSI holders at £400m. The report extended this analysis by assessing the combined consumer surplus (the summed difference between the highest prices consumers would pay and the actual price) and the producer surplus (the difference between the price of the product and the cost of supplying it). This led to an assessment of economic value of £590m. The OFT estimated the total potential value of public sector information in the UK to be roughly double this figure, at £1.11 billion if three kinds of market distortions to be removed: unduly high pricing, distortion of downstream competition, and failure to exploit public sector information. The OFT's approach avoids the danger, common with the top-down approach, of over-estimating value. However, it is likely that the results of its analysis significantly understate the value, both actual and potential, of public sector information. This is partially because some public sector information providers were outside the scope of the report, so that significant volumes of public sector information are excluded from the analysis. More fundamentally, the report did not consider the wider uses and re-uses of public sector information and the potential for enhancing the growth of existing companies and triggering new innovations and entrants into the market. By way of contrast, Vickery's 2011 literature review on reusing public sector information valued public sector information across the entire EU at EUR 140 billion.192 He derived this estimate by extrapolating figures for the total economic impact of geospatial information in Australia and New Zealand. Based on this calculation, the Government in its Autumn Statement 2011 estimated the current total economic value of public sector information in the UK at £16 billion.193 The significant difference between Vickery's estimate and the OFT's figures demonstrates the impact of adopting a top-down approach to assessing value. Other studies that have attempted to assess the commercial value of public sector information have on occasion reached even higher figures. The most relevant UK studies that have attempted to put a value on public sector information include:  a 1999 Oxera study (**'The Economic Contribution of Ordnance Survey GB'**) which concluded that £79-£136 billion of Gross Value Added was dependent to some extent on products and services provided by Ordnance Survey. This study employed the value-added method, calculating the total value of all the products and services produced in the UK in which Ordnance Survey's products and services serve as an input.  a 2007 study by PA Consulting ('The Public Weather Service's Contribution to the UK Economy') which concluded that the public valued the services of the Met Office at £353.2 million, with a minimum additional contribution to the UK economy of £260.5 million based on three case studies.  a 2003 study on the British Geological Survey (**'The Economic Benefits of the BGS'**) which estimated its contribution at between £34bn and £61bn, again using the value-added method. An additional study of interest was carried out in 2010 by ConsultingWhere and ACIL Tasman for the Local Government Association ('The Value of Geospatial Information to Local Public Service Delivery in England and Wales'). The authors calculated that the benefit to the local government sector from the use of geospatial data was £232 million over five years, with a GDP increase of £323 million for England and Wales (equivalent to 0.02 per cent of GDP for England and Wales) and increased taxation of £44 million. The report also calculated that geospatial data had led to an increase in labour productivity of 0.233 per cent among local public sector providers, equivalent to an additional 1,500 full time staff in England and Wales.194 Since this relates only to one type of data in one sector, it is to be supposed that the overall effect of public sector information would be calculated to be much higher were the same methodology applied to all public sector information across the whole economy. In 2000 a study was undertaken by Pira International ('Commercial Exploitation of Europe's Public Sector Information') which estimated the national income attributable to economic activities based on the exploitation of public sector information at EUR 68 billion, or 1.4 per cent of EU GDP. Costs, or the government investment in collecting public sector information, were valued at EUR 9.5 billion, equating to a seven-fold return on investment. The UK's share of this value was estimated to be EUR 11.2 billion (with an upper estimate of EUR 21.8 billion and a lower estimate of EUR 4 billon). These estimates were based not only on the direct revenues from the supply of raw public sector information, but also on value generated by products developed using public sector information as an input. While these Pira values are more moderate, and therefore perhaps more defensible than some of the figures reached by the studies mentioned above, the considerable range of the estimates produced by the report indicates that this is not a precise science.195 The wide variation in estimated value results from differing methodologies, assumptions and economic models. The OFT report was critical of top-down assessments, arguing that this approach is prone to overstating the value of public sector information since it fails to account for potential substitutes. For example, it is clearly not true that without the information provided by Ordnance Survey there would be no mapping information available to users (a point Oxera acknowledge in their own report). Commercial customers have at their disposal a range of potential suppliers of this information - although it may be true that Ordnance Survey provides information that is more comprehensive and of a higher quality than would be possible for a private sector provider, given the investment required. It is therefore not reasonable to claim that the all the value added to the economy by Ordnance Survey information would not be created were Ordnance Survey not to exist. It is also clearly problematic drawing parallels between countries, given variations in the supply and demand for public sector information as well as associated costs, licensing conditions, and other differences. Even drawing parallels between different types of data is fraught with difficulties, as it is clear that some types of data have generated more value than others. Nonetheless, as noted, the OFT's approach is also not without its drawbacks. ## The Costs Of Providing Public Sector Information As the NAO concludes in a recent report on the transparency agenda ('Implementing Transparency'), "when estimates of economic value vary this widely, it is difficult to assess the scale of effort or targeting needed to best build on that value."196 This uncertainty matters because the cost of making public sector information available to the public must be offset against the forecast value created in order to create a robust business case. Unfortunately, just as there is very little certainty regarding the economic value of public sector information, there is also very little data available on the costs of public sector information provision, at least beyond the major trading funds and ONS. The NAO estimates additional staff costs of providing disclosure for pre-existing data range from £53,000 to £500,000 annually by department.197 However, this does not take into account other costs, including those incurred by IT and other support functions, which are difficult to disaggregate. Examples of costs associated with public sector information made publically available to date also vary. For example, the police crime map incurred set up costs of £300,000 and annual running costs of over £150,000, largely because the department repackaged the information to improve accessibility.198 On the other hand, other cases such as the release of public weather service data have incurred much lower costs. This suggests that, as might be expected, improving the quality of data and providing an integrated platform for users is likely to require much greater investment of resources than simply releasing the data in its existing form. However, in value for money terms, this may under some circumstances prove more cost effective than releasing data which the majority of non-technical users are unable to exploit. ## Providing Value For Money From Public Sector Information The investment into providing public sector information may be judged to provide value for money if improved quality means the data enjoys improved usage and therefore provides greater economic and social benefits. It is notable that releases of data have attracted varying levels of interest. For example, the police crime map website received around 47 million visits between February and December 2011. In contrast, the NAO reports that over 80 per cent of visitors to data.gov.uk leave without clicking on any links, and departments report limited interest in departmental spend data releases.199 This disparity may be a consequence of the police crime map presenting data in a format that appears much more user-friendly than data.gov.uk for the average user, commensurate with the significant investment made. Similarly, government spending data has been released in a relatively unprocessed format and may therefore be challenging for the majority of users to exploit. In support of this view, the NAO records that "the Department for Education has reported an 84 per cent increase in the use of its comparative data on schools, compared with the same period last year, since it was consolidated in one location and data were made more accessible200." It therefore seems apparent that while making public sector information available is an important first step, it is unlikely to enjoy widespread use by the public unless it is presented in a user-friendly format, consolidated in one easy to find location: data availability is a necessary, but not always sufficient condition for use and value creation, It may be that the better prepared the data, the more likely it is to produce significant economic and social value as a wider range users are able to deploy it to improve accountability and develop innovative products. This requires greater investment of resources by public sector bodies responsible for publishing the data, but it is a reasonable hypothesis that, at least for some types of data, the investment will be rewarded by strong economic and social returns. As the NAO argues: "evidence on benefits should be considered alongside information on costs and risks to secure best value from the large stock of public data, match the range and presentation of data purposefully to fulfil specific objectives, ensure that risks are identified and mitigated and secure value for money201." However, in order to make the business case for investment, and ensure that this investment is appropriately targeted towards the most valuable PSI, it would be helpful to have a more comprehensive understanding of both the benefits and the costs. ## Summary There appears to be little dispute that public sector information generally delivers economic and social value in excess of the costs required to provide access to it. However, accurately assessing its economic contribution, both actual and potential, requires an improved understanding of the costs and benefits associated with public sector information, including:  a better understanding of drivers of additional costs to release different types of public sector information;  distinguishing between producer surplus and consumer surplus benefits from releasing more public sector information;  a clearer means of determining demand, so as to prioritise the release of public sector information; and  a robust method of evaluating the emerging effects of public sector information as it is released, so that efforts can potentially be focussed on high-value data. It is important to note that all actors could deliver more in terms of transparency of information on the topic. Public sector bodies have, in some instances, not responded to survey questions posed as part of the study, and naturally, private sector organisations are unwilling to discuss and disclose sensitive financial information and the precise means by which PSI does or could improve performance. Figure A3.3 below summarises the key studies that have attempted to value the contribution of public sector information. It should be noted that although summarised here for convenience, these reports were not all attempting to measure the same thing and so the figures are not directly comparable. | Study | Date | Author | |-----------------|--------------------|------------| | PSI sources | | | | evaluated | | | | Upper value | | | | estimated | | | | Lower value | | | | estimated | | | | OFT CUPI | | | | 2006 | OFT | Various | | £1.1bn | | | | (potential) | | | | £590m | | | | - | | | | Vickery | | | | 2011 | Graham Vickery | Various | | c. £16bn (UK); | | | | EUR 140bn | | | | (EU) | | | | MEPSIR | | | | 2006 | HELM Group | Various | | EUR 48bn (EU + | | | | Norway) | | | | EUR 10bn (EU | | | | + Norway) | | | | PIRA | | | | 2000 | Pira International | Various | | 1999 | Oxera | | | Ordnance | | | | Survey | | | | £136bn* | £79bn* | | | The Economic | | | | Contribution of | | | | Ordnance | | | | Survey GB | | | | 2007 | PA Consulting | Met Office | | The Public | | | | Weather | | | | Service's | | | | Contribution to | | | | the UK Economy | | | | £61bn* | £34bn* | | | 2003 | | | | Roger Tym & | | | | Partners | | | | The Economic | | | | Benefits of the | | | | BGS | | | | British | | | | Geological | | | | Survey | | | Source: Deloitte analysis * These figures are based on an analysis of the Gross Value Added dependent to some extent on PSI, and therefore differ from attempts to assess the value of PSI The broader impact Many of the studies discussed above attempt to quantify the actual or potential economic contribution of public sector information. In reality this is difficult to separate from other impacts, such as the social, environmental or political benefits conferred by access to public sector information. For example, if an individual's or a community's health outcomes are improved through use of public sector information , this will have a downstream economic benefit in terms of increased individual productive potential (through avoidance of loss of working hours from illness) and medical costs avoided. Due to the complexity of calculating these less tangible benefits, however, they are often omitted from quantitative studies of economic contribution. However, it is also true that these benefits have an intrinsic value - good health is desirable irrespective of its positive economic impacts, and would remain so even if quantitative economic impacts could not be demonstrated. For this reason it is important to take such benefits into account when weighing up the costs and benefits of public sector information. Where it is not possible to calculate a financial value, case studies and other measures can be used. One of the most important studies to address this area is the 2007 independent review by Ed Mayo and Tom Steinberg ('**The Power of Information**'), which cited a range of benefits that have resulted from sharing information202: | Information use | Benefits | |----------------------------------------------------------------------------------------|------------------------------------------------------------------------------| | Online communities | In medical studies of breast cancer and HIV patients, participants in online | | communities understand their condition better and show a greater ability to cope. In | | | the case of HIV, there are also lower treatment costs. | | | This creates both a welfare benefit and a cost saving benefit. | | | 'Wired' local | | | communities | | | Studies of 'wired' local communities demonstrate that there are more neighbours who | | | know the names of other people on their street. | | | This is likely to create a safer, more cohesive and supportive community. | | | Restaurant food safety | | | information | | | Sharing restaurants' food safety information in Los Angeles led to a drop in food- | | | borne illness of 13.3 per cent, compared to a 3.2 per cent increase in the wider state | | | in the same time frame. | | | The proportion of restaurants receiving 'good' scores more than doubled, with sales | | | rising by 5.7 per cent. | | | This creates a welfare benefit, reduced medical costs and increases consumer | | | spending. | | | Medical prescription | | | information | | | By providing clear information when dispensing medication, pharmacists can improve | | | patient adherence/persistence with medication advice by 16–33 per cent. | | Source: Mayo and Steinberg, Deloitte analysis Not all of these examples concern public sector information but they do indicate the range of benefits which can be delivered by widespread availability of information. They therefore hint at the potential benefits of making public sector information available to a wider range of users, given the volume and range of information held by public sector bodies. It is important to ensure that these less tangible and less easily quantifiable benefits are not excluded from any analysis of the costs and benefits of public sector information. In a more recent study, Pollock (2011) estimated that the indirect benefits from greater availability of public sector information, such as reductions to transaction costs to users and re-users and other efficiency gains could imply gains of around £600m per year for the UK. Maximising the impact of public sector information ## Pricing Models An important aspect of the debate over the economic contribution and value of public sector information is the question of the correct level of pricing for data. Currently, while much public sector information is made available at no charge for use and re-use, some of the most valuable data - including, for example, some mapping data collected by Ordnance Survey, and data held by Companies House - is only available to paying users. There is some debate over whether these charging models are justified, given the costs involved in collecting the data, or whether this introduces counterproductive inefficiencies and market distortions. In one of the key papers on this topic ('Models of Public Sector Information Provision via Trading Funds'), Newbery et al. identified four possible charging policies:  Profit-maximization: setting a price that maximises profit given the demand for the data;  Average cost (cost recovery): setting a price equal to average long-run costs (including fixed costs incurred by data production);  Marginal cost: setting a price equal to the actual cost of the process of supplying data to a user; and  Zero cost: releasing the data free of charge.203 The paper concluded that many Trading Funds' products - primarily 'refined' data products - could not be analysed effectively due to data limitations, and that these should therefore by default be left with their pricing policies unchanged. However, Newbery t al argued that most 'unrefined' data should be made available at marginal cost, which owing to the low cost of providing digital data would effectively be zero. This would bring trading fund data into line with raw data charging policies in other areas of government. The basis for this argument is that the benefits to society of making this data freely available would outweigh the costs, although some trading funds, notably Ordnance Survey, would need additional taxpayer support. The costs and benefits estimated by the paper are summarised below: Trading Fund Gross benefit from releasing raw PSI Cost to government Net benefit Companies House £2.6m £681k £1.9m The Met Office £1.2m £260k £1.03m Ordnance Survey £168m £12m £156m UK Hydrographic Office £1.08m £744k £338k The Land Registry £2.3m £1.1m £1.2m The DVLA £4.3m £582k £3.7m Source: Newbery et al, 'Models of Public Sector Information Provision via Trading Funds' (2008) Clearly, this study raises important questions regarding the fairest way of financing trading fund data collection activities: should taxpayers in effect subsidise free access to data for users, or should users of data directly bear the costs associated with data collection and dissemination? Newbery et al's figures indicate that free access to trading fund data, subsidised by the taxpayer, would in most cases lead to a net economic benefit. There is no guarantee, however, that this benefit will be equally spread across society. It is possible, for example, that most of the benefit might accrue to foreign-based companies which can use the data to boost revenues but not contribute to UK tax revenues. If it could be demonstrated that making the data freely available would be 'revenue neutral' - i.e. the associated tax income to government would at least equal the outlay in support of trading funds - there would be a much more economically and politically powerful case for taking this step. In a 2009 paper ('Enhancing access to government information: economic theory as it applies to Statistics Canada') Kirsti Nilsen argued that in the case of public sector information the benefits are non-rivalrous and non-excludable, and so the principle that the beneficiary pays is a fallacy. "The justification for cost recovery is often based on the so-called benefit principle: Those who benefit from a good should pay for it. However, it is very difficult to determine the benefits of information. Information flows. It moves away from the initial buyer. So, what is the benefit? Who benefits? How do you apply the benefit principle? The assignment of benefit, like the assignment of costs, is an arbitrary exercise."204 Nilsen argued that should Statistics Canada move from a cost recovery pricing model to a zero cost model, the following results could be expected:  sales and licensing revenues for the public sector body would **decrease**;  usage and reuse of the public sector information would **increase**;  increased public sector information usage would provide positive **externalities**: information dissemination, more widespread usage of the data, and economic growth;  tax revenues would therefore **increase**; and  the public sector body's transaction and opportunity costs would **decrease**. This should offset the decline in sales and licensing revenues, in addition to the **increase** in tax revenues. In considering these arguments, however, it is important to reflect on the diversity of the public sector information landscape and the dangers of applying a 'one size fits all' prescription. For example, the Trading Funds operate within a regulatory framework which limits their ability to cross-subsidise information provision from income generated in other areas of activity. From conversations with stakeholders it is clear that the picture is more complex than an initial examination might suggest, as are the implications of radical changes to the current model. Examples where this approach might be less appropriate are considered elsewhere in this report. ## The Impact Of Zero Or Marginal Cost Pricing On Innovation There is already a trend towards making at least some data freely available. This is clear across the full spectrum of PSIHs, from government departments through to trading funds such as Ordnance Survey, which now offers significant numbers of datasets through its Open Data initiative. A 2011 European Commission study ('**Pricing of Public Sector Information'**) found "a clear trend towards lowering charges and/or facilitating re-use"205 among public sector bodies. The study found that where PSBs moved to marginal or zero cost charging, the number of re-users increased by between 1,000 per cent and 10,000 per cent, indicating the potentially significant impact of removing cost barriers to re-use. Removing cost barriers was also found to attract new types of users, particularly SMEs, which may be a particularly innovative class of user and thus add additional value to the economy. The study further found that costs did not increase significantly, or even decreased, once prices were lowered. This is partly due to the fact that zero cost pricing greatly reduces transaction costs, as public sector information providers no longer need to devote resources to complex payment, licensing, supply and enforcement systems. In addition, enhanced volumes of users compensate for reduced prices. The study also found that the availability of low cost data with clear re-use rules spurred the development of innovative public sector information-based apps, opening up a potentially significant new market. It cites examples such as MetroParis and London Tube apps which have jointly generated EUR 400,000 in revenues. However, when public sector information providers create value-added services in the form of their own apps this has been noted to have a detrimental effect on private sector app innovation, suggesting that they should arguably confine themselves to providing data for users and avoid competing directly through the development of value-added products. Some stakeholders, however, have made the point that private sector providers did not develop apps and other value-added products taking advantage of the available data, prompting them to release their own to fill a gap in the market. A significant body of work therefore supports the argument that the gross benefits from not charging, or charging at marginal cost, outweigh the added cost that may be borne by government. This has contributed to growing momentum towards reducing the cost of public sector information at the point of use. Despite the strength of Nilsen's arguments from the standpoint of economic theory, however, there may be political challenges in supporting data collection which is then freely provided to for-profit businesses, even if the wider benefits to society can be demonstrated to outweigh the direct cost to taxpayers. The challenge for advocates of open data, therefore, is to demonstrate that changes to pricing policy can be revenue neutral or lead to an increase in public sector revenues, through a growing tax base. There is evidence indicating that changes to pricing policy can be revenue neutral. A 2011 Finnish study (**'Does marginal cost pricing of public sector information spur firm growth?'**) surveyed the performance of 14,000 firms in the architecture and engineering sector (Standard Industrial Classification 7420) and pricing policies for public sector geographical information across 15 countries. It concluded that in those countries where geographical information was either free or priced at marginal costs, firms grew 15 per cent faster than in countries where information was priced at cost recovery. The study also found that an impact on company growth rates could be detected within a year of switching to a marginal cost pricing scheme, although the impact became more pronounced after two years.206 Importantly, the most significant impact on growth rates was experienced by SMEs rather than large firms. The author attributes this to high public sector information prices creating a barrier to entry for SMEs, which is removed by a switch to marginal cost pricing. He argues that for this reason, marginal cost pricing of public sector information is likely to create more competitive markets and thus lead to lower prices and a wider range of products, benefitting consumers. If this result could be demonstrated to be replicated across other types of public sector information, it would present a persuasive argument - from the point of view of encouraging dynamic markets and economic growth - for moving to a marginal cost pricing mechanism for public sector information. Nonetheless, such a change would need to be evaluated on a case by case basis, given the various types of information involved and the various markets in which public sector bodies which currently charge for information operate. The table below summarises the key studies that have examined the pricing of public sector information. | Study | Date | Author | |---------------------------------|---------------|-------------------| | 2008 | Newbery et al | UK Trading Funds | | Significant net benefit from | | | | moving to marginal or zero cost | | | | pricing structure for raw data | | | | Models of Public | | | | Sector Information | | | | Provision via | | | | Trading Funds | | | | 2009 | Kirsti Nilsen | Statistics Canada | | Zero cost pricing produces | | | | positive externalities across | | | | society while being revenue | | | | neutral due to increased usage | | | | and reduced transaction costs | | | | Enhancing access | | | | to government | | | | information: | | | | economic theory | | | | as it applies to | | | | Statistics Canada | | | | Pricing of Public | | | | Sector Information | | | | 2011 | | | | Charging models for | | | | PSI | | | | Deloitte and | | | | others in | | | | association with | | | | Moving to marginal or zero cost | | | | pricing increases users by | | | | 1000-10,000 per cent, attracts | | | | | | | | Study | Date | |---------------------|------------| | the European | | | Commission | | | 2011 | Heli Koski | | Performance of | | | 14,000 firms across | | | 15 countries | | | Does marginal | | | cost pricing of | | | public sector | | | information spur | | | firm growth? | | ## Case Studies The economic and social value potentially generated by public sector information is well illustrated by the case of 'wicked' **problems**. These are challenges featuring complex interdependencies, which spill across jurisdictions and therefore have the potential to confound traditional, vertically organised structures such as government departments, whose expertise and mandate covers only one area of policy. Examples of wicked problems include climate change, youth unemployment and health issues such as obesity. By making public sector information available for re-use data from diverse sources can be linked and 'mashed', potentially producing new insights and generating unexpected solutions. The value that can be generated by public sector information is also well illustrated through case studies on the impact on the public sector, business and wider society. These have been drawn from the UK and other countries that have been experimenting with different models for providing public sector information. While to some extent this is an anecdotal approach - it is not possible to forecast the number of new businesses or their value - it offers useful insights into the value that can be generated through public sector information. ## Public Sector Efficiencies | Case study | |-----------------------------------------------------------------------------------------| | Spotlightonspend is a managed service that is comprised of everything necessary to | | facilitate cost-effective publication of the spend and related information that is made | | available to the public. | | Spotlightonspend | | Spotlightonspend is designed to: | |  | | Cut costs by removing the need to add to the workload of current staff or increase | | headcount | |  | | Eliminate the complexity of becoming and staying compliant with policy | | Helping public | | sector bodies | | publish data in a | | cost-effective | | manner | |  | | Reduce the risk of inadvertent breach of data protection legislation | |  | | Enhance the information published to improve its accessibility, relevance and value | | for the public | | Barnet StreetPatrol | Barnet, one of the largest boroughs in London, deployed a GPS system called StreetPatrol to help street wardens locate, identify and photograph issues including abandoned vehicles, graffiti, antisocial behaviour and fly-tipping. This enables them to send information immediately back to head office, ensuring a rapid and efficient response. Previously this process could take between three and four days. Using StreetPatrol, wardens are able to spend up to 70 per cent of their time on patrol, compared to 30 per cent for those without the system. ## Delivering Efficiency Savings In Local Policing Adoption of this system has delivered around £180,000 in efficiency savings. Improved speed of response also brings cost savings: an abandoned vehicle costs approximately £50 to recover; a burning vehicle nearly £4,000. By responding quickly wardens are able to tackle problems before they develop. Source: Deloitte: Open Data - driving growth, ingenuity and innovation; and Cabinet Office material new types of users including SMEs, and does not result in significantly higher costs Marginal cost pricing of geographical data leads to an average 15 per cent increase in the growth rate of SMEs ## Business Innovation | Case study | |--------------------------| | Red Spotted Hanky | | Using rail industry data | | to offer customers low- | | price tickets | Launched in 2010, Red Spotted Hanky is an online ticket retailer which aims to offer customers and easier way to book without any administration or payment fees. Red Spotted Hanky relies on data from the rail industry to offer customers low-cost advance bookings. The business employs 13 people and is growing fast, with a loyalty scheme, a tie-up with Tesco and a 'price promise' for customers. Duedil Linking and aggregating information to improve business transparency Duedil is a business information provider based in London's Soho. Duedil gives free access to governance and financial information for every company in the UK and Ireland, and combines this with data from online sources, Application Programming Interfaces, social networks and more. Duedil was launched in April 2011 by entrepreneur Damian Kimmelman. By late 2011 it as valued at £20 million and had attracted considerable interest from investors. Its aim is to make business more transparent, by opening up company information to make the due diligence and research process simple and intuitive. By aggregating and linking all the available information, users can gain a comprehensive understanding of businesses and the people who run them. ## Parkopedia Using Local Authority Data To Give Drivers Live Parking Updates Parkopedia is an innovative open data company which fuses location and other data. A small UK-based business, it uses live data from local authorities to help drivers identify free car parking spaces. Parkopedia has grown to become the world's leading source of parking information covering more than 20 million spaces in 25 countries. Used by millions of drivers, Parkopedia's service include a pre-booking tool which allows drivers to book parking online, and real-time parking space availability information. Parkopedia also works with other organisations to integrate its data into journey planner mobile applications and satnavs. Source: Deloitte: Open Data - driving growth, ingenuity and innovation ## Case Study - The Value Of Psi In The Mobile App Market One area where public sector information has generated significant innovation, some of which has been successfully monetised, is in the mobile app market. Deloitte's POPSIS study (2011) estimated the value of the mobile app market at around $35 billion, of which 40% is contributed by apps that use public sector information. Based on a UK contribution of 13% of all apps, this suggests that the value of the PSI-based app market in the UK is some £1.13bn. Furthermore, this is a rapidly growing market, with use of smartphones and tablets in the UK increasing rapidly year on year. The figure of £1.13bn is likely to understate the true value of public sector information-based apps to the UK economy, as it does not take account of the benefit to users (such as time savings and increased ability to access important information). Country distribution of mobile apps in the sample Public sector information-based app share Based on 'Apps' market snapshot of POPSIS study. The study considers a sample of ~500 apps from Android, Istore, and Ovi apps Source: Deloitte, available http://ec.europa.eu/information_society/policy/psi/docs/pdfs/report/11_2012/apps_market.pdf ## Country Case Studies While international case studies are a helpful illustration of public sector information practices elsewhere, care must be taken when extrapolating the lessons. For example, the same proportion of benefits may not occur in the UK due to differences in economic structures, legislative frameworks and the culture and capabilities of consumers. Denmark's Open Data Innovation Strategy207 In 2009 the Danish government launched the Open Data Innovation Strategy (ODIS) to provide easier access to PSI for businesses and other users. Although this is a recent development that is likely to have much as yet unrealised potential, efficiency gains in both the public and private sectors are already emerging. Certain sectors have been particularly quick to spot the opportunities presented by the availability of public sector information.  Financial services: banks are working with the tax authorities to access payroll and pension data for clients of the banks. This has the estimated potential to save banks EUR 67 million per year in efficiency gains and reduced losses. Additional savings could be gained by accessing data on clients' employment conditions. The insurance industry is also interested in the potential for customer data to improve its risk assessments. In these cases, however, there remain issues to be resolved around customer consent for the sharing of these personal details.  The energy sector: data on building specifications, as well as demographic data on residents, could be used to target energy-saving measures. Potential savings are estimated at EUR 0.54-2.7 billion.  The pharmaceutical and healthcare sector: patient data could be used to select patients for clinical trials, improving the process of developing new drugs. Denmark is in some ways an unusual case owing to its relatively small size and a legacy of robust public sector data collection and digitisation, which has left it well placed to improve economic and social outcomes through the release of public sector information. It is also clearly at an early stage in this process, with significant issues in data security and confidentiality yet to be resolved. Nonetheless it provides a striking example of the potential benefits to be realised by making public sector information available to business users, both in terms on financial savings and wider benefits to society. Denmark: the value of address data208 In 2002, the official Danish address data was made available free of charge. This meant that any user could access the data without paying a fee to the Danish Enterprise and Construction Authority (DECA) charged with collecting and maintaining this data. Eight years later DECA commissioned a study to analyse the benefits of making the data free of charge. The study concluded that between 2005 and 2009 the total direct financial benefits of the data were EUR 62 million, with costs of around EUR 2 million. The study also estimated that in 2010 total benefits would be EUR 14 million, with costs of EUR 0.2 million. The benefits were split at around 30 per cent in the public sector and 70 per cent in the private sector. As with many other studies, only direct financial benefits were measured, as downstream economic and wider social benefits were considered too difficult to quantify. However, the authors suggested that these benefits were likely to be of considerable value. They cite the example that 46 per cent of Danish families own a GPS navigation system, incorporating the address datasets, which has doubtless generated significant benefits - for example in travel time saved. The study also highlighted barriers which have limited the benefits of the address data, caused by technical, traditional and legislative barriers which, for example, limit how quickly business addresses are registered and included in the database. This indicates the need for efficient data collection, processing and dissemination systems and the regulatory framework to support this. In conversations with stakeholders, the caveat has been raised that some of the benefits identified in this study may not be transferable to the UK. In particular, the Public Sector Mapping Agreement means that sharing of geospatial data between public sector bodies in England and Wales209 is already relatively advanced compared to many countries. Utilities companies also have access to this information. Furthermore, the UK has an unusually dense post code network, which means that these are suitable for accurate navigation via GPS navigation systems. These caveats highlight the risks inherent in assuming that benefits experienced in one country will be directly transferable to another. The study nonetheless highlights the important direct financial benefits that can result from making these key datasets freely available to users, and suggests that these direct financial benefits both in the public and private sector can considerably outweigh the cost to government. Spain: The Aporta Project In 2011 an analysis of the 'infomediary' business sector was carried out, defined as "the set of companies that create applications, products and/or added-value services for third parties, using public sector information."210 This was intended to be a comprehensive survey of all Spanish PSI activities. Headline findings were:  business turnover directly associated with infomediary activities is EUR 550-650 million, 35-40 per cent of the total company activity of EUR 1.6 billion;  activity by re-use field was as follows: o business/financial 37.6 per cent o geographic/cartographic 30.5 per cent o legal 17 per cent o transport 5.2 per cent o social data/statistics 1.9 per cent o meteorological 1.1 per cent o others 6.7per cent  the re-used information comes mostly from national agencies, but half of the companies also re-use international information;  re-use policies are valued, particularly to improve the quality and accuracy of information, improve understanding of the legal framework, and expand the amount and scope of information generated; and  areas identified for improvement include standardization of formats, standardization and improvement in the regulation of licences for re-use, and pricing of information. This survey indicates the scale of the opportunity for business stemming from the re-use of public sector information, with the financial services and geospatial sectors seeing particularly significant opportunities. However, it also highlights the need to improve quality and accessibility, through standardised formats and improved licensing arrangements. Australia: Office of Spatial Data Management and Geoscience Australia211 In 2001 the Australian Government launched the Commonwealth Policy on Spatial Data Access and Pricing, which provided free access to spatial data online, or charge no more than the cost of transfer for packaged data. This applied to all spatial data collected by government departments and agencies. Furthermore, in 2009 Geoscience Australia began licensing all data under the Creative Commons licence, allowing royalty-free use and re-use. A 2010 report by PwC (**'Economic Assessment of Spatial Data Pricing and Access'**) valued the net welfare gain at $4.7 million. Extrapolating this for all Australian Government spatial data, Houghton calculated net welfare benefits totally $70 million. Usage increased rapidly, with the total number of spatial datasets delivered by Australian government agencies increasing at 112 per cent per annum between 2001-02 and 2005-06, from around 75,000 to over 1.5 million. Even though the number of datasets rose, intensity of dataset use increased over the period, with the number of downloads per dataset rising 44 per cent per annum. This case reinforces the view that making data available at zero or marginal cost generates welfare benefits in excess of the revenue lost, with Houghton calculating a benefit/cost ratio of 13. ## New Zealand: Spatial Information In The Economy - Realising Productivity Gains212 An extremely comprehensive 2009 study assessed the value of spatial data to the New Zealand economy. It concluded that the use and re-use of spatial information added an estimated $1.2 billion to the New Zealand economy in 2008, equivalent to 0.6 per cent of GDP. In addition, it estimated the non-productivity benefits to be worth many times this figure, through, for example, planning 'smarter' cities and transport systems, aiding national security, or promoting social cohesion. However, the authors avoided calculating a financial assessment of these benefits because: there is too much uncertainty around likely events and probabilities and the underlying value approaches are controversial. The figures presented by the report should therefore be treated as a 'lower estimate' which in reality could be substantially exceeded. The report further estimated that barriers to the use and re-use of data cost $481 million of productivity-related benefits, which would have generated at least $100 million in government revenue. It recommended releasing the basic spatial information held by the government at marginal cost. A broader intervention to develop New Zealand's spatial data infrastructure would generate a predicted benefit-to-cost ratio of at least 5:1. In conducting the productivity gains analysis, the report treated historical growth rates of the New Zealand economy as the base case. The authors then estimated the historical productivity of each sector without the productivity benefits of spatial information; and the potential productivity if adoption barriers for spatial information were removed (i.e. the potential unrealised benefit). This provides an interesting insight into the industry sectors most likely to benefit from the use and reuse of geospatial PSI. Sector Quantifiable historical productivity without spatial information Estimated productivity without adoption barriers Crops 1.25 1.88 Bovine cattle, sheep and goats, horses 1.25 1.88 Other animals 1.25 1.88 Raw milk 1.25 1.88 Wool 1.25 1.88 Forestry 5.25 5.71 Fishing 3.44 3.44 Meat products 0.25 0.38 Dairy products 0.25 0.38 Other processed food 0.25 0.38 Coal 0 0 Oil 0 0 Gas 0.63 0.78 Electricity 0.63 0.78 Petroleum & coal products 0 0 Iron & steel 0 0 Other mining 0 0 Nonferrous metals 0 0 Non-metallic minerals 0 0 Chemicals, rubber, plastics 0 0 Wood and paper products; publishing and printing 0.25 0.38 Textiles and clothing 0.25 0.38 Other manufacturing 0.25 0.38 Water 0.63 0.78 Construction 0.75 1.13 Trade services 0.77 1.15 Transport 2.10 3.15 Communications services 0.82 0.82 Other business services 0.23 0.46 Recreational and other services 0.23 0.46 Government services 0.52 1.04 Dwellings 0 0 Source: ACIL Tasman calculations and estimates ## Appendix 4: Further Statistics Companies House Companies House is a statutory body largely funded by fees paid by customers to register a company. These fees provide the majority of revenue, with users of the data paying for dissemination costs only, which means the data is free of charge in some cases. Companies House serves as an 'information exchange' - unlike some of the trading funds, it does not provide value-add services to users, but rather exists to gather data in the form of company registrations and disseminate this to users. Figure A4.1 below contains some download statistics provided by Companies House on usage statistics across its various distribution channels. ## Figure A4.1: Companies House Usage Statistics Companies House Direct This is the Companies House online subscription service, for which users pay monthly. It offers free basic company information as well as company documents and reports for a charge. Usage statistics since 2010/11 are shown below. Companies House report that there were over 405 million free searches between January and December 2012, indicating high uptake of the free data available. The number of subscribers to this service rose from 20,967 in 2010/11 to 21,653 in 2012/13 (YTD). Webcheck This is the Companies House 'pay as you go' service which allows users to check company name availability, search free basic company information and purchase company documents and reports. The number of page hits grew from 380 million in 2010/11 to nearly 450 million in 2011/12, with strong growth posted again for the 2012/13 YTD. Mobile App Companies House have released a mobile app which gives free access to information including company address, status, company appointments and filing history. The number of downloads reported by Companies House (as of 10/12/12) is 12,362. 11,075 of these were for the iPhone version, and 1,287 for Android. The iPhone app was released in September 2012 while the Android version was released in November. URI company searches Companies House runs a Uniform Resource Identifier service (URI) for all companies on the register. This allows free searches which will return basic details for the company. Companies House report that since the introduction of this service in October 2011 it has seen over 111 million data requests. DVD ROM Companies House offer a product stored on a DVD ROM, for a fee, containing PDF images of company documents filed since 31 December 2002. There has been a decline in both one-off requests for the DVDs since 2010/11 reflecting the increased availability of information via the website. One-off requests fell from 931 to 898 between 2010/11 and 2011/12 and subscriptions fell from 664 to 637 over the same period. Source: Companies House Land Registry Land Registry's main purpose is to register ownership of land in England and Wales and to record dealings with land once it is registered. The relevant powers and responsibilities are set out in the Land Registration Act 2002. There are also statutory responsibilities under the Agricultural Credits Act 1928 and the Land Charges Act 1972. Under the Land Registration Act 2002, Land Registry has the power to provide 'consultancy and advisory services'. The income from these services is used to invest in Land Registry and helps to ensure that fees for normal registration services are kept to a minimum. ## Figure A4.2: Land Registry Usage Statistics Land Registry released their Transactional Data in January 2012 and their Price Paid information in March 2012 in open data format. The chart below shows the number of visits and downloads received between their release and the end of October 2012. A Land Registry survey of Price Paid Data users between March and November 2012 indicated that the data was being used to:  Help businesses, for example to provide housing market updates  Assist research, for example into local housing needs and affordable housing policy  Help people buy and sell houses  Help people monitor properties  Present the data in new ways and carry out new analysis Source: Land Registry The Met Office The Met Office uses its data to produce a range of value-added services, some of which are noncompeted services to governments, and others which it sells into competed markets, either to government or the private sector. Examples of the former include the services provided to defence and its climate modelling work. Examples of the latter include services provided to aviation clients and insurance companies. Most paid-for services are therefore value-added, as even wholesale data requires a high level of processing to enable re-use. Figure A4.3 contains statistics received from the Met Office on the number of requests and downloads received by its Data Point service. ## Data Point Portal For Accessing Met Office Reusable Data For Web And App Developers. The Number Of Registered Users Has Also Increased Significantly Between December 2011 And January 2013, From Around 100 To Over 2000 The Met Office has supplied Deloitte with the number of requests received by data feed in December 2012, which may be taken as a recent indication of the level of demand - around 2.4 million. The proportions of each request by data type are shown in the chart below. As is clear from these figures, the Met Office experiences very high and continual demand for across its data feeds, with site specific forecasts accounting for over three quarters of the demand, at over 1.9 million requests. The average daily download of data from the Met Office site, in terms of Mb downloaded, has increased rapidly over the last six months, as the chart below shows. The British Atmospheric Data Centre The British Atmospheric Data Centre (BADC) is NERC's dedicated data centre for the atmospheric sciences. As such it has a crucial role in providing long-term curation and access to datasets that support scientific research. Whilst its main role is to archive the outputs of NERC's own research activities it also accesses datasets from many other sources in response to the needs of the research community.  MOHC climate simulations contributing to the CMIP5 archive: 58Tb, multiple models and experiments ##  Midas Observations: 258Gb, All Years, All Observations The number of users and the number of files downloaded in 2012 is shown in the charts below. MyOcean The main objective of MyOcean is to deliver and operate a single European Ocean Monitoring and Forecasting system of the GMES Marine Service (OMF/GMS) to users for all marine applications. OSTIA SST is also made available through the GHRSST portal and has many more users than through my oceans as registration is not required. The charts below show the number of unique users and the number of requests in Jan/Feb 2013. Hadley Centre Climate Observation Datasets (HadObs) Researchers at the Met Office Hadley Centre produce and maintain a range of gridded datasets of meteorological variables for use in climate monitoring and climate modelling. This site provides access to these datasets for scientific research and personal usage only. Registered users are a mix of national and international. It should be noted that one person may be registered for more than one dataset. ## Other Sources Of Data Include:  Wholesale (ECOMET) Catalogue - The primary objectives of ECOMET are to preserve the free and unrestricted exchange of meteorological information between the NMS's for their operational functions within the framework of WMO regulations and to ensure the widest availability of basic meteorological data and products for commercial applications. There are currently 35 Customers purchasing our Wholesale data, the majority of whom are resident outside the UK.  WMO Resolution 40 - The meteorological and related data and products described as the minimum set of data and products which are "essential" to support WMO Programmes and which Members shall exchange without charge and with no conditions on use.  On-line from the Met Office website - various downloadable data related to content available to view. Includes historical station data, regional climate data and marine observations.  Weather Observations Website (WOW) - A portal allowing users to upload weather observations, this also includes the Met Office official monitoring sites. Data can be downloaded based on the content viewed.  Library requests - About 300 requests a year for historical observation datasets of various sizes provided under personal or research use only terms of use. It is important to note that the outputs of the Met Office reach many millions of people through channels that are not represented in these figures. For example, the forecasts of the Public Weather Service broadcast by the BBC on TV and radio are estimated to reach an audience of between 10 and 20 million per week. The audience through other channels are estimated at around four million. An additional 5-10 million are estimated to access forecasts through digital channels such as the web and mobile apps. These, it should be noted, are figures for 'value-added' services rather than raw data. The Met Office also provides a large range of other services, many on a commercial basis, meaning that it is complex to estimate the number of users across the full range of data and value-added services. Source: Met Office Ordnance Survey In the case of Ordnance Survey, the collection of data is the organisation's *raison d'etre* and this public sector information is therefore not a by-product of other activities. Most revenue, therefore, is generated from charges levied on users which cover not only dissemination costs but also the cost of collection. Where value-added services are provided, these are priced to cover the cost of development. Ordnance Survey products and services are priced at market rates to avoid undercutting competitors. Access is provided on the same terms for all parties. The following data was received from Ordnance Survey for this report: ## The Approximate Split Between Open O/S Data And O/S Data Available Under Licence And The Number Of Downloads Of O/S Data By Different Channels  For OS OpenData, in 2012 we processed 34,500 orders. Nearly 95 per cent of orders were for download, the exceptions tending to be for national datasets of OS VectorMap District and OS Streetview where the volume of data is very high. The top three products by items ordered were OS VectorMap District, OS Streetview and Code-Point Open. The very different nature of the products means that a comparison by data volume and number of downloads does not provide clarity. For example OS VectorMap District may be ordered as a national set (one order) or as individual 100km x 100km tiles, whereas Code-Point Open is available only as a national set. ## Number Of O/S License Holders For Last Three Years  We do not keep a periodic record, but at present we have approximately 250 licensed partners who take the data and on-sell it in value-add products or services. The trend has been for the number of licensed partners to grow and for the number of direct customers to shrink, as Ordnance Survey focuses on the key users in specific areas such as Energy and Infrastructure, while encouraging further development of value-added products by a growing range of partners ## Api Usage Statistics  Below is a graph showing the volume of data on a monthly basis utilised through OS OpenSpace since January 2011. Source: Ordnance Survey ## Appendix 5: Empirical Methodology # This Appendix Provides Further Details Of The Quantification Methodology Used For The Current Value Of Public Sector Information In The Uk. The Appendix Covers How The Report Has Defined The Term 'Value' And The Different Modelling Assumptions Used. ## Final Estimates And Ranges Can Be Found In The Main Report. General Approach And Limitations As has been discussed in the main report, attempts to accurately quantify the value of current or future public sector information in the UK are restricted by the lack of data. To recap, all things being equal, a standard valuation exercise for public sector information would draw upon the following pieces of data to reach estimates:  an estimate of the total number of public sector information datasets available and not available;  the relative value of different datasets to one another;  the price paid for different datasets;  how different datasets are used;  the different costs incurred in supplying different datasets;  the number of jobs in the UK attributable to public sector information or involved in its supply or use/re-use;  the willingness to pay by consumers for different datasets;  the financial value of the different types of benefits (economic and societal) enjoyed by consumers using and re-using public sector information; and  price elasticities of demand for different datasets and awareness of the shape of consumers' demand curves. Further, in order to reach a robust estimate of public sector information value, data or knowledge of linkages would be required to establish the direction of causality between use and re-use of public sector information and their impacts in order to properly account for additionality effects. While elements of the above data requirements are available to differing degrees, the majority of the above is not available for 2011-12 (the financial year this report focusses on), or for that matter for earlier years. In the time available for this research project this report has sought to acquire some of this data from government officials, PSIHs, consumers and other stakeholders. However, in the absence of any extensive primary research exercise (including, but not limited to, consumer surveys, data audits and experiments) there remain significant data gaps. Accordingly, the modelling exercise is based on a pragmatic approach, making conservative assumptions where necessary and relying on previously collected data, e.g. on price elasticities. Similarly, the methodology builds on previous methodologies rather than creating a new one from first principles. The authors of the report have discussed, and received feedback on, the methodology with the DSB and a number of other government officials213. The approach has sought to give an indication of the depth and breadth of the value of public sector information in the UK rather than a definitive statement of its value today or tomorrow. Given the public sector information is rapidly evolving, we believe it is better to give a broad indication of the sources and quantum of value (complete with the appropriate caveats) rather than a figure that has spurious accuracy. It is acknowledged this approach is not ideal and could be improved with the addition of new primary research to update assumptions and fill data gaps. Definition of value It is important to clearly define what is understand by the term value. From the literature, it is possible to disaggregate value into four distinct components:  the direct value of public sector information to producers and suppliers (the PSIHs): these are the benefits accruing to producers and suppliers of public sector information through the sale of public sector information or related value-added services;  the indirect value of public sector information arising from its production and supply: the benefits accruing up the supply chain to those organisations interacting with and supplying PSIHs (but not directly using or re-using public sector information), and the benefits accruing to those organisations where employees of PSIHs and supply chain organisations spend their wages;  the direct use value of public sector information to consumers of public sector information: the benefits accruing to businesses, civil society, individuals and the public sector from directly using and re-using public sector information for a variety of purposes; and  the wider societal value arising from the use and re-use of public sector information: the benefits to society of public sector information being exploited, which are not readily captured elsewhere. The first three types of value can be grouped as **economic value** or narrow economic value and can be measured using standard economic methodologies to derive a monetary estimate for value and the associated employment figure. The final type of value is harder to measure as it captures wider benefits to society arising from the use of public sector information - these are typically not measured in monetary terms. The literature discusses a number of ways in which public sector information can have broader impacts:  increasing democratic participation: giving citizens and businesses access to public sector information allows them to perform their own analyses of salient issues, make more informed choices about public service providers and interact with policymakers to challenge their assumptions and improve the policymaking process;  promoting greater accountability: for example through the scrutiny of costs of public service provision and benchmarking comparable services;  greater social cohesion: for example, by providing more information on the provision and distribution of services, public sector information can be used to dispel myths on who receives certain public services;  generating environmental benefits: such as reducing congestion and pollution through the release of better traffic and transport data which helps drivers to better plan journeys; and  identifying previously unknown links between different policy areas: through data-mash ups it may be possible to develop system-wide solutions that holistically seek to address the root of policy challenges. Thus, for the purposes of this evidence base, the value of public sector information is defined as the benefits accruing to the suppliers, users and re-users of the information and data in terms of profits generated, jobs created and supported and the wider societal benefits. It is important to clarify that value defined in this way is not the same as the **market value** of public sector information. Market value typically refers to the volume of sales multiplied by the price of the product. In this way it equates to revenues or thus includes labour costs, capital costs, profits and the intermediate costs of production which are not included in our definition (see below for more details). Conversely, market value will not capture indirect and induced effects and wider societal benefits. Methodologies considered As highlighted in the literature review appendix, there is no consistent methodology used in previous research to quantify the value of public sector information which has led to a large variance between estimates (ranging from £590 million to £16 billion - a factor of almost 30). The underlying reasons for these different figures appear to be:  whether the quantification approach has been 'top down' or 'bottom-up';  how the term 'value' has been defined;  the underlying data used; and  the category of public sector information being valued. Below are summarised some of the different methodologies used in the literature. ## Figure A5.1: Value Of Public Sector Information Methodologies | Author | |----------------------------------------------------| |  | | Linear demand curves | |  | | PSIHs split into three | | categories and then sub- | | divided in public sector | | information type | |  | | Calibrated elasticity estimates | |  | | Revenue from PSIHs | | OFT / DotEcon (2006) | | Bottom-up or welfare approach. Value = net surplus | | = consumer surplus + producer surplus | |  | | Value-added public sector | | information is priced | | competitively | |  | | Number of OPSI licences | |  | | For 'free' public sector | | information, value is estimated | | relative to usage of value | | added public sector | | information | |  | | Assume a lower bound of 20% | | return on expenditure | | Houghton (2011) | | Welfare approach and returns to expenditure | | approach | |  | | Website usage and number of | | downloads | |  | | Useful life of public sector | | information knowledge is 5 | | years | |  | | Elasticity varies over time | |  | | Information on marginal cost | | pricing | |  | | Limited to firms within SIC | | 7420 | | Koski (2011) | | Econometric approach examining impact of marginal | | cost pricing on real sales growth | |  | | Various control variables for firms | |  | | Average turnover per user | | calculated from survey | |  | | Public sector information turnover | | data | | Survey of PSIHs asking size of PSI market and sum | | of turnover of individual re-users minus cost of | | acquisition | | MEPSIR (2006) | |  | | Ratio of re-users per sub- | | domain was 9.5 (mean) and | | 8.5 (median) | |  | | Number of users and re-users | | Pollock et al (various) | | Gains from moving from marginal cost pricing is | | 2/5(Fλε) | |  | | F = total revenue from sales of | | public sector information | |  | | Multiplier varies between 5 | | and 8 and elasticity 2 to 3.5 | | Productivity based approach for use and non-use | | values - Computable General Equilibrium (CGE) | | model | |  | | Extensive macro- and | | microeconomic data required for | | CGE modelling process | |  | | Various assumptions underpin | | CGE model | | ACIL Tasman (2009) | | Author | Approach summary | |--------------------------------------------------------|------------------------------------------------| |  | | | Assumptions on adoption | | | rates from literature | | | Future efficiency-gain approach - combination of a | | | literature review tracing impact of R&D and impact | | | on profits of start-ups due to reduced entry barriers | | |  | | | ONS economy data by sector | | | Cebr (2012) | | |  | | | Impacts via business | | | efficiency, innovation and | | | creation | | | Gains from making address data free of charge | | | quantified comparing use of data before and after | | | policy change multiplied by price | | |  | | | Counterfactual of what would | | | have happened anyway | | |  | | | Volumes of data usage | | | Cowi A/S (2010) | | |  | | | Extensive macro- and | | | microeconomic data required for | | | CGE modelling process | | |  | | | Various assumptions underpin | | | CGE model | | | Deloitte Access (2011) | | | CGE modelling to analyse the productivity improving | | | from addressing the 'information glut' | | |  | | | Spending and taxation data | | |  | | | Various underpinning each | | | calculation | | | Combination of an index on value potential and | | | index on the ease of capture; scaling up drivers in | | | case studies; and identifying the addressable share | | | of market for efficiency gains | | |  | | | Graduate and employee data | | | McKinsey (2011) | | |  | | | Capital stock data | | |  | | | Bespoke case study data | | |  | | | Two categories of public | | | sector information: public | | | sector information for final | | | users and public sector | | | information for intermediate | | | users | | | Investment cost estimates and demand side | | | estimates built from cost of time, access price, price | | | paid for public sector information etc. | | |  | | | Annual reports | | | PIRA (2000) | | |  | | | Statistical agencies data | | |  | | | Costs allocated accordingly | | |  | | | Proportion of fixed to total costs | | |  | | | Assumptions on multipliers | | | and elasticity | | | PwC (2010) | Welfare approach | |  | | | Administrative costs | | |  | | | Proportion of purchases by firms | | | Roger Tym & Partners (2003) | Surveys on willingness to pay and case studies | |  | | | Survey of customers | | | | | | Oxera (1999) | | | Value-added approach that charts the different ways | | | public sector information affects the UK economy | | |  | | | GVA and revenue contribution | | |  | | | Various | | | | | Following a review of the different methodologies used, two broad ways of quantifying the current214 value of public sector information were considered: a bottom-up approach along the lines of the OFT/DotEcon methodology and a top-down approach using a SIC-SOC matrix. The top-down approach began by identifying the number of jobs directly involved in the supply, use and re-use of public sector information. This was on the basis of Standard Occupational Code (2010) (SOC) categories of jobs and the numbers employed in each. The categories identified as being involved in public sector information were:  science, engineering and technology associate professionals;  information technology and telecommunications professionals;  IT business analysts, architects and system designers;  IT and telecommunications professionals not elsewhere classified;  management consultants and business analysts;  actuaries, economists and statisticians; and  business and related research professionals. While this might not capture all jobs involved in public sector information, it is a useful first approximation. The next stage was to allocate these jobs across different sectors of the economy using a bespoke SIC215-SOC matrix which shows how SOC jobs are distributed across different sectors of the economy. Having an estimate of the number of public sector information-related jobs in each sector of the economy allowed the estimation of the level of turnover attributable to public sector information (using worker productivity ratios) in each sector and then adjust to focus only on value. However, as has been noted elsewhere216, such a top-down approach, while straightforward, has a number of drawbacks which reduce its viability. Namely:  it does not properly account for the counterfactual or the additional impact of public sector information; and  accordingly there is a risk of over-stating the value of public sector information. While it may be the case that public sector information may underpin a number of products and services in a given sector, not all the value in that sector can be traced back to public sector information. Further, such analysis does not explicitly consider what value the sector could generate using substitutes to public sector information if it were no longer available. ## For These Reasons, This Report Uses A Bottom-Up Approach Modified From The Oft/Dotecon. The Quantification Approach For The Current Value Of Public Sector Information The approach has two main stages:  Stage 1: estimates of the value of public sector information to PSIHs and value to direct users of public sector information using a consumer and producer surplus approach; and  Stage 2: estimates of the value of associated indirect and induced impacts to PSIHs using Input-Output model multipliers (this stage was not carried out by DotEcon). This report has not sought to quantify the value of the wider societal impacts of public sector information using a systematic methodology. There is a lack of reliable evidence on the linkages between the use and re-use of public sector information and the impact on environmental, political, social and other indices - though, where possible, the report has made ad hoc estimates of the value generated from particular datasets. ## Stage 1: Consumer And Producer Surplus Approach - The Welfare Approach The welfare approach can be estimated from summing the current net consumer surplus217 with the total producer surplus218 from the supply of public sector information. The approach differs according to whether the public sector information in question is paid-for or free. By focusing on consumer surplus, which takes into account the presence of substitutes, the report is able to accommodate the presence of substitute public sector information datasets and in doing so captures the additionality impact. Paid-for public sector information One of the key drivers for the size of value arising from paid-for public sector information is how demand varies with price changes (its price elasticity of demand) - this will influence the size of consumer surplus. When demand is more elastic, the economic value is likely to be lower as customers will switch to substitute products in response to price rises. When price elasticity of demand is low or inelastic, economic value will be higher as customers will be less inclined to switch to substitutes - perhaps because there are few true substitutes. Clearly, a critical assumption will therefore be the price elasticity of demand for different categories of public sector information and PSIHs. The value of the price elasticity of demand will depend on the benefit users and re-users currently enjoy from public sector information in 2011-12 and will differ by dataset and it unlikely to be stable as new benefits and uses emerge. Additionally, price elasticity will be influenced by the availability of substitutes and context (e.g. some data is only valuable at a particular point in time). In the time and resource available it has not been possible to survey customers to generate new price elasticities of demand for different public sector information datasets. On this basis, the report has relied on the long-run elasticities presented in the DotEcon report for the OFT. It is acknowledged that the elasticity values will have changed since 2006 especially given the greater availability of open data from PSIHs. However, the other key driver of elasticity - the availability of substitutes - has not changed significantly since the report as there has been no emergence of new competitors in the provision of public sector information in most cases. Clearly, this is an area where new primary research is required, but for the purposes of this evidence base this is considered to be a sufficient starting point for indicating the value of public sector information. Following the approach by DotEcon, the report uses three broad classes of elasticity for different types of PSIHs and public sector information datasets:  Low elasticity: -0.3  Medium elasticity: -0.8  High elasticity: -1.5 These elasticity figures are treated as the baseline. However, as is good practice, the report considers adjusted alternative values for each category following research by Davies, Slivinski, Bedrijvenplatform, Lazo and others219. | Case | Baseline | Alternative 1 | |---------|-------------|------------------| | Low | | | | -0.3 | -0.5 | -0.2 | | Medium | | | | -0.8 | -1.2 | -0.6 | | High | | | | -1.5 | -2 | -1.2 | Source: Deloitte analysis drawing on OFT/DotEcon research These elasticity figures are then matched to a number of key PSIH suppliers in the dataset. | PSIH | |-------------------------------| | HM Land Registry | | Low | | Registers of Scotland | | Low | | Companies House | | Low | | Ordnance Survey | | Medium | | UK Hydrographic Office | | Low | | Environment Agency | | Medium | | Met Office | | Medium | | DVLA | | High | | Office of National Statistics | | Low | Source: Deloitte analysis It is acknowledged that these are not the only suppliers of pay-for public sector information in the UK. However, as noted by Newbery et al (2008), it is estimated that the Trading Funds listed above comprise around 70 per cent of the estimated total income from UK PSIHs, and this captures a sufficiently large dataset population (and the subsequent calculations 'gross-up' the figure to capture the full value). The choice of elasticity assumption assigned to each PSIH is based on a combination of the understanding of the public sector information held and disseminated by each PSIH, its use and reuse, the level of substitution, discussions with stakeholders and the nature of customers - they have been adjusted from the 2006 mapping. There is, by necessity, an element of abstraction due to the diversity of datasets supplied for a fee by each of the above PSIHs. To accurately calculate total consumer surplus for the pay-for public sector information market, it is necessary to understand the shape of the demand curves for each dataset. Attempting to derive individual demand curves for 4,000 plus datasets is clearly not feasible and the report has instead posited aggregated demand curves for each individual PSIH. For simplicity, and following previous quantification approaches, the report assumes linear demand curves for pay-for public sector information. This appears justifiable in this instance along similar lines to those set out by DotEcon: "While in practice demand curves may not be linear, assuming a linear demand can reasonably be argued to give a lower bound on consumer surplus, as real-world demand curves are often convex (as shown in the dotted line) and thus result in a greater difference between willingness to pay and costs. With more complex specifications of demand, this formula is more complex, but there is still a one-to-one relationship between revenue and consumer surplus."220 There is perhaps more scope for debate as to the shape of the demand curves when it comes to free public sector information - this is discussed this in more detail below. Thus, using the assumption of linear demand curves, it is possible to recover the consumer surplus (i.e. value to the direct users of public sector information) calculated using the standard formula: Formula (1): Consumer surplus = ½ (Revenue / Price Elasticity) Source: Deloitte analysis Formula 1 is used for each PSIH in turn. Revenue data is sourced from annual reports from PSIHs and adjusted following discussions with stakeholders. In particular, it should be noted that a proportion of Trading Funds' revenue is not related to the provision of public sector information and should accordingly not be included. PSIH Total revenue, 2011-12 (£) Of which, is public sector information related (£) HM Land Registry 360,000,000 72,000,000 Registers of Scotland 58,000,000 12,000,000 Companies House 66,000,000 15,00,000 Ordnance Survey 142,000,000 142,000,000 UK Hydrographic Office 19,000,000 13,000,000 | Total revenue, 2011-12 | Of which, is public sector information | |-------------------------------|-------------------------------------------| | PSIH | | | (£) | related (£) | | Environment Agency | | | 417,000,000 | 834,000 | | Met Office | | | 196,000,000 | 121,000,000 | | DVLA | | | 459,000,000 | 1,376,000 | | Office of National Statistics | | | 29,000,000 | 29,000,000 | Source: Deloitte analysis based on Public Data Group publication *Approach to Charging* and making adjustments for revenue that is not public sector information related, December 2012. Numbers rounded. Note the above figures have not been 'grossed up' for the missing Trading Funds. The assessment of producer surplus from paid-for public sector information also follows the DotEcon approach. As they note: "In order to estimate the producer surplus or loss, we would require estimates on the costs of collecting and supplying the data and then compare this to revenue. However, estimates on the costs of supplying [public sector information] data for each group are not readily available. In addition, many of the costs of data collection and processing may not be related to the supply of [public sector information] to the private sector, but might result from other public policy objectives that already take such costs into account."221 Accordingly, when PSIHs do not report a target rate of return on capital employed (ROCE), losses and profits are assumed to be accounted for in the setting of public policy objectives are left out of the assessment (i.e. the National Office of Statistics). In contrast, where a ROCE is stated, this reflects the cost of capital is taken into account when setting public policy objectives and producer surplus can be estimated as the difference between actual and target ROCE222. Formula (2): Profit = Revenue ([actual ROCE - target ROCE] / [1 + actual ROCE]) Source: Deloitte analysis Again, the report has used financial data from annual reports and stakeholder discussions to calculate producer surplus (profit) for each PSIH where relevant. For most Trading Funds, the ROCE target is the standard 3.5 per cent figure - actual ROCE data for each Trading Fund can be found in their annual reports. Given the Office of National Statistics is structured differently and does not have to make a return it is not included in producer surplus figures. Free public sector information Clearly where there is no price for public sector information the above methodology becomes more challenging - using revenue data to estimate consumer surplus is not feasible as there is no PSIH revenue attributable to free public sector information. Further there is no producer surplus to capture as the information is made available for free by PSIHs. There are also valid questions as to whether the demand curve for free public sector information datasets can still be assumed to be linear - they may be convex or concave. The different potential shapes for the free public sector information demand curves are shown below. ## Figure A5.7: Potential Demand Curves For Free Public Sector Information Source: Deloitte analysis In all cases, given the 'price' for free public sector information is zero, consumer surplus is the entire area under the demand curve and can be found taking the integral of the curve. However, as is known from behavioural economics literature, consumer behaviour can move in unexpected directions as price moves from zero to a nominal amount and vice versa223. In the lefthand corner, assuming a linear demand curve suggests that as price moves away from zero, consumers react by reducing the quantity demanded proportionally. This may not be the case if consumers react to the price becoming non-zero by not reducing their consumption proportionately - this may suggest a convex, concave or a kinked demand curve. The shape of the demand curve will therefore have a significant bearing on the size of consumer surplus224. In the available time and resource, it has not been possible to collect primary data on consumer behaviour to changes in price from zero. In the absence of such data, any specification for the demand curve will be assumption driven: in the case of linear demand curves that consumers proportionately adjust quantity demanded to changes in price, in the case of convex demand curves that the integral sufficiently approximates a discrete summation and is not biased by the units of scale. Following convention, and as a simplifying assumption (and for reasons of consistency with pay-for public sector information), the report continues to use a linear demand curve formulation. However, for completeness an alternative demand curve formulation is considered. Beginning with the linear demand curve formulation, in the absence of detailed willingness to pay data on different types of free public sector information, it is necessary to make a series of assumptions to recover a provisional willingness to pay for free public sector information. The DotEcon methodology suggests one approach for this: assuming the choke price (or maximum willingness to pay) for raw data (taken as a proxy for public sector information) is equal to the choke price of value-added (pay-for) public sector information minus the current price of valueadded public sector information225. Using linear demand curves for modelling simplicity, this methodology assumes that value-added public sector information is competitively priced in the main and that the willingness to pay for this would not exceed the willingness to pay for raw data (a proxy here for free public sector information) plus the cost of value-added features - unless the consumer would be better of obtaining the raw data and performing the value-add services themselves. Using geometry it is possible to recover the choke price for pay-for public sector information. However, in order to do this it is necessary to use average prices for pay-for public sector information. This is not straightforward as prices vary by dataset, volume, usage and consumer type and we have been informed there is no such thing as an 'average price' per dataset. The report has sought to recover a proxy average price using annual report data of Trading Funds and then used geometry to calculate willingness to pay estimates for different types of free public sector information. The average value for free public sector information willingness to pay is estimated to be around £1,300 with the figure varying between £500 and over £2,000. While this figure may appear high, it should be noted it encompasses the willingness to pay across the economy and all types of users and re-users, ranging from individuals looking up civil servant pay levels to SMEs developing apps that harness bus timetables to large multi-nationals downloading free economic statistics. This appears to be a reasonable first approximation for these indicative estimates. It would be advisable to conduct more research to ascertain a more accurate, disaggregated figure. Having recovered willingness to pay for free public sector information, quantity or usage of this information is still required. As discussed in an earlier chapter, data on the number of downloads and page views from a number of major data portals such as data.gov.uk and ons.gov.uk has been gathered - approximately 2.7 million downloads over a twelve month period. Based on the assumption that of these downloads around two thirds of the datasets are actually used or re-used (approximately 1.8 million uses and re-uses). Having quantity used / re-used and the willingness to pay allows us to generate revenue and using the previous linear demand elasticity assumptions it is possible to recover consumer surplus for free public sector information. The alternative calculation of surplus assumes a Cobb Douglas demand curve with customers maximising their utility of consumption from public sector information and all other goods subject to a budget constraint. Through a series of algebraic manipulations it is possible to recover the formula for consumer surplus as: ## Formula (3): Consumer Surplus = Price*Ln(Demand) The estimated quantity (demand) and price (willingness to pay) figures can then be used to calculate consumer surplus in this instance. The final estimates have taken an average of the linear and Cobb-Douglas estimates. ## Stage 2: Indirect And Induced Value Of Public Sector Information Estimates of the value impacts accruing through the business-to-business supply-chain, and employees spending associated wages, are based upon the UK Domestic Use Matrix for 2005 (latest available tables accounting for import leakage) from ONS and the direct use estimate derived above. The direct use estimate of producer surplus (analogous to operating profit) is converted into expected gross output (GO) for each relevant industry on the basis of information contained in the UK DUM. This process is uses the inverse of the industry average ratio of operating profit to GO. GO TYPE I and TYPE II multipliers are then used in an Input-Output setting to consider the upstream business-to-business purchasing effects (indirect) and consumer spending effects (induced). The average GO multiplier used in this process was estimated to be in the order of 3.0. To allow a comparable estimate of value to the original producer surplus (and thus allow aggregation with other quantified elements), the results are converted back from GO into GVA and then, in the same manner, operating profit, by definition, providing a comparable surplus estimate. Again this is achieved by considering the ratios of operating profit to GVA and GO, relative to the incremental GO for business-to-business spending and consumer spending. The 'surplus multiplier' - the ratio of indirect and induced surplus to the direct use surplus - was estimated to be 3.4 (1 + 2.4). For each £1 generated as producer surplus in direct use, a further £2.40 is generated via indirect and induced effects. Per worker productivity estimates sourced from ONS through the Annual Business Survey are then used in conjunction with estimates of GVA to provide an indicative level of employment supported in organisations supplying inputs to the PSI supply chain and supply goods and services to consumers. ## Appendix 6: Transport Sector Case Study Over the last decade the release of ever greater volumes of detailed and real-time information has had a considerable impact on the transport sector. This appendix focuses on quantifying the impact of releasing transport data in London, where particularly large volumes of information have been made available. It also discusses impacts further afield and the future opportunities for increased use of information. It is therefore an extended version of the transport case studies presented in Chapter 5. ## Overview Over the past decade the UK transport sector has seen the release of ever greater volumes of detailed and real-time information. This has allowed travellers to plan and adapt their journeys in response to real-time updates on conditions across the transport network, as well as allowing improved public scrutiny of the performance of the transport system. This section highlights some of the ways in which information has impacted the transport sector. There is a particular focus on London, which - partly owing to the extent of its transport network - has seen particularly high volumes of information released, and a correspondingly large number of products and services developed to allow travellers to access this information and use it to enhance their journeys. As part of this case study there is an attempt to quantify part of the impact of releasing this data, by assessing the value of time saved through better access to up to date travel information. This case study also assesses the impact of information on the transport sector outside London: in other cities and on inter-city transport by road and rail. Where possible it offers some estimate of the value generated by information in these areas, although any such figures should be treated as high level assessments based on reasonable assumptions, in the absence of the data that would be needed to conduct more detailed calculations. Information released by Transport for London London is unique among the UK's cities in the extent and complexity of its transport network. Its underground network alone comprises over 400km of track, with over 500 trains operating across the network at peak times. Each train travels over 184,000km a year, carrying 1.171 billion passengers in 2011/12. This is in addition to approximately 19,500 bus stops served by around 7,500 buses226; an extensive overground rail network; light rail networks including the DLR and London Tramlink; and a riverboat service operating from Greenwich to Millbank. In addition, London has an extensive road network, with private motor vehicles accounting for more journeys than the underground and buses combined.227 Source: www.tfl.gov.uk This complexity means that detailed and current information is vital to enable travellers to efficiently navigate the network. This includes maps, timetables, and up to date information on closures, disruptions and delays. Transport for London (TfL) has signed up to the transparency agenda and provides a wide range of information to users and re-users - principally through its website but also through other channels. In so doing it builds on the 2010 Mayor's Transport Strategy, which included among its commitments "improving the provision of real time and other journey planning information, including upgrading the TfL web-based journey planner, allowing further improvements to its real time performance, accuracy and personalisation." TfL writes that through transparency it hopes to:  "Enable our stakeholders to hold TfL to account;  Deliver better value for money; and  Enable businesses and non-profit organisations to develop innovative applications using our data."228 ## Accessing Information The information collected and released by TfL is largely made available to developers and the general public through their website. For developers, at the time of writing, there are 29 data feeds available in TfL's Developer Area.229 For information, the complete list of data feeds available is included at the end of this appendix. This data is not published under the OGL, and the licensing terms for developers set by TfL include some restrictions, including branding conditions. The data is, however, available free of charge, and TfL encourage its re-use in innovative ways, subject to licensing conditions. The TfL website contains an extensive guidance system providing contextual information and assistance for each feed, as well as suggestions for its use by developers.230 For users other than developers, TfL provides information directly through its website under the 'getting around' and 'live travel news' sections. The information available includes:  a range of maps;  station locations;  accessibility information;  live service updates;  live departure information; and  information on planned works and weekend closures. Other ways of accessing the information include a free mobile service alerts service for the tube and DLR. In addition, there are several free tools available for non-developer users, including a journey planner. ## Usage Levels In the absence of usage figures, the analysis here presented is based on the apps available in the UK through the Apple App Store and Google Play (for Android apps) which use TfL data. This analysis suggests that in the UK across both platforms there have been around 500,000 downloads of apps relating to bus services, and around 2.6 million downloads of apps related to tube services. In addition there have been nearly 900,000 downloads of apps covering both the bus and tube networks. This means that in total there have been nearly four million downloads of apps using TfL data.231 It should be emphasised that these figures give only a very rough estimate of the number of users of TfL data. Many users will access the information directly through the TfL website, through another website, or through other services. There is also no guarantee that an app download translates into regular use, as users may download an app but then decide either that they do not like it (and download an alternative), or fail to integrate it into their daily routine. Nonetheless, these figures are indicative of the high level of uptake of TfL data. It is also important to recognise that much of this information has long been available through other forms. For example, even before the invention of the internet it was possible to access information about disruptions to travel through the media, such as the television and radio news. Drivers have long listened to radio traffic updates to help them avoid congestion. However, this information is now significantly easier and more convenient to access at a time that suits the user rather than the distributor of the information. The use of smartphone apps allows instant access to detailed up-to-date information on the status of all aspects of the transport system, as well as enabling users to plan an alternative route if necessary. There is likely to be value in this added convenience, both in terms of a greater number of users of the data, and also due to improved access to the latest information when on the move. ## Benefits Conceptually, it is easy to see how the information provided by TfL has generated a range of benefits. The most notable benefits are likely to be derived from:  Live arrival and departure times for trains, buses and the underground Developers are now able to offer smartphone apps which allow travellers to see how long they need to wait for the next bus, or when their next train home will be departing. This means that they are able to make more efficient use of their time, with less time wasted waiting, and are able to make informed decisions about the most efficient way of completing their journey. For example, if there is a 12 minute wait for the next bus, it may be more time efficient to walk five minutes to the tube station instead. With this information, travellers are empowered to make better decisions  Traffic cameras and congestion data for the road network Access to live traffic cameras for drivers and other road users means that it is now possible to plan a route in advance avoiding areas with heavy traffic and incidents such as road accidents. This information is available both via the web, as with the BBC Travel News website shown below, and on the move via smartphone apps. It is also possible to access information on congestion and average traffic speeds along a route. Source: www.bbc.co.uk/travelnews/london/trafficcameras  Oyster Card data allowing travellers to track their usage By registering an Oyster Card online, users are now able to view a history of their journeys on TfL services, including how much each journey has cost them and the start and end times. This allows users insight into their usage patterns, including the time and money they spend on transport, and might potentially encourage behaviour change, for example changing their travel patterns in order to travel outside peak time and take advantage of lower fares, where possible.  Oyster Card data giving insights into the flows of travellers through the transport network A by-product of the Oyster Card system is an extensive database containing details of every journey taken on the London public transport network, allowing TfL to monitor journey times and volumes of passengers across the network. This should enable the transport network to be run in a more resilient way, revealing common bottlenecks and allowing the impact of delays and closures to be modelled across the network, improving contingency planning. That the changes described above will benefit both users and operators of the transport network seems clear. In many cases it is difficult to identify and isolate the precise impact of each benefit, beyond incremental improvements to efficiency and user convenience. However, there follows details of a quantification of some aspects of these benefits, notably time savings to travellers. Quantification of benefits ## Tfl 'Lost Customer Hours' Data TfL track the performance and reliability of all their transport services. However, each mode of transport reports its performance in different ways. London Underground publishes performance reports covering each 28 day period throughout the year. To understand the overall level of delay caused by a disruption on the network, London Underground uses a measure known as Lost Customer Hours. This is generated by multiplying the duration of a disruption by the number of people estimated to be affected, based on the severity of the incident and expected customer demand at different times and places. Lost Customer Hours therefore accounts both for those who faced delayed journeys, and for those who were unable to travel at all. Over the year to October 2012 the underground network averaged just under two million lost customer hours per month. London buses do not provide information on lost customer hours in their performance reports. Annual lost customer hours have been calculated by taking the figure for the average 'excess wait' (beyond that timetabled) and multiplying it by the number of annual passenger trips made by bus. For private road users, London Streets benchmarks performance by measuring 'journey time reliability' (JTR): the proportion of journeys completed within an allowable excess of five minutes for a standard 30 minute journey during the morning peak. The analysis is based on taking the JTR figures and multiplied them by the annual number of driver and passenger journeys, and separately the number of taxi journeys, to work out the number of journeys experiencing delays in excess of five minutes. An assumption regarding the average time lost per delay is multiplied by the number of delayed journeys to arrive at a figure for lost customer hours for private road users. The approach to rail travel (London Overground) is similar: the reliability figure of 96.6 per cent for 2011-12 from the Travel in London Report and is used to work out the number of delayed journeys. An assumption regarding the average time lost per delayed journey is then used to calculate a figure for lost customer hours for London rail travel. Note that this refers only to London Overground, the TfL-operated rail network. It does not include rail travel to and from locations outside of London; nor does it include non-TfL services run by national rail operators in London. ## Apps Using Tfl Data An online resource (www.xyo.net) has been used to estimate the number of downloads of apps based on TfL data, as described above. Although these figures should not be assumed to be fully accurate, they give a sense of the level of demand for apps using TfL data. It is unlikely that all app downloads lead to regular use of the app. It may be that a user downloads an app to try it out, but decides they do not like it and deletes it in favour of an alternative. Equally, it is likely that some people download an app but then fail to develop the habit of consulting it regularly. This is accounted for in the model. The model includes both a conservative scenario, in which 20 per cent of app downloads lead to regular use, and an optimistic scenario in which 40 per cent of app downloads lead to regular use. These percentages are then applied to the total app download figures to generate conservative and optimistic figures for regular app use. Note that the multi-function journey planner apps are included in the totals for both tube and bus, as they are equally applicable to both. These figures apply only to bus and tube passengers. It should be noted that in addition to the benefit to users of apps (who are second order users of the data), which is the focus of this analysis, there will be first order benefits from the data through contributing to an app economy which provides jobs, tax revenue, and other benefits. Even where apps are not charged for they may create jobs, as there are other mechanisms for revenue generation (for example through advertising). This 'infomediary economy' is an additional benefit from the release of TfL data. This aspect is not quantified in this analysis, but it should be borne in mind as another wider economic impact of releasing the data. ## The Model By making some assumptions about the number of passenger hours saved through better access to information, and the value of an hour, it is possible to estimate the time potentially saved, and the value of that time, owing to the information released by TfL. The model uses Department for Transport figures for the value of time, published in October 2012. They make a distinction between working time, which is a business cost, and non-working time (including commuting) which is time to which each individual attaches a value. The value of working time in the DfT analysis varies by mode of transport. The figures provided by the DfT are for 2010; in this analysis they have been inflated at the prevailing rate of CPI to estimated 2012 values. The full DfT cost of time figures are provided for reference at the end of this section. To work out the number of passenger hours saved, the model is based on TfL figures for customer hours lost, or calculations of these where the data is unavailable, as described above. The proportion of passengers likely to be using an app based on TfL data to access travel information is then calculated, based on the download figures. In addition to the two scenarios regarding the level of regular app use, it is important to recognise that not all travellers would be able to adapt their route even if they knew that they faced disruption on their planned route. For example, someone needing to travel from High Barnet to Waterloo would be likely to have no viable alternative to the Northern Line, even if this meant enduring significant delays. The model therefore factors in two additional scenarios: a conservative assumption in which ten per cent of users are able to alter their route in response to information on delays, and an optimistic scenario in which 25 per cent of users are able to alter their route. Although DfT provide a range of values of time, this model uses the lowest value - for leisure/commuting - rather than the higher working time values. Adopting this approach generates conservative estimates, in the absence of more detailed information on the types of travellers affected by delays. It is also reasonable to assume that the majority of journeys do not occur with business as the primary journey purpose. However, it should be noted that introducing the value of working time into the model would mean that the estimated value of time saved would become significantly higher due to the large differential between leisure/commuting and working time in the DfT values of time. ## Findings The estimate of the value of time saved through use of TfL data generated by the model ranges from around £15 million to nearly £58 million per annum (based on 2012), depending on the scenario for level of app use and ability of travellers to change their journey routes. Of this value, around a third is accounted for by savings for underground passengers, and another third by savings for passengers of London trains (over-ground). The remainder is split roughly equally between bus passengers and private vehicles. Taxis account for a relatively small level of savings, due to the low number of passengers relative to other modes of transport. It should be noted, however, that if the values of working time are used the savings for taxi users become relatively more significant, as the DfT accords taxi users the highest value of time of any mode of transport. These figures are shown in the chart below. Source: Deloitte analysis The number of beneficiaries, i.e. passenger journeys which save time as a result of travellers using TfL information, is shown in the graph below (millions of journeys). Under the most conservative scenario around 200 million passenger journeys per year are estimated to save time due to TfL information, while under the most optimistic scenario the figure is over 700 million passenger journeys. The highest number of beneficiaries are private car users, indicating that under this modelling approach there are a large number of car users experiencing savings to their journey time, but that the time saving to each journey is relatively small. Source: Deloitte analysis ## Summary It is important to note the limitations of these figures. They attempt to model only time saved due to travel disruption avoided - they omit the time potentially saved in everyday travel, for example by allowing commuters to time their exit from the office so as to catch the next bus. They are furthermore based on a range of assumptions regarding traveller behaviour, specifically assumptions regarding app use and ability to alter their route of travel, as well as estimations of the value of time that may not be accurate for all travellers. For these reasons the approach here adopted is the most conservative that seems reasonable. The figures represent the lower bound impact of TfL data - in other words, the true impact is likely to be significantly higher. By way of comparison, the much fuller HS2 benefit assessment estimated annual time saving benefits at a net present value to 2043 of £7.3 billion.232 On a per annum basis, over the 17 years between 2026 and 2043 (before which the line is not scheduled to be operational) this equates to £417 million in annual journey time savings, or £440 million in 2012 prices.233 This is based on many fewer passengers but a much greater journey time saving per journey. As such, the provision of exhaust PSI in London and its environs, at what is a relatively low marginal cost to Government, may create as much as 13 per cent of the annual monetised time savings of a major infrastructure investment such as HS2. In short, information is time, and time is money. Finally, these figures do not take account of the broader welfare benefits - for example social and environmental - which is likely to results from reducing friction and improving efficiency for travellers around London. These benefits, although beyond the scope of this study and difficult quantify, are likely to be significant. ## Tfl Statement In the course of the work on this case study, discussions were held with TfL. They have provided the following statement for inclusion in the report. "Every day, millions of Londoners and visitors rely on the information provided by Transport for London (TfL). Our online journey planning and service update tools are essential sources of travel advice used by 8 million customers. And through traditional media such as radio, television and newspapers, our travel information reaches millions more. But in our aim to deliver world leading customer service, we are now realising the enormous potential of opening up our data sources to the wider community. Our digital strategy, formulated in line with the UK Open Government agenda and the Mayor of London's open data policies, sets out our commitment to free data, updated in real time where possible, to encourage web and app developers to create the tools and services our customers want. Over 5,000 developers have already signed up to our data feeds, supporting hundreds of travel apps and helping millions of end users - all achieved at much less cost than were the same services created using TfL's own resources, and while supporting the digital economy. The wider economic benefits of releasing data are clear. If transport is disrupted for some reason, real-time customer information can alleviate the impact by helping people choose alternative routes. The case study presented here estimates that this benefit alone may be worth tens of millions of pounds per year. Yet even when transport is running smoothly, TfL's journey planning information helps people select the quickest or least congested route, while recent innovations, such as our release of real time bus arrival data, enable customers to adopt a 'just-in-time' approach to their travel, reducing waiting time and freeing up time for more productive activities. TfL has also exploited the opportunities of customer information, both open source and through our own channels, to tackle some of the biggest challenges a transport operator can face - from alerting people to travel hotspots during the London 2012 Games, when 60,000 people followed dedicated Games travel advice on Twitter, on top of TfL's usual 400,000 followers, to supplying real time service updates to keep London moving during critical transport infrastructure upgrades. Moreover, it's not just TfL's customers that benefit. Providing high quality real time information also helps us, as a transport operator, to provide a better service through people avoiding already crowded stations or roads, and to recover quickly from disruption by giving our customers choices. While providing substantial benefits, the continued release of data does incur some up front and ongoing management costs, so we would encourage developers using our feeds to share analytics with us on how customers use their products, to improve our ability to release the most useful data and drive the greatest value for money. In summary, we recognise the substantial advantages resulting from open transport data, for customers, for operators, and for the wider economy. We welcome the findings of this case study into the impact for disruption mitigation, and will continue to seek ways of making our data even more accessible and useful." releasing transport data for London are a significant proportion of the estimates for journey time savings delivered by a major national infrastructure project such as HS2, for much lower investment of resources. The estimated savings for HS2 include values of working time. If only the value of leisure/commuting time is included (as is the case for the calculations of the value of savings in London), the value of time saved by HS2 falls to £105 million per year. This figure is not used as it is likely that HS2 will be used more heavily for business travel, whereas London transport is more heavily used for commuting and leisure purposes. However, this illustrates that the relative significance of the savings due to release of information are likely to be greater than the 13 per cent of HS2 savings suggested above. ## Information Relating To Transport Beyond London This case study focusses on London and specifically the information released by TfL. London provides a particularly compelling example of the benefits that can be generated by releasing information. This is partly due to the large volumes and variety of information released by TfL, and the user-friendly formats in which it is provided. It is also because London is unique in the UK both in its size as a conurbation and the scale and complexity of its transport network. It is reasonable, however, to anticipate that benefits from the release of information in other cities in the UK also exist, either actually or potentially; as well as benefits to inter-city rail and road transport. Anecdotally, the transport systems of other major UK cities such as Manchester and Leeds are not well served by tools such as smartphone apps, either because the information has not been made available or is not in an adequate format, or because there are not a sufficiently high number of users to justify creation of an app. The latter seems unlikely, given the number of apps available and the very limited use base to which some of them cater: if nothing else, one would expect an app to be created as a service to the community. An example of an initiative in this area is the Future City Demonstrator, for which Glasgow won £24 million of government funding early in 2013. In its press release the ODI noted that "open data will be at the heart of the programme. People will be able to monitor traffic levels on the road, before beginning their journeys. They will also be able to check whether bus and train services are running to time."234 In many ways this is similar to the services already available in London, indicating that other cities are interesting in developing a similar 'open data infrastructure' to support and improve the operations of their physical transport infrastructure. Due to smaller transport networks and fewer passenger journeys, the scale of the benefits realised are unlikely to match that experienced in London. For example, the Glasgow subway contains 15 stations and a route length of ten kilometres, just 2.5 per cent of the length of the London Underground. Nonetheless, all things being equal it is to be expected that there will be benefits in line with the scale of the transport systems involved. There will also be a broader social and environmental value to the more efficient running of these transport systems. In addition to benefits in other cities, there are potential benefits to be realised in inter-city transport. With nearly 490 billion vehicle kilometres recorded on major roads in England and Wales in 2011, and just 81.9 per cent of journeys completed on time in the year to October 2012, there appears to be significant scope for improvements.235 The case study below highlights one example of how the release of information is capable of improving inter-city transport. ## Traffic England Traffic data is available through Traffic England, a service provided by the Highways Agency's National Traffic Information Service. The information covers most of the motorways and major A-roads in England. Data includes real time information on traffic speed for each section or motorway or road, details of disruptions and closures, and other useful information such as weather conditions. Users are able to employ the information provided through this service to:  monitor regular commutes;  avoid unnecessary queues and delays;  see how busy the roads are by viewing live traffic cameras;  identify roadworks and whether or not they are causing delays; and ## Traffic England  plan business trips, deliveries and holidays by checking future roadworks, events and forecast traffic conditions that are expected to cause delays. ## Traffic England - Motorway Traffic Flow Source: www.trafficengland.com/motorwayflow.aspx?ct=true#mtf Traffic England notes that the website receives around 960,000 visitors per month.236 As an indicative estimate, if 50 per cent of these monthly users were to save ten minutes of journey time, using a low value o time of £6.80 per hour (based on DfT figures), this would generate time savings worth over £544,000 per month, or over £6.5 million per year. These are very high level estimates based on broad assumptions about the level of time savings achieved by users, but provide an indication of the scale of benefits, in terms of time saved, that could be expected to be currently generated by th It seems safe to assume that not all road users who could benefit from this information are currently aware of or using it. It is therefore likely that the potential or 'latent' benefit from increased exploitation of the information is even greater than the current benefit in journey time savings. In 2011 there were nearly 490 billion vehicle km travelled on major roads.237 If even one per cent of these could made more efficient or timely through the use of better information, this would improve journeys totally nearly five billion km. Assuming an average speed of 35 km/h, this would equate to 140 million hours of journey time affected. Note that this is not time saved, but serves to illustrate the potential scale of the impact of improved access to information to road users if even very conservative assumptions are applied. In addition to the financial value of time saved, there will be other financial savings, including fuel savings, and avoidance of cost to delivery services and the businesses they serve owing to delays. There will also be wider non-financial benefits, including environmental benefits from reduced transport emissions, and benefits arising from reduced road congestion. Further to the 'latent' benefits that could be gained from increased use of the available information under current conditions, there is likely to be an additional benefit from future use as congestion becomes more prevalent across the UK road network. The DfT estimates that in 2010 eight per cent of traffic travelled in 'very congested conditions'. It forecast that by 2035 this figure would be 17 per cent, rising to 42 per cent for London (if no further investments in road infrastructure are made beyond those set out in the 2010 Spending review). This equates to 32 lost seconds a mile for all traffic by 2035, and 140 lost seconds a mile in London.238 This increased risk of congestion and delays seems likely to increase the need of drivers for detailed and up to date f is service. ## Traffic England traffic flow information, and increase the amount of travel time that could potentially be saved through use of information. In addition to increased exploitation of the information, it is likely that its value to road users will increase as more information is made available, and the tools for accessing and manipulating the information become more powerful. Traffic England is currently running a Traffic Map Beta which offers improved and more resilient information on speeds by drawing data from a wider range of sources, as well as extended coverage. As the information improves it is likely to generate higher levels of value for users. One of the challenges for the release and use of information relating to the national road network is the lack of cohesion amongst the responsible bodies. The House of Commons Select Committee on Transport has summarised the organisational structure:  the Secretary of State has responsibility for overall Government policy on roads, puts the relevant legislation in place, sets the strategic framework for new developments in traffic management, and establishes financial parameters;  the Highways Agency is an executive agency of the Department for Transport (DfT) and, on behalf of the Secretary of State, operates, maintains and improves the strategic road network - most motorways and all-purpose trunk roads - in England;  local highway and traffic authorities - County Councils, Metropolitan Borough Councils, Unitary Authorities, London Boroughs and Transport for London - are responsible for all other public roads (including non-trunk 'A' roads, 'B' and 'C' roads) and a small number of short, motorway standard 'A' roads in major urban areas; and  Integrated Transport Authorities (ITAs) (which replaced the six English Passenger Transport Authorities in 2009) have full responsibility for local transport plans in their cities and can modify governance arrangements within their areas.239 Given this complexity, information is often split across different jurisdictions and may be unavailable in a consolidated form or a single location - unhelpful for road users whose journeys may well take them across several administrative boundaries. The case study below examines the role of roadworks.org in improving access to data by combining data held by multiple authorities. ## Improving Access To Fragmented Information - Roadworks.Org Information on when and where roadworks will take place has the potential to allow road users to plan their journeys better, in order to avoid congestion and the inconvenience and economic cost this incurs. However, in England and Wales roadworks information is split across 175 local Highways Authorities. Where it is published by local authorities this is done using a variety of bespoke platforms, which are costly to administer and cover only the area within the administrative boundaries of that local authority. The diverse formats of this disaggregated information make it difficult to incorporate into real-time systems with national coverage. This situation therefore incurs higher than necessary costs for local authorities while failing to serve the needs of road users. Roadworks.org is an attempt to provide a solution to this problem. It currently publishes details of over two million roadworks annually, from over 140 Highway Authorities in England and Wales. ## Improving Access To Fragmented Information - Roadworks.Org Roadworks.Org Source: www.roadworks.org This aggregated national database has demonstrated significant benefits including:  Many utility companies and their contractors, including BT Openreach, have embedded roadworks.org within their works management systems, enabling pre-coordination of planned works with those local authorities that have implemented roadworks.org. This reduces clashes and the disruption and congestion caused by works.  Roadworks.org provides a data feed API to over 60 companies, enabling them to use up to data and broad coverage roadworks data to develop innovative services. A recent report by ELGIN estimated the total benefits at £25 million per annum. This includes tangible benefits of £6.3 million arising from costs savings to each local authority owing to the greater efficiency of the service as compared to individual bespoke systems. | Tangible savings | Savings (£ per LA) | |---------------------------------|-----------------------| | Better coordination | 15k | | Communication with stakeholders | 20k | | Public enquiries | 7.5k | | Duplication of systems | 25k | | Fixed Penalty Notice revenue | 5k | | | | The remaining £19 million savings are calculated as 'intangible savings' from the benefits of reduced congestion owing to better coordination of works; and greater operational efficiency for utilities companies and local authority Highway Maintenance departments. These estimates are likely to be less accurate but give an indication of the scale of the benefits achievable. There are costs associated with this system. The paper calculated the total costs of operating the roadworks.org system to be £700,000 per year (based on 2011/12 costs), implying a subscription fee of £4,000 per local authority if all 175 local authorities were to subscribe. This is set against estimated tangible savings of £72,500 per local authority, in addition to the intangible benefits, meaning a net tangible saving of £68,500 per local Highway Authority (or £12 million p.a.). ## Improving Access To Fragmented Information - Roadworks.Org This case demonstrates an important point regarding information: there is generally a cost to making it available in the most useful form for users and through an effective distribution channel. However, where the cost benefit analysis is favourable, this is an investment worth making - even before the additional downstream benefits are estimated. This case also demonstrates the role that the private sector can play in helping public sector organisations make the best possible use of their data, in order to derive the maximum benefit for the lowest cost. It is also a unique example of governance to protect the a critical national dataset which is Open but crated by private risk capital Source: Elgin, 'A new public-private model for creating a national database of local roadworks' (March 2013) There are also benefits to be gained from opening up data in the rail industry. There is considerable effort currently being expended to increase the availability of data in this space, as the case study below demonstrates. ## Disruptive Innovation In Rail Travel - Placr And Other Providers Several companies are focussing on using information to disrupt the rail industry through innovative products and services. The objective is a liberalised data market which will allow a range of value-added services to arise, with the potential to considerably enhance the customer experience and disrupt the industry status quo - either through providing more accurate information on the nature of the service and any delays, cancellations or route changes, or by allowing customers to find more competitively priced ticket options. It should be noted that much of the data discussed in this section may fall outside the strict definition of public sector information. The train operating companies are private, while Network Rail, as a statutory corporation, operates the physical rail infrastructure. This means that the status of data relating to privately operated trains running on a quasi-public network data is unclear. Given, however, that the rail industry receives billions of pounds of government subsidy annually, it could be argued that there is a public interest in all data relating to the rail industry being treated as public sector information. In theory, therefore, the government could make provision of information by the train operating companies as if it were public sector information a condition of operating a franchise on the network. For the purposes of this analysis we treat all information discussed as public sector information. We consider that to omit this information would be to ignore a vital part of the picture. One company operating in this space is Placr, a start-up focussed on location and transport data, currently being incubated by the Open Data Institute. Its website states: "Our chief objective since foundation has been the creation of a single UK source of transport information by unification of timetable, live departure and disruption information for bus, rail, metro and ferry services."240 ## Barriers Placr has identified a range of both opportunities and barriers. Industry data streams that they would like access to include:  short term cancellations;  rolling stock formation, i.e. how many carriages does a train contain; and  cycle policies. In addition, data that is made available by the Association of Trade Operating Companies (ATOC) under the Rail Settlement Plan incurs a charge for use, including a license fee of £5,005 annually for data supplied daily or weekly, and an annual quoted charge of up to £27,430 for daily fares, timetable and routeing guide data.241 This is sufficiently high to act as a potential disincentive for a start-up that has yet to generate a reliable revenue stream. ATOC does provide trial data for proof of concept and test purposes, but this is not necessarily up to date and therefore may be inappropriate to be used for commercial purposes. Licensing conditions for rail data are also said by some stakeholders to be confusing for developers and have been used to shut down services. For example, in 2009, in following a dispute between Kizoom and ATOC, the latter withdrew Kizoom's licence to use to use train department information for its free MyRailLite app242 ## Disruptive Innovation In Rail Travel - Placr And Other Providers Developers May Therefore Face Some Challenges In Accessing Data In The Rail Industry. In terms of the opportunity, Placr identify three areas in which they believe increased availability of data can disrupt the rail industry and improve the experience of passengers. ## Providing Live Service Updates Increased availability of data has the potential to allow passengers current information on the status of rail services. Some of this information is already available through the National Rail website, TOC websites and mobile apps, which provides live departure boards and allows users to track a train's progress throughout its journey. ## National Rail Enquiries Source: http://nationalrail.co.uk/times_fares/ldb/ There are other, potentially more interesting ways of tracking service quality. For example, the train lateness map available at transportapi.com represents 'lateness' as coloured bubbles on a map, allowing users to intuitively see where the delays are and plan their journey using the best-performing route. ## Disruptive Innovation In Rail Travel - Placr And Other Providers Train Lateness Map Source: www.scribd.com/doc/123365071/Friday-Lunchtime-Lectures-at-the-ODI-How-can-Open-Data-Revolutionise-your-Rail- Travel By presenting the data in innovative formats, service users are able to interact with it in new ways and gain additional insight into the performance of travel services and the best way to complete their journey. Travel becomes more intuitive and users gain enhanced understanding of the travel options at their disposal, which should translate into faster and more efficient journeys. ## Generating Financial Savings For Passengers It is hoped that fare data will soon be made open. This data, and the innovative services that arise from it, is likely to be of benefit to passengers. Part of the potential value of this data to passengers has been demonstrated by the example of TfL, which now allows holders of a registered Oyster Card to view their journeys online, and also offers to send monthly statements detailing all journeys and credit top-ups during the period. This gives users the ability to track their expenditure patterns on public transport, and also allows them to identify any journeys where they believe they have been wrongly charged and apply for a refund. The data is therefore of clear benefit to users. New and potentially disruptive services may also be built on this data. An example of using data to generate savings for travellers is Tickety Split, a service run by Money Saving Expert. This service is based on the insight that buying separate tickets for constituent parts of a journey is often cheaper than buying one ticket. Although the journey may take longer and require changing trains, it may be that the traveller values the financial saving more highly than the opportunity cost of additional time spent on the journey. Train operating companies do not generally offer their customers this choice, and searching manually for the best split ticket combinations can be cumbersome. Tickety Split searches available fare data to calculate the cheapest combination. In the example below, a ticket from London to Leeds costs £97, but this can be reduced by £13.30 to £83.70 if intermediate tickets are bought from London to Grantham and from Grantham to Leeds. ## Disruptive Innovation In Rail Travel - Placr And Other Providers Tickety Split Source: http://splitticket.moneysavingexpert.com/ Information on the impact of fare-splitting on revenues is not publically available.243 It is, however, possible to roughly estimate the scale of the savings that might be achievable through this technique, bas the followin ed on g:  franchised passenger revenue in 2011/12 was £7.229 billion;  around 75 per cent of this revenue was generated by ordinary fares (assuming that season ticket holders are unable to secure savings through ticket splitting); and  assuming an average saving through ticket splitting of 13 per cent. Based on these assumptions, passengers could save an estimated £705 million per year through ticket splitting. The full extent of these estimated potential savings are unlikely to be realised, due to varying levels of awareness and adoption among passengers. Even if only 25 per cent of passengers were to take advantage of split ticketing, this would still equate to **an estimated £176 million saving per year**. This indicates that increasing accessibility of fare data holds large potential benefits both for individual passengers and for the travelling public overall. In addition to the financial gains to passengers, this example also demonstrates the ways on which data can be used to empower consumers. In so doing it is likely to induce train operating companies to run more efficient, consumer-focussed operations and to offer more competitive fare pricing. Future releases of data could offer the potential for additional innovative services which would increase potential savings to passengers. For example, the data from a smart ticketing system such as Oyster could be linked to real time data on train movements to provide a service whereby automatic refund claims are filed on behalf of passengers when their trains are delayed. This could have a genuinely disruptive effect on the industry, forcing train operating companies to focus on delivering a reliable service, as a poor level of service would have a direct impact on revenues. Were such a service to be developed, it would depend on access to data that can be used to monitor reliability. ## Creating Independent Streams Of Data About Rail Network Performance Many of the benefits to users discussed above will depend on data that can provide an independent view of the performance of the railways. For example, Tube Radar (based on Open Street Maps) provides a view of performance (time intervals between trains) across the network, as compared to normal performance. Placr also cite the example of being asked by the press to offer a view on levels of service during a recent strike, in ## Disruptive Innovation In Rail Travel - Placr And Other Providers the face of conflicting reports from TfL and the unions. ## Tube Radar Source: http://tube-radar.com/ One source of this data is smartphones carried by passengers, which can be used to monitor the progress, frequency, acceleration/deceleration and other details regarding train operations. By crowd sourcing this data, an additional window on the performance of the rail network is opened up, increasing pressure on train operating companies to improve standards and provide a high quality service to their customers. ## Conclusion Placr and other start-ups operating in this space offer numerous ideas for products and services that could collectively transform the experience of rail travel in the UK, by empowering passengers and enabling them to hold rail operating companies to account. As average rail fares rise year on year, with many users perceiving rail travel as offering poor value for money,244 data offers a mechanism ensuring that service users and taxpayers receive value for money from train operators. Some of the data required to drive this transformation remains either unavailable or subject to restrictive pricing and licensing conditions, although there are signs that this situation may gradually be changing. There is demonstrable value to be generated from releasing this data, both in terms of financial savings to users, convenience in journey planning, and in driving accountability (and from thence efficiency) in the rail industry. While not strictly public sector information, given the level of taxpayer contribution to the rail industry and its status as infrastructure of national importance, there is a clear responsibility for government to ensure that the industry operates in an open and accountable manner. This seems likely to be an area in which increasing the openness of data will generate rapid and measurable returns to rail service users, taxpayers and the wider economy. Source: much of the content of this section is derived from a session at the ODI, "How can open data revolutionise your rail travel?" (01/02/2013). Slides available at http://www.scribd.com/doc/123365071/Friday-Lunchtime-Lectures-at-the-ODI-How-can-Open- Data-Revolutionise-your-Rail-Travel ## Syndicated Feeds Available To Developers Through The Tfl Website Syndicated Feeds Available To Developers Through The Tfl Website The full list of syndicated feeds offered by TfL is included below. TfL state "before we give permission to use any feeds, we need to know how they will be used, where they will be used and how many people are likely to view them." Gaining access to these feeds requires:  Providing personal and/or company contact details  Providing information on intended use, target audience and estimated audience numbers  Agreeing to the terms and conditions The full list of feeds available is provided below (correct as of January 2013).  Live traffic camera images v2  Live bus arrivals API (instant)  Source London Charge Point data dictionary  Journey Planner API Beta  Tube station accessibility data  Rolling origin and destination survey  River services timetable  Tube departure boards, line and station status  Journey Planner Timetables  Coach Parking sites/timetables  Licensed private hire operators - Find-a-ride  Pier locations  Bus routes  Tube - this weekend  Station facilities  Live bus arrivals API (stream)  Live Roadside Message Signs v2  Source London Charge Point Location Data  Barclays Cycle Hire availability  London Underground passenger counts  Public transport accessibility levels  Barclays Cycle Hire statistics  Oyster card journey information  Live Traffic Disruptions  Dial a Ride statistics  Station locations  Oyster Ticket Stop locations  Bus stop locations  Tube - this weekend v2 Source: www.tfl.gov.uk/businessandpartners/syndication/16492.aspx ## Dft Value Of Working Time Per Person (£ Per Hour) | Vehicle occupant | Market price (2010 | |--------------------------------|-----------------------| | prices and values) | | | Market price (2012 prices | | | and values - Deloitte | | | analysis) | | | Car driver | 33.74 | | 35.4 | | | Car passenger | 24.17 | | 25.4 | | | LGV (driver or passenger) | 13 | | 13.7 | | | OGV (driver or passenger) | 13 | | 13.7 | | | PSV driver | 13 | | 13.7 | | | PSV passenger | 25.81 | | 27.1 | | | Taxi driver | 12.47 | | 13.1 | | | Taxi/minicab passenger | 57.06 | | 59.9 | | | Rail passenger | 47.18 | | 49.6 | | | Underground passenger | 45.9 | | 48.2 | | | Walker | 37.83 | | 39.7 | | | Cyclist | 21.7 | | 22.8 | | | Motorcyclist | 30.53 | | 32.1 | | | Average of all working persons | 34.12 | | 35.8 | | Purpose Market price (2010 prices and values) Market price (2012 prices and values - Deloitte analysis) Commuting 6.46 6.80 Other 5.71 6.00 Source: Department for Transport, 'TAG Unit 3.5.6: Values of Time and Vehicle Operating Costs', October 2012 ## Appendix 7: Further Case Studies This Appendix Contains Further Details On The Healthcare And Public Sector Case Studies Outlined In Chapter 5. The Healthcare And Life Science Sector This section considers examples of how the release of public sector information datasets relating to the healthcare sector can have a beneficial impact. This may be in terms of identifying new efficiencies in the NHS, or it may be in improving patient outcomes, which may itself result in cost savings either directly to the health service or to the wider economy. ## Mastodon C - Identifying Nhs Prescription Savings From Big Data Case study summary By using data on prescribing practice across England, variations in spending on different classes of drugs can be identified. It is then possible to calculate the potential savings to be achieved by moving from prescribing branded to generic drugs. Size of the prize  For statins alone, the NHS could save around **£200 million per year** by reducing prescriptions of branded in favour of generic versions.  When extended to all classes of drugs, the total potential savings could amount to **£1.4 billion per year.** NHS prescribing data is released at GP level through the Health and Social Care Information Centre. These are large datasets, with around 10 million lines of data released every month - an example of 'big data.' Mastodon C, a start-up company currently being incubated by the Open Data Institute and describing itself as an 'agile big data specialist', saw an opportunity in this data to identify potential efficiency savings for the NHS.245 Prior to this analysis there was already an awareness in the sector of the possibility of achieving savings through changes to prescribing practices. The British Medical Journal has published research indicating that the potential savings to the NHS of switching from branded to cheaper (but in many cases equally effective) generic drugs could total £1.4 billion246. There have been previous and ongoing attempts to achieve savings through increasing prescription of generic drugs, notably through the work of prescribing advisors. However, these attempts have hitherto met with limited success. GPs may habitually prescribe a branded drug without considering the cost implications; equally, patients may be accustomed to a branded version and feel that a generic is an inferior substitute. For these and other reasons, it has proved difficult to bring about significant change in behaviour. Mastodon C, working with Open Healthcare UK, wanted to try a new approach to raising awareness. They used big data to demonstrate regional differences in the cost of prescriptions, hoping thereby to drive change by allowing GPs and PCTs to compare their performance to those of GP practices and PCTs across England. By highlighting seemingly unwarranted variation, GPs and PCTs could identify where they were underperforming compared to their peers in terms of keeping prescribing costs as low as possible. The team chose statins as the focus of their project, because there is widespread agreement that the generic version is in most instances as effective as the branded versions (based on the guidelines provided by NICE). The price difference is also significant: £1.30 for a generic version as opposed to £20 or more for many branded statins, as shown in the Figure A7.1. Source: www.scribd.com/doc/122981341/Friday-Lunchtime-Lectures-at-The-ODI-Big-Data-Comes-to-the-NHS The team's decision highlights an important point: users of big data and public sector information need to approach the analysis responsibly and in an informed way. The Mastodon C team maintains that data itself is not a silver bullet to understanding a problem. The team needed to fully understand the clinical guidance attached to each drug, so as to avoid, for example, recommending savings where there were strong clinical reasons for choosing a branded drug rather than the generic version. In their own words, "good domain knowledge usually beats supersmart algorithms." In this case, while the data itself was crucial, the insights became possible only through working closely with GPs and other healthcare professionals. This issue of responsible use of the data also applied to the level of granularity of the analysis. Although the data would allow comparisons to be made at a GP practice level, the Mastodon C team opted to map their findings at a PCT/CCG248 level. This decision arose out of concerns that presenting the results at a GP level could lead to distortions in the data involving very small practices, as these might handle only a few relevant cases. This could mean that their prescribing costs cost appear exceptionally high. The team were concerned that their work could lead to a GP practice being unjustly labelled 'the worst in Britain' in the media. This might then create a backlash and build resistance to future analyses and releases of data among the healthcare profession. By comparing prescribing practice across England, the Mastodon C team identified around £200 million worth of potential savings. These could be achieved if the behaviour of the GPs with the highest level of branded prescriptions was brought into line with the behaviour of the GPs prescribing the highest level of generic versions. The mapping of results by PCT revealed notable differences between PCTs across England. Source: http://prescribinganalytics.com/ The team also identified some potentially effective levers of influence over prescribing practice. Cambridge PCT had very low prescribing costs for statins: the team found that this was because the PCT had taken a very strong line on prescribing the generic version, and this had changed behaviour at the GP practice level. The achievement of considerable cost savings in Cambridgeshire demonstrates that action at the PCT level may be the most effective approach to achieving savings through changes in GP prescribing behaviour. It should be noted that work in this field is already undertaken by the government. For example, the NHS Prescription Services, part of the NHS Business Services Authority, provides the NHS with a range of drug, financial and prescribing information. The IT tools allow NHS organisations to look at prescribing patterns for a range of medicines right down to individual GP level, so they can target work with practices to help them improve. At a local level, NHS organisations have developed systems to incentivise prescribers to prescribe more cost effectively. Many local NHS organisations have also invested in software which prompts prescribers on the most cost effective prescribing choice.249 These tools have helped the NHS to achieve one of the highest rates of generic prescribing in Europe, with the overall prescribed generic rate calculated at 83 per cent in 2011.250 This highlights that in some instances where data is released, there may have been previous and ongoing efforts by public sector organisations to use this data to develop insights. The work of private sector organisations may be able to build on this work and enhance the value derived from the data, but this is likely to be most effective, and avoid duplication, where communications between public and private sector organisations are strong. In summary, the work of Mastodon C in this area demonstrates a number of key insights into the value that may be derived from making more and better use of public sector information in the health sector. These insights include:  it is not generally enough to have access to data - also required is the contextual and sector knowledge to use it intelligently and responsibly;  large efficiency savings may be hidden in areas of regular practice. There are likely to be other areas both in the NHS and the wider public sector where changes in behaviour could generate significant financial savings without compromising outcomes;  the insights from data can help drive change in areas that previously resisted policy solutions. For example, in this case a key insight was that change in GP prescribing behaviour might be best driven from the PCT level;  there is a need for communication between public and private sector organisations to ensure that where data is released, the analysis undertaken is complementary and builds on previous and ongoing efforts to use the data to gain insights. ## A Patient Database For The Nhs - The Challenges To Extracting Value From Large Datasets Case study summary: A central NHS patient database could offer significant savings to the NHS as well as improving standards of care and the patient experience. However, there are significant technical, privacy and cultural hurdles to overcome if this is to be made a reality. This case illustrates both how attractive the prize of harnessing the power of large public sector information datasets can be, but also the difficulties these can present. Size of the prize: Difficult to estimate, but if the system is delivered as planned the savings are likely to be billions of pounds. An initial illustrative estimate identified **£4.4 billion of potential savings**, although these are not all directly related to the patient database. The idea of a central NHS patient database has existed for some time, but previous attempts have encountered a variety of issues owing to the challenges of building a system with the requisite capabilities and scale. However, early in 2013 the Health Secretary, Jeremy Hunt, launched a plan to store patient records in a cloud-based system by 2018, with the ultimate goal of transitioning towards a 'paperless NHS'.251 While the details have not been fully established, the broad outline of the scheme is that each patient would have an individual electronic health record which would be accessible from any point within the NHS - whether by the patient's GP during a consultation, by a hospital consultant preparing to carry out an operation, or an ambulance crew responding to an emergency call-out. Outwardly at least these proposals have much to recommend them, and appear to be a good example of an opportunity to achieve increased efficiency and improved outcomes through increased exploitation of public sector information. Patient records offer a rich source of data with the potential to both improve the standard of care received by the patient, and to enhance the efficiency and effectiveness of the NHS. However, despite this promise, some have viewed the proposals through the lens of past failures of NHS database projects, as well as privacy and confidentiality concerns. Commentators have also raised concerns that this database may threaten patient confidentiality. In part this is simply a technical issue: a cloud-based, highly networked system will need to be rendered secure against unwanted incursions by non-authorised agents, given that much of the information held will be of a highly personal and sensitive nature. If the information is released, either to approved users as is currently the case with the National Pupil Database, there will be additional concerns regarding confidentiality252. As discussed below, it may be possible to anonymise datasets to an extent that the level of risk of an individual record becoming known is acceptable. However, healthcare information may pose particular challenges. In the case of very rare diseases where, for example, there are only one or two cases per GP practice area - it may be impossible to effectively anonymise the data. This indicates that the approach to protecting patient privacy will need to be rigorous and adapted to the constraints of the data. In his announcement the Health Secretary acknowledged these concerns, but maintained that the Government had learnt from past failures and would not be adopting a top-down approach in an attempt to construct a monolithic central IT infrastructure. Instead of a centralised approach akin to constructing an aircraft carrier, he argued that "most systems won't necessarily need to be replaced, just updated or adapted so they can talk with each other. A thousand different local solutions linking together using common standards."253 The announcement argued that this would deliver considerable financial benefits, based on a report which identified potential savings amounting to £4.4 billion254. It should be noted that these benefits were calculated from a wide range of changes which were estimated to deliver a range of incremental benefits. In addition, the Health Secretary's announcement identified broader welfare benefits that include improved outcomes, ultimately meaning lives saved, as well as an improved user experience of engaging with the healthcare system at all levels. For example, if staff in Accident & Emergency have details of a patient's health history and current medication, they should be able to respond more appropriately to the emergency, with potentially life-saving consequences. Equally, if clinicians have access to up to date health records for all patients this means that patients would not have to verbally repeat their medical history at each stage of the process. This is likely to save time and ensure that clinicians have access to accurate records. There is some international precedent for a centralised patient database. The most notable example is Denmark, which currently makes hospital records available to patients online, and which is in the process of making GP records available. However, Denmark has a population numbering just ten per cent of the population of England alone and a population that is, prima facie, more homogenous, meaning that a patient database in the UK will need to operate on a much larger scale. This makes it a more challenging technical and logistical proposition. This case throws into sharp relief the tensions around using large datasets concerning individuals. On the one hand the potential for a range of benefits, from efficiency savings to enhanced user convenience and new insights, is extremely tempting. On the other hand there are valid concerns around privacy and confidentiality and the potential misuse of sensitive information. Effectively harnessing the potential of data to transform the NHS, as well as other areas of the public sector, will require these tensions to be reconciled in a manner which satisfies security and privacy concerns while nonetheless permitting effective use of the data. ## Publication Of Mortality Rates Following Cardiac Surgery Case study summary: Publishing data on mortality rates following adult cardiac surgery appears to be associated with a decline in mortality. There are various theories as to why this is the case, including competitiveness among surgeons which leads to a rise in performance, increased awareness among healthcare professionals, and public pressure for higher standards. However, there are also concerns that the apparent decline in mortality may reflect 'gaming' of the mortality data. Size of the prize: A decline in mortality rates is itself desirable. The economic value depends on the value attributed to a statistical life. Taking a median value from a range of recent studies, the value of lives saved among those undergoing adult coronary artery surgery in NHS centres in north-west England in 2005 was around £55 million. This suggests that the total value of lives saved per annum could **exceed £400 million** for England and Wales, if similar benefits were observed in all regions. Since 2005, data on mortality rates following adult cardiac surgery has been made publically available in the UK. Subsequently, studies have attempted to gauge the impact that the release of this data has had, both on outcomes of surgery and the willingness of surgeons to accept high-risk cases. There is a reasonable volume of evidence suggesting that publication of this data is associated with a decline in mortality. A 2007 research paper published in the journal *Heart* found that over an eight year period (from 1997 to 2005) observed mortality decreased from 2.4 per cent to 1.8 per cent. The authors argue that while data was not made publically available over the majority of the period covered by the study, over this period it became clear to surgeons that public release of the data was a matter of time, following the Bristol Public Enquiry in 2001.255 The findings of the paper, moreover, appear to be corroborated by other studies, including a study which found a 41 per cent reduction in risk-adjusted mortality rates during the first four years following publication of outcomes data.256 An improvement in clinical outcomes that leads to an increase in lives saved is of itself desirable from a wider social welfare perspective. The economic value attributed to this decline in mortality from surgery depends on the value of a statistical life, which varies widely. To take an example, drawing on a survey of recent studies257 produces a median value for the total value of a statistical lifetime of around £3 million. Using this value means that the decline in mortality can be valued at around £55 million, just for north-west England in 2005. Assuming similar benefits were experienced across England and Wales, the total value of lives saved in 2005 alone is estimated to have exceeded £400 million, as compared with 1997 mortality rates. If similar benefits can be realised in other areas of clinical practice, the annual benefits in terms of lives saved are likely to be valued in terms of billions of pounds. There have, however, been fears that public disclosure of outcomes could trigger risk-averse behaviour among surgeons, meaning that they would not accept cases where there was an increased risk of mortality.258 There is little evidence that this has in fact occurred, with the *Heart* study finding that the number of patients classified as high-risk actually increased over the period. However, a response to the article argued that surgeons have a powerful incentive to 'game' the system by over-assessing the risk profile of patients, thereby making their own performance appear stronger.259 There is some evidence that similar effects may have occurred elsewhere, with one survey cited in the *Heart* study finding that 79 per cent of New York cardiologists reported that publication of mortality statistics had influenced their decision about whether to perform angioplasty on individual patients.260 These concerns notwithstanding, the evidence seems to indicate that transparency can be a powerful driver of accountability and improved standards in the healthcare sector. As the authors of the *Heart* paper suggest, "if public disclosure can drive data collection and analysis, but does not create significant risk‐averse behaviour, its introduction may be beneficial in other areas of medicine."261 Releasing data on standards, where appropriate and subject to the appropriate monitoring mechanisms, therefore appears to be an 'easy win' for the use of public sector information to drive tangible economic and welfare benefits. ## The Public Sector One of the most interesting areas for the improved exploitation of public sector information is greater sharing of and access to information within the public sector itself. By removing barriers to the flow of information between public sector bodies - either because potential users are unaware of what information is available, or because there are physical or legal constraints on the sharing of this information - policy formation could be based on much richer and more complete information. All things being equal, this should lead to better informed and therefore more effective policies. A report by the Administrative Data Taskforce published in December 2012 highlighted a number of areas of research and policy where sharing of data could generate new insights and lead to improved policy outcomes. These are summarised below. | Area of research and policy | |------------------------------------------------------------------------| | Social mobility | | Linking data on education, training, employment, unemployment, | | income and benefits | | Linking data on education, health, employment, income and wealth | | Causal pathways over the life | | course | | Support for the elderly | | Comparative analysis of access to and provision of social care support | | for the elderly | | Poverty | | Linking data on housing conditions, health, incomes and benefits | | Social care for children | | Linking indicators of parental employment, social background and | | childcare | | | | Area of research and policy | |---------------------------------------------------------------| | Offence and re-offence | | Linking data on offending and re-offending behaviour, income, | | benefits, health and mental health | Source: *The UK Administrative Data Research Network: Improving Access for Research and Policy* (December 2012) This list serves as an indication of the many policy areas which could benefit from increased sharing of information between government departments. Given the level of government spending, and the wider economic significance of these policy areas, if sharing leads to enhancement of policy in any one of these areas the economic and broader welfare impacts should be large. Below is an example of one area in which progress is already being made in the sharing of information. Announced in May 2012, the Social Mobility Transparency Board is tasked with pursuing "smarter use of data between the Department for Education, the Department for Business, Innovation and Skills (BIS) and HM Revenue and Customs."262 The role of the Board is to improve sharing between key information holders and external researchers, building connections and establishing procedures to ease access to data for research. The value of public sector information to social mobility researchers From conversations with key stakeholders it is clear that public sector information is crucial for researchers focussing on social mobility. Hitherto, most work in this field has been built upon birth cohort studies which follow a group of subjects and update key indicators every ten years. Data held by public sector bodies holds the promise of far richer and more robust insights into key indicators of social mobility, potentially extending over the entire population. For researchers to use this data effectively, however, it needs to be shared and linked across the various information holders. The organisations so far identified as holding the information most useful to researchers in this field are:  the Department for Education;  the Higher Education Statistics Agency;  the Department of Work and Pensions; and  Her Majesty's Revenue and Customs. This being a relatively recent initiative, tangible benefits are still emerging. However, stakeholders point to a number of incremental benefits. There is steady improvement in the level of understanding of the drivers of social mobility, especially how higher education works as a driver of social mobility and understanding of the factors driving participation in higher education. Insights into the role of socio-economic group, school type, family income and other factors in influencing participation in higher education continue to deepen as a result of increasing access to data. ## Opportunities In The Local Public Sector The local public sector spends around £70 billion per year and employs approximately two million people, providing many of the essential services across the UK. It therefore seems reasonable to expect that there will be many opportunities to realise efficiencies and improved outcomes through the more effective exploitation and sharing of information. The local public sector also poses unique challenges owing to its great diversity. It includes county and district councils (in two-tier 'shires'), unitary authorities, London and metropolitan boroughs, and *sui generis* authorities such as the City of London and Isles of Scilly. These administer a diverse range of services under a variety of delivery models. Any changes in the use of public sector information at a local level is therefore likely to be incremental and involve, at least initially, either individual local authorities or small groups working together. This diversity, however, is also a significant strength, since it makes local authorities laboratories for the use and re-use of information. In the course of our research Deloitte has encountered many examples of local authorities exploiting information in ways that are often highly innovative, with lessons not only for other local authorities but also for central government departments and other public sector bodies. The individual efficiency gains and improvements in outcomes may in many cases be small, but collectively they represent a quiet revolution in the delivery of services at a local level. Should these experiments grow in number and the best examples become widely adopted, the national impact could be significant. There are also numerous other examples of local authorities using information in innovative ways, including:  Lambeth Borough Council have set up a site called "Lambeth in Numbers" to help inform their Food Strategy work. It brings together data from various sources including central and local government on a map.  Bristol City Council Air Quality data  Trafford Council - Breakthrough Fund on stimulating data sets  Hampshire County Council work on land supply The example below illustrates an example of improvements in policy formation and delivery through information sharing between local authorities and other public bodies. ## An Example Of Data Sharing At A Local Level - Families With Complex Needs Examples of data sharing between local councils and other public bodies are proliferating across the UK. These are often responses to the twin pressures of deep funding cuts and intractable problems involving multiple agencies. An example of this sort of problem is the case of families with complex needs, often referred to in the press as 'troubled families'. These families may combine issues such as mental health problems, children out of school, and long term worklessness and benefit dependency, meaning that they fall within the remit of multiple public sector bodies including social services, the Police, and the local and national welfare services. These services are estimated to cost around £75,000 per family per year.263 Increased coordination between local councils and other local partners may prove both more cost efficient and more effective in resolving the problems faced by such families. The councils of Greater Manchester, Leicestershire and Bradford are working together to improve information sharing and management in this area. The project aims to develop a single toolkit for information sharing, combining existing guidance and approaches. This is intended to be applicable to both the councils and the agencies working with families with complex needs. In addition the project is intended to lay the foundations for a culture more conducive to information sharing, addressing issues such as different professional cultures of sharing, lack of training and expertise, and differing interpretations of legislation. In practice, the steps needed to achieve this can appear prosaic but are nonetheless potentially powerful enablers of an environment in which information can more easily be shared within and between organisations. As the project is still ongoing it is too early to judge its effects, whether in terms of reduced costs or ## An Example Of Data Sharing At A Local Level - Families With Complex Needs improved outcomes. Nonetheless, this appears to be a positive example of the potential of greater sharing and exploitation of data between councils and other public sector bodies in response to a policy problem which has proved unresponsive to a siloed approach. The Local Government Transparency Survey The Local Government Association (LGA) conducted a survey in September 2012264 covering the publication of open data, the impact of open data on councils and how data is used locally. 37 per cent of local authorities responded to the survey. In their responses they identified the ways in which they are using open data, which give an indication of the impact it is having. A selection of these responses is included below.  engaging with community groups to create API makers and ways to make data useful;  using their own open data and that of other councils to gain insight into the characteristics of people in the area and, accordingly, their needs in relation to the services the council currently and intends to provide or commission;  planning to utilise the Police, NHS, public health and other public sector partners' open data to produce a single view of the borough;  seeing a reduction in FOI requests;  using data to help customers 'self-serve' online in their reporting e.g. fly tipping, tree issues, damage to street furniture; and  undertaking service reviews and improvement - benchmarking, performance, spend, organisational structures and pay scales. These responses indicate the diversity of ways in which local authorities are making use of public sector information from a wide range of sources, in order to achieve efficiency savings and improve service delivery and the ways in which citizens interact with local government. That said, the survey also identified barriers to local authority use of data. The barriers most commonly cited by respondents were:  lack of resources to prepare and publish data (69 per cent);  issues around data protection and the release of personal information (32 per cent);  organisational and cultural barriers (30 per cent);  technical barriers (30 per cent); and  lack of skills to prepare and publish data (27 per cent). Respondents also cited a range of other barriers, including:  a lack of a definitive list to help them know what information should be published;  a lack of clear guidance on data standards; and  a lack of mature offerings from suppliers to provide open data as part of standard operations. Given how diverse the landscape is, in terms of both the extent to which local authorities are using and releasing public sector information, the ways in which they are using it, and the barriers they are facing, it makes sense to build on current efforts to share best practice across the local public sector. This would provide a way to capitalise on local authorities as 'laboratories' for the use of information. Where one local authority achieves efficiency savings or improves services, this may be applicable to many other local authorities and in this way the benefits can be scaled up. It would seem sensible to have a discussion about how and through what channels this can be achieved. The LGA has already begun some work in this area, along with DCLG, through initiatives such as the Local E-Government Standards Board (LEGSB) and the Local Public Data Panel. There appears to be support for such initiatives from local authorities themselves: in the survey, around two thirds were in favour of the LGA providing a framework for publishing data through by way of a transparency strategy, and indicated that they would like to see case studies and guidance on how to publish open data. Summary of opportunities in the local public sector The examples given above indicate some of the ways in which the local public sector is beginning to exploit information to deliver both efficiencies and improved outcomes for policies and services, leading to welfare gains for citizens. These examples are likely to be a leading edge for significantly expanded future benefits, if the current trend of increasing sharing and exploitation of data continues. The report by ConsultingWhere and ACIL Tasman on the use of geospatial information in the local public sector identified the following benefits for 2009:  GDP was £323m higher than it would otherwise have been (an increase of 0.02 per cent);  government revenue from taxation was £44m higher than it would otherwise have been;  the delivery of goods and services by local public service providers was £232m higher than it would otherwise have been; and  an increase in labour productivity equivalent to 1,500 full time staff across England and Wales, owing to the effects of improved citizen and business contact with local service providers.265 These benefits have arisen from the use of just one type of information (geospatial) by some, but not all local authorities. Given that the local public sector collectively accounts for expenditure of some £70 billion per year266, and is often the primary point of contact for citizens and businesses dealing with issues as diverse as education, social services and planning permission, the potential for further gains - both to local public sector efficiency and the wider economy - is likely to be significant. As this section has demonstrated, the strength of the local public sector is its diversity, making it a laboratory for the use of information. In order to facilitate the potential of information release and sharing, it is important to ensure that the necessary frameworks (legal, regulatory and in terms of culture) are in place, and that local authorities have the freedom to experiment while also receiving suitable guidance. Under these conditions the potential for public sector information to transform local public service delivery and efficiency is likely to be significant. ## Appendix 8: Government Officials Informal Consultation Consultation Questions Background Deloitte has been engaged by the Data Strategy Board to conduct a market assessment of Public Sector Information (PSI). The results of study will feed into the independent Shakespeare Review which is examining ways to widen access to Public Sector Information (PSI) and consider new and innovative opportunities for it. Survey 1. Please could you provide your name; organisation; job title; role in the collection/dissemination of PSI in your organisation; and your contact details (telephone and email address)? 2. Approximately what proportion of the data that your organisation collects is made available to the general public (either freely or for a fee)?. *Choose one option only.* a. None b. Between 0 and 25% c. Between 26 and 50% d. Between 51 and 75% e. More than 75% f. All data is made available g. Don't know 3. Approximately what proportion of the data made available to the general public by your organisation is at no cost? *Choose one option only.* a. 100% is free b. Between 75 and 99% is free c. Between 50 and 74% is free d. Between 25 and 49% is free e. Less than 25% is free f. None is free g. Don't know 4. How does your organisation make data available to the general public? *Indicate all that apply.* a. Own website b. On data.gov.uk c. On another data portal (please specify) d. Upon receipt of special requests e. Other (please specify) 5. Approximately what proportion of your organisation's staff are directly involved in the collection, processing and dissemination of data? *Choose one option only.* a. Less than 5% b. Between 5 and 10% c. Between 11 and 25% d. More than 25% e. Don't know 6. Approximately what proportion of your organisation's budget is spent on the collection, processing and dissemination of data? *Choose one option only.* a. Less than 5% b. Between 5 and 10% c. Between 11 and 25% d. More than 25% e. Don't know 7. Would you say that the data collected by the department is primarily used by: Choose one option only. a. Your own organisation b. Other Government organisations and agencies c. Third parties - please specify d. Don't know who the main users / re-users of data are 8. What sort of requests do you receive from the general public regarding open data? Indicate all that apply. a. Requests for other data that your organisation collects to be made public b. Requests for your organisation to provide new data that is currently not collected c. Requests for clarification of various issues around datasets or to improve the quality of datasets d. Requests to correct different aspects of datasets e. Requests for the data currently available publicly to be made available in different formats f. Other - please specify 9. Are you able to give an indication of the types of users downloading your organisation's datasets? Indicate all that apply and provide an approximation of the proportion of users they represent. a. Other Government organisations and agencies b. Other public service providers c. Not-for profit organisations including researchers d. For-profit private sector organisations e. Individuals f. Other - please specify 10. Can you given indication of how the data is used and re-used? 11. Does your organisation plan to make available more data to the general public in the near future (within twelve months)? a. Yes b. No c. Don't know 12. If the above answer is yes, how much more data does your organisation plan to make available to the general public? a. Less than 25% b. Between 26 and 50% c. Between 51 and 75% d. More than 75% e. Don't know 13. What are the key challenges you see in making more data available to the general public? ## Consultation Responses The following organisations responded to the survey:  HMRC  Home Office  Defra  DH  DH Statistics Function  DH MHRA  FCO  DCLG  MoD  MoJ  CO  BIS The following table shows the responses to each questions, by percentage of respondents selecting each option. Note that in some cases it was possible to select more than one response, meaning that the sum of responses for these questions exceeds the total number of respondents. | Question | a | b | c | d | e | f | |-------------|------|------|------|------|------|------| | 1 | | | | | | | | n/a | n/a | n/a | n/a | n/a | n/a | n/a | | 2 | | | | | | | | 8% | 25% | 0% | 0% | 17% | 8% | 33% | | 3 | | | | | | | | 42% | 42% | 0% | 0% | 0% | 0% | 8% | | 4 | | | | | | | | 92% | 83% | 67% | 75% | 33% | 0% | 0% | | 5 | | | | | | | | 33% | 0% | 0% | 8% | 50% | 0% | 0% | | 6 | | | | | | | | 42% | 0% | 0% | 0% | 50% | 0% | 0% | | 7 | | | | | | | | 50% | 8% | 17% | 33% | 0% | 0% | 0% | | 8 | | | | | | | | 67% | 50% | 75% | 33% | 58% | 8% | 0% | | 9 | | | | | | | | 50% | 42% | 50% | 42% | 42% | 33% | 0% | | 10 | | | | | | | | n/a | n/a | n/a | n/a | n/a | n/a | n/a | | 11 | | | | | | | | 83% | 8% | 0% | 0% | 0% | 0% | 0% | | 12 | | | | | | | | 42% | 8% | 0% | 8% | 25% | 0% | 0% | | Question | a | b | c | d | e | f | |-------------|------|------|------|------|------|------| | 13 | | | | | | | | n/a | n/a | n/a | n/a | n/a | n/a | n/a | | | | | | | | | ## Appendix 9: Bibliography Academic Papers & Reports ACIL Tasman, 2009. *Spatial Information in the New Zealand Economy*. Wellington: Land Information New Zealand. Administrative Data Taskforce, 2012. The UK Administrative Data Network: Improving Access for Research and Policy. London: Economic and Social Research Council. Association of Greater Manchester Authorities. Helping to improve information sharing and management: a national exemplar project. Capgemini Consulting, 2013. The Open Data Economy: Unlocking Economic Value by Opening Government and Public Data. London: Capgemini Consulting. Cebr, 2012. *Data equity: unlocking the value of big data*. London: SAS. Cebr, 2012. *The Economic Costs of Gridlock.* London: Cebr. Centre for Technology Policy Research, 2010. *Open Government: some next steps for the UK.* ConsultingWhere and ACIL Tasman, 2010. The Value of Geospatial Information to Local Public Sector Service Delivery in England and Wales. London: Local Government Association. Danish Enterprise and Construction Authority, 2010. *The Value of Danish Address Data.* Copenhagen. Dekkers, M., Polman, F., te Velde, R. and de Vries, M., 2006. Measuring European Public Sector Information Resources. Helm Group of Companies. Deloitte Access Economics, 2012. *The Economic Impact of the "Information Glut"*. London. Deloitte Analytics, 2012. *Open data: driving growth, ingenuity and innovation*. London. Deloitte Consulting and Tech4i2, 2011. *Pricing of Public Sector Information Study.* Department for Transport, 2011. The Economic Case for HS2: The Y Network and London –West Midlands. London: Department for Transport. Department for Transport, 2012. *Road Transport Forecasts 2011*. London: Department for Transport. Department for Transport, 2012. *Values of Time and Vehicle Operating Costs*. London: Department for Transport. Earnst & Young, 2011. Making Energy Efficiency Your Business: understanding the potential of the nondomestic Green Deal. London: Earnst & Young. Elgin, 2013. *A new public-private model for creating a national database of local roadworks* e-skills UK, 2013. *Big Data Analytics: an assessment of demand for labour and skills, 2012-2017*. London: SAS UK. Genovese, E., Roche, S., Caron, C. and Feick, R., 2010. The EcoGeo Cookbook for the assessment of Geographic Information Value. International Journal of Spatial data Infrastructure Research. Goodwin, P., 2004. *The Economic Costs of Road Traffic Congestion*. London: University College London. Graves, A. *The Price of Everything but the Value of Nothing.* Office of Fair Trading presentation. Heseltine, *The Rt Hon the Lord of Thenford CT, 2012. No Stone Unturned in Pursuit of Growth.* HM Government, 2012. *Open Data White Paper: Unleashing the Potential*. London. Houghton, J., 2011. *Costs and Benefits of Data Provision*. Victoria: Centre for Strategic Economic Studies, Victoria University. Huijboom, N. and van der Broek, T., 2011. *Open data: an international comparison of strategies.* European Journal of ePractice. Kalapesi, C., Willersdorf, S. and Zwillenberg, P., 2012. The Connected Kingdom: how the internet is transforming the UK economy. London: Boston Consulting Group, Inc. Kundra, V., 2012. Digital Fuel of the 21st Century: Innovation Through Open Data and the Network Effect. Joan Shorenstein Center on the Press, Politics and Public Society. Lippert, C., 2010. *Public Sector Information Reuse in Denmark.* European Public Sector Information Platform Report No. 20. Local Government Association, 2012. *Local Government Transparency Survey 2012*. London: Local Government Association. Mandela, A., 2009. *PSI re-use: UK perspectives*. Locus Association. Mayo, E. and Steinberg, T., 2007. The Power of Information: An Independent Review. McKinsey Global Institute, 2011. *Big data: the next frontier for innovation, competition, and productivity*. McKinsey & Company. National Audit Office, 2012. *Implementing transparency: cross-government review*. London: National Audit Office. National Fraud Authority, 2012. *Annual Fraud Indicator*. London: National Fraud Authority. O'Hara, K., Whitley, E. and Whittal, P., 2011. Avoiding the jigsaw effect: experiences with Ministry of Justice reoffending data. University of Southampton, London School of Economics, and Detica. Office of Fair Trading, 2006. *The Commercial Use of Public Information*. London: Office of Fair Trading. Open Data User Group, 2013. *Further Benefits of an Open National Address Set.* London: Open Data User Group. Oxera, 1999. *The Economic Contribution of Ordnance Survey GB*. Oxford: Oxera. PA Consulting Group, 2007. *Met Office: The Public Weather Service's Contribution to the UK Economy*. London: PA Consulting Group. ## Pira International, 2000. Commercial Exploitation Of Europe'S Public Sector Information Pollock, R., 2011. *Welfare Gains from Opening up Public Sector Information in the UK*. Cambridge: University of Cambridge Pollock, R., Newbury, D. and Bently, L., 2008. Models of Public Sector Information Provision via Trading Funds. Cambridge: University of Cambridge. PriceWaterhouseCoopers LLP, 2010. *Economic Assessment of Spatial Data Pricing and Access*. Canberra: ANZLIC - The Spatial Information Council. PriceWaterhouseCoopers LLP, 2013. A review of the potential benefits from the better use of information and technology in Health and Social Care. London: PriceWaterhouseCoopers LLP. ## Public Data Group. *Business Case*. Roger Tym & Partners, 2003. *The Economic Benefit of the British Geological Survey.* London: Roger Tym & Partners. Rothenberg, J., 2012. Towards a better supply and distribution process for open data: international benchmark. Logica Business Consulting. Stauffacher, D., Hattotuwa, S. and Weekes, B., 2012. The potential and challenges of open data for crisis information management and aid efficiency: a preliminary assessment. ICT4Peace Foundation. The National Archives, 2009. *How we deal with exceptions to marginal cost pricing*. London: The National Archives. The National Archives, 2010. The United Kingdom Report on the Re-use of Public Sector Information 2010: unlocking PSI potential. London: The National Archives. The Office of Public Sector Information, 2011. Information Fair Trader Scheme Report: Ordnance Sur vey. London: The National Archives. The Office of Public Sector Information, 2012. *Information Fair Trader Scheme Report: Land Registry*. London: The National Archives. Transport for London, 2011. *Travel in London, Supplementary Report: London Travel Demand Survey*. London: Transport for London. Transport for London, 2011. *Travel in London: Report 5*. London: Transport for London. Transport for London, 2012. *London Buses Performance: Financial Year 2011/12*. London: Transport for London. Transport for London, 2012. *London Underground Performance Report: Period 4 2012/13*. London: Transport for London. Transport for London, 2012. Syndication Developer Guidelines: Transport for London Data Service Version 2.0. London: Transport for London. Transport for London: London Streets, 2012. *Performance Report: Quarter 1 2012/13*. London: Transport for London. Uhlir, P. F., 2009. The Socioeconomic effects of public sector information on digital networks: towards a better understanding of different access and reuse policies (workshop summary). US National Committee for CODATA, and Board on Research Data and Information. Vickery, G., 2011. *Review of recent studies on PSI re-use and related market developments.* Information Economics. Yiu, C., 2012a. *A Right to Data: Fulfilling the Promise of Open Public Data in the UK*. London: Policy Exchange. Yiu, C., 2012b. *The Big Data Opportunity: Making government fast, smarter and more personal.* London: Policy Exchange. ## Departmental Open Data Strategies Cabinet Office, 2012. *Open Data Strategy*. London: Cabinet Office. Defra, 2012. *Open Data Strategy June 2012 - March 2014.* London: Defra. Department for Business, Innovation & Skills, 2012. *Open Data Strategy 2012-14.* London: Department for Business, Innovation & Skills. Department for Communities & Local Government, 2012. *Open Data Strategy April 2012-April 2014.* London: Department for Communities & Local Government. Department for Culture, Media and Sport, 2012. *Open Data Strategy 2012-15.* London: Department for Culture, Media and Sport. Department for Education, 2012. *Open Data Strategy*. London: Department for Education. Department for International Development, 2012. *Open Data Strategy April 2012 - March 2014.* London: Department for International Development. Department for Transport, 2012. *Open Data Strategy*. London: Department for Transport. Department for Works and Pensions, 2012. *Open Data Strategy*. London: Department for Works and Pensions. Department of Energy and Climate Change, 2012. *DECC's Open Data Strategy*. London: Department of Energy and Climate Change. Department of Health, 2012. The Power of Information: putting all of us in control of the health and care information we need. London: Department of Health. Foreign and Commonwealth Office, 2012. *The FCO's Open Data Strategy*. London: Foreign and Commonwealth Office. HM Revenue & Customs, 2012*. Open Data Strategy*. London: HM Revenue & Customs. HM Treasury, 2012. *Open Data Strategy 2012-2015*. London: HM Treasury. Home Office, 2012. *Open Data Strategy for the Home Office 2012-13*. London: Home Office. Ministry of Defence, 2012. *Open Data Strategy 2012-2014*. London: Ministry of Defence. Ministry of Justice, 2012. *Open Data Strategy 2012-15*. London: Ministry of Justice. ## Other Documents Association of Train Operating Companies, 2012. RSP licence fee and datafeeds charge. Cabinet Office, 2012. *Making open data real: a government summary of responses.* London: Cabinet Office. Department of Business Innovation and Skills, 2012. *Annual Report and Accounts 2011-2012.* London: Department of Business Innovation and Skills. HM Government, 2011. *Making open data real: a public consultation.* London: HM Government. Met Office, 2012. *Annual Report and Accounts 2011/12.* Exeter: Met Office. Open Data User Group, 2012. Open Data User Group response to the consultation on the code of practice for datasets and beta charged licence. London: Open Data User Group. ## Crown Copyright 2013 You may re-use this information (not including logos) free of charge in any format or medium, under the terms of the Open Government Licence. Visit www.nationalarchives.gov.uk/doc/open-government-licence, write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk. This publication is available from www.gov.uk/bis Any enquiries regarding this publication should be sent to: Department for Business, Innovation and Skills 1 Victoria Street London SW1H 0ET Tel: 020 7215 5000 If you require this publication in an alternative format, email enquiries@bis.gsi.gov.uk, or call 020 7215 5000.
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## Comité Binational Et Service Permanent Pour La Régulation Économique De La Liaison Fixe Transmanche The Bi-National Committee And Permanent Service For Channel Fixed Link Economic Regulation Rules Of Procedure Relating To The Aims, Composition, Scope Of Work And Administration Of The Bi-National Committee And Permanent Service Règlement Intérieur Relatif Aux Objectifs, À La Composition, Au Périmètre De Travail Et À L'Administration Du Comité Binational Et Du Service Permanent 16Th **February 2017** 16 Février 2017 Contexte Background Article 57 of Directive 2012/34/EU of the European Parliament and of the Council of 21 November 2012 establishing a single European railway area (recast) stipulates that regulatory bodies shall cooperate closely and may establish working arrangements accordingly. L'article 57 de la Directive 2012/34/UE du Parlement Européen et du Conseil du 21 novembre 2012 établissant un espace ferroviaire unique européen (refonte) prévoit que les organismes de contrôle coopèrent étroitement et qu'ils peuvent, à ce titre, fixer d'un commun accord des modalités de leur collaboration. To this end, and pursuant to Article 3 of the IGC regulation, ARAFER and ORR agreed to draw up a cooperation agreement coordinating their common economic regulatory functions (the Cooperation Agreement) with the aim of ensuring that their cooperation is based on reciprocity and mutual trust and understanding. A cette fin, et conformément à l'article 3 du règlement de la CIG, l'ARAFER et l'ORR ont consenti à établir un accord de coopération encadrant leurs missions communes de régulation économique de la Liaison Fixe transmanche (ci-après « l'Accord de coopération »), et ce, afin de garantir que cette coopération soit fondée sur la réciprocité, la confiance et la compréhension mutuelles. L'article 7.1 de l'Accord de coopération prévoit que les autorités Article 7.1 of the Cooperation Agreement provides for the Authorities to établissent un organe dénommé le comité binational dont l'objet et les missions sont décrits à l'article 7.1 de l'Accord de coopération. establish a body known as the bi-national committee, whose responsibilities and tasks shall include those set out in Article 7.1 of the Cooperation Agreement. Article 8.1 of the Cooperation Agreement provides for Authorities to establish a bi-national standing working group known as the permanent service which is responsible for enhancing cooperation between the Authorities and ensuring that the Authorities have regard to Article 3.1 of the Cooperation Agreement while carrying out the regulatory tasks set out in Article 5 of the Cooperation Agreement. L'article 8.1 de l'Accord de coopération stipule que les autorités établissent un groupe de travail binational dénommé le « service permanent » dont l'objet est, d'une part, de garantir le développement de la coopération entre les autorités et, d'autre part, d'assurer la mise en œuvre d'un processus décisionnel coordonné tel que défini à l'article 3.1 de l'Accord de coopération par les Autorités dans le cadre de leurs missions de régulation décrites à l'article 5 de l'Accord de coopération. Les articles 7.5 et 8.3 de l'Accord de coopération stipulent que le comité binational adopte un règlement intérieur qui établit des éléments de procédure interne pour le comité binational et qui définit les modalités de travail du service permanent. Articles 7.5 and 8.3 of the Cooperation Agreement provide for the binational committee to adopt rules of procedure which set out internal procedural matters for the bi-national committee and contain working arrangements for the permanent service. These rules of procedure have been drawn up pursuant to those provisions. Le présent règlement intérieur a été élaboré conformément à ces dispositions. ## Interprétation Interpretation Sauf disposition contraire, les termes et expressions utilisés dans l'Accord de coopération prendront la même signification dans le règlement intérieur. Dans le présent règlement intérieur : Unless otherwise indicated, terms and expressions used in the Cooperation Agreement shall have the same meaning in these rules of procedure. In these rules of procedure: « ARAFER » désigne l'Autorité de régulation des activités ferroviaires et routières, l'organisme de contrôle ferroviaire en France. "ARAFER" means Autorité de régulation des activités ferroviaires et routières, the rail regulatory body in France. « Accord de coopération » désigne l'accord entre l'ARAFER et l'ORR sur la régulation économique de la Liaison Fixe transmanche initialement "Cooperation Agreement" means the agreement between ARAFER and ORR for Channel Fixed Link economic regulation initially dated 16 March ## 2015, as amended and restated from time to time. signé le 16 mars 2015, dans sa version modifiée et mise à jour à l'occasion. « Autorité » désigne l'ARAFER ou l'ORR. Les « Autorités » désignent l'ARAFER et l'ORR conjointement. "Authority" means ORR or ARAFER and "Authorities" means ORR and ARAFER together. "Bi-national committee" means the body established by the Authorities pursuant to Article 7 of the Cooperation Agreement. « Comité binational » désigne l'organe établi à l'article 7 de l'Accord de coopération. « Collège » désigne: (i) dans le cas de l'ARAFER, le collège de l'ARAFER; et (ii) dans le cas de l'ORR, le collège de l'ORR ou tout membre ou employé de l'ORR avec la responsabilité déléguée appropriée de prendre des décisions contraignantes pour l'ORR. "Board" means: (i) in the case of ARAFER, the ARAFER collège; and (ii) in the case of ORR, the board of ORR or any member or employee of ORR with the appropriate delegated responsibility to take decisions binding on ORR. « Concessionnaires » désigne les sociétés privées prévues à l'article 1er du Traité de Cantorbéry. "Concessionaires" has the meaning given in Article 1 of the Treaty of Canterbury. « Directive » désigne la directive 2012/34/UE du Parlement européen et du Conseil du 21 novembre 2012 (refonte) établissant un espace ferroviaire unique européen. "Directive" means Directive 2012/34/EU of the European Parliament and of the Council of 21 November 2012 (recast) establishing a single European railway area. « DRR » désigne le document de référence du réseau publié par les Concessionnaires sur le fondement de l'article 27 de la Directive. "Network statement" means the network statement published by the Concessionaires in accordance with Article 27 of the Directive. « Entreprise ferroviaire » désigne toute entreprise selon les termes de l'article 3 du paragraphe 1 de la Directive. "Railway undertaking" has the meaning set out in Article 3(1) of the Directive. « Jour Ouvré » désigne un jour autre qu'un samedi, dimanche ou jours fériés ou des vacances de la fonction publique à Londres ou à Paris. "Working day" means a day other than a Saturday, Sunday, public holiday or civil service holiday in London or Paris. « Liaison Fixe » désigne la Liaison Fixe au sens de l'article 1 du Traité de Cantorbéry. "Fixed Link" means the Fixed Link as defined as in Article 1 of the Treaty of Canterbury. « Organisme de contrôle » désigne une autorité autonome juridiquement "Regulatory body" means an autonomous, legally distinct and independent distincte et indépendante au sens de l'article 55 de la Directive. authority as referred to in Article 55 of the Directive. « ORR » désigne Office of Rail and Road, l'organisme de contrôle ferroviaire au Royaume-Uni. "ORR" means the Office of Rail and Road, the rail regulatory body in Great Britain. "Chairs" means the Chair of the ORR board and the President of ARAFER. « Présidents » désigne le Président du collège de l'ORR et le Président de l'ARAFER. « Règlement binational » désigne le règlement transférant la compétence de régulation économique ferroviaire de la Commission "IGC regulation" means the regulation transferring economic rail regulation competence from the Intergovernmental Commission to the national regulatory bodies, setting out principles for cooperation between them and establishing a charging framework for the Fixed Link. intergouvernementale aux organismes de contrôle nationaux, établissant les principes de la coopération entre ceux-ci et portant établissement d'un cadre de tarification pour la Liaison Fixe. « Service permanent » désigne le groupe de travail permanent entre les services des Autorités établi à l'article 8 de l'Accord de coopération. "Permanent service" means the standing working group established by the Authorities pursuant to the Article 8 of the Cooperation Agreement. « Traité de Cantorbéry » désigne le traité signé entre la France et le Royaume-Uni le 12 février 1986 autorisant la construction et l'exploitation de la Liaison Fixe par des concessionnaires privés. "Treaty of Canterbury" means the treaty signed between France and the United Kingdom on 12 February 1986 authorising the construction and operation of the Fixed Link by private concessionaires. ## Première Partie : Règlement Interieur Relatif Au Comité Binational Part One: Rules Of Procedure Relating To The Bi- National Committee 1. Objectifs : Objectives: Le comité binational supervise notamment les activités du service permanent et l'animation des échanges entre les Autorités. Il est le garant d'une prise de décision coordonnée et cohérente par les Autorités dans le cadre de l'Accord de coopération. The responsibilities of the bi-national committee shall include steering the activities of the permanent service and exchanging views between the Authorities in support of co-ordinated and consistent decisionmaking by the Authorities in the context of the Cooperation Agreement. To this end, the bi-national committee shall act as a second stage mechanism for the Authorities to identify and resolve differences and to avoid the adoption of conflicting decisions. Dans le cadre de cet objectif, le comité binational intervient, en tant que de besoin, comme mécanisme de second rang permettant aux Autorités d'identifier et de résoudre les différences de points de vue et d'éviter l'adoption de décisions contradictoires. ## 2. Fonctions: Tasks: Afin d'accompagner les Autorités dans le cadre de leurs missions de régulation, le comité binational est chargé de : To assist the Authorities in their regulatory tasks, the bi-national committee shall: exchange views between the Authorities in support of co-ordinated and consistent decision-making by the Authorities, on any matter within scope of the Cooperation Agreement; 2.1. Faciliter les échanges entre les Autorités afin de garantir la coordination et la cohérence du processus de prise de décision par celles-ci sur tous les sujets compris dans le périmètre de l'Accord de coopération ; 2.2. Superviser les activités du service permanent, et notamment : steer the activities of the permanent service, including but not limited to: 2.2.1. Guider le service permanent dans la préparation du programme de travail annuel, et ce, dès la signature de l'Accord de coopération et avant le début de chaque année de fonctionnement ; et directing the permanent service to prepare an annual work programme as soon as possible after the date of signature of the Cooperation Agreement and before the start of each operational year; and 2.2.2. Approuver le programme de travail annuel élaboré par le service permanent ; approving the annual work programme prepared by the permanent service; facilitate the taking of decisions by the Authorities following an appeal pursuant to Article 56(1) of the Directive and ensuring that such decisions are agreed and published by both Authorities; 2.3. Faciliter la prise des décisions par les Autorités dans le cadre des procédures prévues au premier paragraphe de l'article 56 de la Directive en s'assurant qu'elles fassent l'objet d'un accord entre les Autorités et qu'elles soient publiées par celles-ci ; 2.4. En cas de notification par le service permanent au comité binational d'une différence de point de vue entre les deux Autorités sur la mise in the event that the permanent service notifies the bi-national committee of a difference of view between the two Authorities concerning either en œuvre de l'article 9 de l'Accord de coopération ou sur le fond d'une procédure de règlement de différend : the application of Article 9 of the Cooperation Agreement or the substance of any appeal: 2.4.1. Rapprocher les points de vue ; ou resolve the difference itself; or aid the Chairs in conciliating between the Authorities pursuant to Article 12 of the Cooperation Agreement; 2.4.2. Aider, conformément à l'article 12 de l'Accord de coopération, les Présidents des Autorités lors de la procédure de conciliation ; 2.5. Si nécessaire, lorsque le service permanent mène des instructions initiées par les Autorités ou en réponse à une plainte liée à la Liaison Fixe, conformément aux articles 56(2), 56(4), 56(6), 56(9) et/ou 56(12) de la Directive : where necessary while the permanent service is carrying out investigations initiated by the Authorities or in response to a complaint in relation to the Fixed Link in accordance with Articles 56(2), 56(4), 56(6), 56(9) and/or 56(12) of the Directive: 2.5.1. Identifier et valider les éléments devant faire l'objet d'une instruction par le service permanent ; identify and agree upon matters to be subject to investigation by the permanent service; 2.5.2. Faciliter la prise de toute décision de mise en demeure par les Autorités ; et facilitate the taking of any decision by the Authorities to deliver a formal notice to comply; and 2.5.3. S'assurer qu'une décision de mise en demeure est notifiée et publiée, dans la mesure du possible, de manière coordonnée par les deux Autorités ; ensure that any formal notice to comply is notified and published where possible in a coordinated way by both Authorities; 2.6. En cas de notification par le service permanent au comité binational d'une différence de point de vue entre les deux Autorités sur l'application de l'article 10 de l'Accord de coopération ou sur le fond de toute procédure de sanction : in the event that the permanent service notifies the bi-national committee of a difference of view between the two Authorities concerning either the application of Article 10 of the Cooperation Agreement or the substance of any investigation: 2.6.1. Rapprocher les points de vue ; ou resolve the difference itself; or 2.6.2. Aider, conformément à l'article 12 de l'Accord de coopération, les Présidents lors de la procédure de aid the Chairs in conciliating between the Authorities pursuant to Article 12 of the Cooperation Agreement; conciliation ; 2.7. Lors de l'adoption par les Autorités d'avis motivés sur le DRR ainsi que sur toute autre question ne relevant pas des articles 9 ou 10 de l'Accord de coopération : when the Authorities are adopting non-binding opinions on each iteration of the network statement and any other matter that is not subject to Articles 9 or 10 of the Cooperation Agreement: 2.7.1. S'assurer qu'aucune des deux Autorités n'adopte unilatéralement un avis relatif à la Liaison Fixe sans avoir préalablement recueilli l'accord de l'autre Autorité ; ensure that neither Authority unilaterally adopts an opinion in relation to the Fixed Link without first seeking the agreement of the other Authority; 2.7.2. Soumettre aux Autorités les recommandations élaborées par le service permanent et soumises à l'approbation du comité binational ; et submit recommendations to the Authorities prepared by the permanent service and submitted to the bi-national committee for approval; and 2.7.3. Publier les avis des Autorités en anglais et en français sur le site internet de chaque Autorité ; publish the opinions of the Authorities in English and French on the website of each Authority; 2.8. En cas de notification par le service permanent au comité binational d'une différence de point de vue entre les deux Autorités sur l'application de l'article 11 de l'Accord de coopération ou sur le fond de toute recommandation pour l'adoption d'un avis motivé : in the event that the permanent service notifies the bi-national committee of a difference of view between the two Authorities concerning either the application of Article 11 of the Cooperation Agreement or the substance of any recommendation for the adoption of a non-binding opinion: 2.8.1. Rapprocher les points de vue ; ou resolve the difference itself; or aid the Chairs in conciliating between the Authorities pursuant to Article 12 of the Cooperation Agreement; 2.8.2. Aider, conformément à l'article 12 de l'Accord de coopération, les Présidents lors de la procédure de conciliation ; 2.9. Effectuer le suivi de l'application de l'Accord de coopération ; monitor the application of the Cooperation Agreement; 2.10. Réaliser toute autre tâche qui lui est assignée d'un commun accord carry out any other task assigned to it by agreement of the two Authorities. par les Autorités. 3. Composition : Composition: 3.1. Le comité binational comprend une délégation de trois membres de l'ARAFER et une délégation de trois membres de l'ORR. Les membres du comité dialoguent d'égal à égal. The bi-national committee shall comprise an ARAFER delegation of three people and an ORR delegation of three people. The views of each delegation shall carry equal weight. 3.2. Chaque Autorité désigne les membres de sa délégation qui siègent au comité binational. Each Authority shall decide on the members of its delegation to the binational committee. Each Authority shall communicate to the other the names of the head and of the other members of its delegation, and notify any changes which may occur in the composition of the delegation. 3.3. Chaque Autorité communique à l'autre Autorité les noms du chef de délégation et de ses autres membres et notifie à l'autre Autorité toute modification pouvant intervenir dans la composition de sa délégation. 3.4. En cas d'empêchement d'un membre du comité binational, l'Autorité concernée peut procéder à son remplacement. Le nom de la personne remplaçante est communiqué à l'autre Autorité préalablement à la réunion. If any member is unable to attend a meeting of the bi-national committee, the relevant Authority may replace that member with an alternate whose name shall be communicated to the other Authority beforehand. 3.5. Le comité binational est composé de membres des Collèges. The bi-national committee shall be composed of members of the Boards. 4. Président du comité binational : Chair of the bi-national committee: 4.1. La présidence du comité binational est assurée alternativement par le chef de chaque délégation. The chair of the bi-national committee shall be held by the head of each delegation alternately. 4.2. Le rôle du Président est d'assurer l'efficacité et l'équité des débats. The role of the chair will be to ensure that meetings are run efficiently and fairly. 4.3. Le Président ne dispose pas d'une voix prépondérante. The chair shall not have a casting vote in relation to any decision making. 4.4. En l'absence du Président, la présidence est assurée par un autre membre de sa délégation. Le chef de l'autre délégation en est informé. In the absence of the chair, the chair shall be assumed by another member of his or her delegation, and the head of the other delegation shall be informed. 4.5. Le Président est nommé et entre en fonction le premier jour de l'année de fonctionnement correspondante et assure cette fonction jusqu'au terme de ladite année de fonctionnement. The chair shall be appointed and take office on the first day of the relevant operational year and shall hold office until the end of the last day of that operational year. ## 5. Réunions : Meetings: 5.1. Au plus tard au début de chaque année de fonctionnement, le comité binational valide un calendrier des réunions ordinaires (ci-après « les Réunions ordinaires »). By no later than the start of each operational year, the bi-national committee shall agree a schedule of regular meetings (Regular Meetings). 5.2. Le comité binational se réunit au moins trois fois par année de fonctionnement. There should be no fewer than three Regular Meetings in each operational year. 5.3. Le comité binational peut planifier une réunion avant la prochaine Réunion ordinaire (ci-après « la Réunion urgente ») s'il s'avère qu'il est nécessaire ou opportun de l'organiser. The bi-national committee may schedule a meeting to occur prior to the next Regular Meeting (an Urgent Meeting) if it is necessary or expedient to do so. 5.4. A l'exception des cas de force majeure, les Réunions urgentes sont annoncées avec un préavis minimum de cinq jours ouvrés. There shall be at least five working days' notice of Urgent Meetings, except in emergencies. 5.5. Sauf accord contraire des chefs de délégation, les Réunions ordinaires sont organisées en alternance au Royaume-Uni et en France. Les Réunions urgentes se tiennent au lieu que les chefs de délégation jugent le plus approprié. Regular Meetings shall normally be held alternately in the UK and in France, except if the heads of delegation agree otherwise. Urgent Meetings shall be held wherever the heads of delegation consider appropriate. The agenda and relevant documents relating to any Regular Meeting or Urgent Meeting (together, Meetings) shall wherever possible be provided to each delegation at least five working days in advance. 5.6. L'ordre du jour et la documentation pertinente relative à toute Réunion ordinaire ou Réunions urgente (ci-après, conjointement « les Réunions ») doivent, dans la mesure du possible, être fournis à chaque délégation au minimum cinq jours ouvrés avant leur tenue. 5.7. Les Réunions peuvent se tenir par conférence téléphonique ou à l'aide de tout équipement de communication similaire. Any Meeting may be held by conference telephone or similar communication equipment. 5.8. Sauf accord contraire de l'ensemble des participants, les Réunions se tiennent à la fois en langue anglaise et française. Unless otherwise agreed by all participants, all Meetings shall be held in both English and French. If more than six months have elapsed/will elapse between Meetings, the heads of delegation shall immediately inform the Authorities and explain why such a gap has occurred/will occur. 5.9. Dans le cas où plus de six mois se seraient écoulés ou pourraient s'écouler entre deux Réunions, les chefs de délégation en informent immédiatement les Autorités et justifient la raison d'un tel délai d'inactivité. 5.10. Lors des Réunions, le quorum est atteint à partir de deux membres de chaque délégation, y compris le chef de la délégation nationale ou la personne désignée pour en assumer temporairement le rôle. Chaque Autorité prend toutes les mesures nécessaires afin d'atteindre le quorum lors des Réunions. The quorum for any Meeting of the bi-national committee shall be two members of each delegation, including the head of each national delegation or the person nominated to act temporarily in his or her place. Each Authority shall take all reasonable steps to ensure participation of a quorate delegation at Meetings. 5.11. Sur accord des chefs de délégation, le comité binational peut auditionner toute personne de son choix. By agreement between the heads of delegation, the bi-national committee may hear from any person it may choose. ## 6. Prises De Décision Lors Des Réunions : Decision Making At Meetings: Where the bi-national committee is required to consider any matter (the Relevant Matter), it shall follow the procedure set out in this paragraph: 6.1. Lors de l'examen de toute affaire (ci-après « l'Affaire concernée »), le comité binational met en œuvre la procédure décrite au présent paragraphe : 6.1.1. Dans la mesure du possible, le comité binational examine les éléments de l'Affaire concernée lors de la Réunion ordinaire suivante ; wherever possible, the bi-national committee shall examine the evidence relating to the Relevant Matter at the next Regular Meeting; 6.1.2. Lorsque l'Affaire concernée est urgent, le comité binational organise une Réunion urgente et examine les éléments relatifs à cette affaire à cette occasion ; where the Relevant Matter is urgent, the bi-national committee shall convene an Urgent Meeting and examine the evidence relating to the Relevant Matter at that Urgent Meeting; after the bi-national committee has discussed the Relevant Matter at a Meeting, it shall prepare a report to the Authorities, setting out its agreed recommendations; 6.1.3. Lorsque le comité binational a examiné l'Affaire concernée lors d'une Réunion, il prépare un rapport destiné aux Autorités dans lequel il présente les recommandations ayant fait l'objet d'un accord ; 6.1.4. Si le comité binational ne parvient pas à un accord lors d'une Réunion, il organise une Réunion urgente afin d'examiner de nouveau l'Affaire concernée conformément aux délais prévus par la réglementation applicable ; et if the bi-national committee is unable to reach consensus at a Meeting, the bi-national committee shall convene an Urgent Meeting to reconsider the Relevant Matter within such time period as is necessary to comply with any legal deadline; and if the bi-national committee remains unable to reach consensus, or if both heads of delegation agree that it is not necessary or expedient to convene a second Meeting, it shall submit a report to the Chairs within such time period as is necessary to comply with any legal deadline. Such report shall concisely set out the details of the Relevant Matter and the areas of agreement and disagreement between the delegations. 6.1.5. Si, à l'issue d'une Réunion urgente, le comité binational ne parvient toujours pas à aboutir à un accord ou si les deux chefs de délégation s'accordent sur le fait qu'il n'est ni nécessaire ni urgent d'organiser une deuxième Réunion, il transmet un rapport aux Présidents dans les meilleurs délais. Ce rapport précise, de manière concise, les détails de l'Affaire concernée et les points d'accord ou de désaccord entre les délégations. 6.2. Tout acte ou décision adopté par le comité binational est authentifié par la signature du président du comité binational ou de toute personne nommée par le comité binational pour agir temporairement en son nom. Any decision or other act of the bi-national committee shall be authenticated by the signature of the chair of the bi-national committee, or a person nominated by the bi-national committee to act temporarily in his or her place. ## 7. Soumission Des Rapports : Submission Of Reports: Lorsque le comité binational doit soumettre un rapport, celui-ci: Where the bi-national committee is required to submit a report, such report shall: 7.1. Est préparé par le service permanent, en sa qualité de secrétariat du comité binational ; be prepared by the permanent service in its capacity as secretariat to the bi-national committee; 7.2. Est rédigé en anglais et en français ; be in writing in English and French; 7.3. Est unique et reflète les opinions du comité binational dans son ensemble ; et be a single report reflecting the views of the bi-national committee as a whole; and 7.4. Présente, le cas échéant, de manière concise les points d'accord ou de désaccord entre les délégations. where applicable, concisely set out any areas of agreement and disagreement between the delegations. 8. Langues : Languages: 8.1. La langue de travail de la délégation de l'ORR est l'anglais. La langue de travail de la délégation de l'ARAFER est le français. The working language of the ORR delegation to the bi-national committee shall be English. The working language of the ARAFER delegation to the bi-national committee shall be French. 8.2. Les textes rédigés en anglais et en français font également foi. English and French texts shall be equally authoritative. 9. Publications : Publications: Lorsque le comité binational doit publier ou organiser la publication de tout document, il envoie ou organise l'envoi de l'avant-projet à tous les destinataires pertinents afin de confirmer, dans un délai Where the bi-national committee is required to publish or arrange for the publication of any document, the bi-national committee shall send or arrange for the draft document to be sent to all relevant parties to raisonnable : confirm within a reasonable time: 9.1. Si le document contient des erreurs matérielles ; et whether the document contains any material errors; and 9.2. Si des informations contenues dans le document doivent être traitées de manière confidentielle. whether any information contained within the document should be treated as confidential. ## 10. Autres Dispositions : Other Provisions: 10.1. Chaque année de fonctionnement du comité binational débute le 1er avril de l'année en cours et dure douze mois calendaires, pour se terminer au 31 mars de l'année suivante. Each operational year of the bi-national committee shall commence on 1 April of the relevant year and be for a period of twelve calendar months ending on 31 March of the following year. 10.2. Le comité binational peut, sur proposition de l'un ou l'autre des chefs de délégation, décider d'examiner toute modification de ces règles. Si une modification est adoptée, après accord du comité binational, elle doit être soumise aux Autorités pour approbation. La modification entre en vigueur dès la notification de l'approbation par les deux Autorités au comité binational. The bi-national committee may decide to consider any amendment to these rules proposed by the head of either delegation. If such an amendment is adopted by agreement of the bi-national committee, it shall be submitted to the Authorities for approval. The amendment shall come into force when the approval of both Authorities has been notified to the bi-national committee. ## Deuxième Partie : Reglement Interieur Relatif Au Service Permanent Part Two: Rules Of Procedure Relating To The Permanent Service 11. Objectifs : Objectives: Le service permanent favorise la coopération entre les Autorités et garantit que celles-ci tiennent compte de l'article 3.1 de l'Accord de coopération dans le cadre de la mise en œuvre de leurs missions de The permanent service shall be responsible for enhancing cooperation between the Authorities at the working level and ensuring that the Authorities have regard to Article 3.1 of the Cooperation Agreement régulation décrites à l'article 5 de l'Accord de coopération. while carrying out the regulatory tasks set out in Article 5 of the Cooperation Agreement. A cette fin, le service permanent agit en amont afin de permettre aux Autorités d'identifier et de résoudre les divergences d'opinion et d'éviter l'adoption de décisions contradictoires. To this end, the permanent service shall act as an early stage mechanism for the Authorities to identify and resolve differences and to avoid the adoption of conflicting decisions. ## 12. Fonctions : Tasks: Afin d'appuyer le comité binational et d'aider les Autorités dans la réalisation de leurs missions de régulation, le service permanent : To support the bi-national committee and assist the Authorities in their regulatory tasks, the permanent service shall: while having regard to any work concerning the Fixed Link to be undertaken by either Authority over the same period in relation to their regulatory functions outside the scope of the Cooperation Agreement: 12.1. Tout en tenant compte des travaux concernant la Liaison Fixe devant être entrepris pour l'une ou l'autre des Autorités dans la même période au titre de leurs fonctions de régulateur en dehors du périmètre de l'Accord de coopération : 12.1.1. Elabore un programme de travail annuel soumis pour approbation au comité binational ; et draw up an annual work programme which shall be submitted to the bi-national committee for approval; and 12.1.2. Veille à la mise en place des activités décrites dans ce dernier ; following approval of the work programme ensure that the specified activities are carried out; undertake the annual review and monitoring of the Concessionaires' network statement and submit a report presenting agreed recommendations to the bi-national committee on the network statement; 12.2. Réalise l'instruction annuelle de l'avis sur le document de référence du réseau des concessionnaires et en assure le suivi. A cette fin, il soumet au comité binational un rapport présentant les recommandations communes ; investigate appeals pursuant to Article 56(1) of the Directive; 12.3. Instruit les différends au titre du premier paragraphe de l'article 56 de la Directive ; when investigating appeals pursuant to Article 56(1) of the Directive: 12.4. Lors de l'instruction des différends au titre du premier paragraphe de l'article 56 de la directive : collect and exchange submissions from the appellant, the defendant and any other interested parties; 12.4.1. Analyse les productions du demandeur, du défendeur et de toute autre partie intéressée et les communique dans le respect du principe de contradictoire ; 12.4.2. Soumet aux Collèges un rapport présentant les recommandations communes ; et submit a report presenting agreed recommendations to the Boards on the above submissions; and 12.4.3. Notifie sans délai au comité binational toute divergence d'opinion entre les deux Autorités concernant soit l'application de l'article 9 de l'Accord de coopération soit le fond du différend. notify the bi-national committee without delay of any difference of view between the two Authorities concerning either the application of Article 9 of the Cooperation Agreement or the substance of any appeal; 12.5. A la demande des Autorités, instruit les procédures de sanction initiées par les Autorités ou en réponse à une plainte liée à la Liaison Fixe, conformément aux Articles 56(2), 56(4), 56(6), 56(9) et/ou 56(12) de la Directive ; at the request of the Authorities, carry out investigations initiated by the Authorities or in response to a complaint in relation to the Fixed Link in accordance with Articles 56(2), 56(4), 56(6), 56(9) and/or 56(12) of the Directive; 12.6. Lors de l'instruction des procédures initiées par les Autorités ou en réponse à une plainte liée à la Liaison Fixe, conformément aux articles 56(2), 56(4), 56(6), 56(9) et/ou 56(12) de la Directive : when carrying out investigations initiated by the Authorities or in response to a complaint in relation to the Fixed Link in accordance with Articles 56(2), 56(4), 56(6), 56(9) and/or 56(12) of the Directive: identify and agree upon matters to be subject to investigation; 12.6.1. Identifie et valide les questions qui seront soumises à instruction ; collect evidence from the defendant, the Concessionaires, railway undertakings and any other relevant parties; 12.6.2. Rassemble les éléments de preuves communiqués par le défendeur, les concessionnaires, les entreprises ferroviaires et toute personne concernée ; submit a report presenting agreed recommendations on the 12.6.3. Soumet à l'approbation du comité binational un rapport présentant les recommandations communes à l'issue de l'instruction ; investigation to the bi-national committee for approval; 12.6.4. Effectue le suivi de la mise en conformité à la mise en demeure; investigate and monitor timely compliance with any notice to comply by any party to whom such notice is addressed; 12.6.5. Soumet aux Collèges un rapport relatif à la conformité avec la mise en demeure ; et submit a report on compliance presenting agreed recommendations to the Boards; and 12.6.6. Notifie sans délai au comité binational toute divergence d'opinion entre les deux Autorités concernant tant l'application de l'article 10 de l'Accord de coopération que le contenu de l'instruction ; notify the bi-national committee without delay of any difference of view between the two Authorities concerning either the application of Article 10 of the Cooperation Agreement or the substance of any investigation; 12.7. Lors de la préparation des recommandations pour l'adoption d'avis motivés par les Autorités, notifie sans délai au comité binational toute divergence d'opinion entre les deux Autorités tant sur l'application de l'article 11 de l'Accord de coopération que sur le contenu de tout projet d'avis motivé ; when preparing recommendations for the adoption of non-binding opinions by the Authorities, notify the bi-national committee without delay of any difference of view between the two Authorities concerning either the application of Article 11 of the Cooperation Agreement or the substance of any opinion; ensure that each Authority has equal and prompt access to any information or evidence of which the permanent service becomes aware; 12.8. Garantit que chaque Autorité dispose d'un accès égal et rapide à tout élément d'information ou de preuve porté à la connaissance du service permanent ; 12.9. Assure le secrétariat du comité binational et : act as secretariat to the bi-national committee and: 12.9.1. Prépare l'ordre du jour, la documentation et les supports des réunions du comité binational ; prepare agendas, documentation and papers for meetings of the bi-national committee; 12.9.2. Prépare une synthèse de chaque réunion du comité binational ; prepare a summary of each meeting of the bi-national committee; 12.9.3. Assure l'exécution et le suivi des décisions des Autorités relatives à la Liaison Fixe ; give effect to and follow up on decisions of the Authorities in relation to the Fixed Link; 12.9.4. Reçoit et traite la correspondance adressée : receive and deal with correspondence addressed to: 12.9.4.1. Au comité binational ; et the bi-national committee; and 12.9.4.2. Aux Autorités en ce qui concerne les correspondances liées à la Liaison Fixe ; the Authorities in respect of correspondence related to the Fixed Link; 12.9.5. Fournit l'appui technique et administratif nécessaire au comité binational, y compris l'organisation de la réalisation des expertises et consultations ; provide the necessary administrative and technical support to the bi-national committee, including arranging expert assistance and consultancy support; share details of planned resource requirements for each delegation for the coming operational year; and 12.9.6. Partage les informations concernant les ressources budgétaires de chaque délégation pour l'année de fonctionnement suivante ; et 12.10. Lorsque les Autorités ou le comité binational le demandent, il restitue les travaux relatifs à la régulation ferroviaire de la Liaison Fixe, en vue d'assurer un accès et une tarification équitables et non discriminatoires au réseau et aux services. where requested by the bi-national committee or the Authorities, report on matters relating to the regulation of railway activities in the Fixed Link for the purpose of ensuring fair and non-discriminatory access and charging to the rail network and services. ## 13. Composition : Composition: The permanent service shall comprise an ARAFER delegation and an ORR delegation. The views of each delegation shall carry equal weight. 13.1. Le service permanent est composé d'une délégation de l'ARAFER et d'une délégation de l'ORR. Les membres du service permanent dialoguent d'égal à égal. 13.2. Chaque Autorité désigne les membres de sa délégation qui siègent au service permanent. Each Authority shall decide on the members of its delegation to the permanent service. 13.3. Chaque Autorité communique à l'autre le nom du responsable de la délégation et de ses autres membres et notifie toute modification Each Authority shall communicate to the other the names of the head and of the other members of its delegation, and notify any changes pouvant intervenir dans la composition de sa délégation. which may occur in the composition of the delegation. 13.4. En cas d'empêchement du chef de délégation, l'Autorité concernée peut procéder à son remplacement. Le nom de la personne remplaçante est communiqué à l'autre Autorité préalablement à la réunion. If either head of delegation is unable to attend a meeting of the permanent service, the relevant Authority may replace that head with an alternate whose name shall be communicated to the other Authority beforehand. 13.5. Chaque délégation doit normalement être composée au minimum des représentants suivants : It is expected that each delegation will normally consist of at least the following: 13.5.1. Un responsable de délégation expérimenté ; a head of delegation with appropriate seniority; 13.5.2. Un conseiller économique ; et an economic advisor; and 13.5.3. Un conseiller juridique. a legal advisor. If appropriate, other advisors (such as railway and/or financial experts) and specialists from the Authorities will join meetings of the Permanent Service in addition to or instead of the delegates listed above. 13.6. Le cas échéant, d'autres conseillers (tels que des experts ferroviaires et/ou financiers) et d'autres spécialistes représentant les Autorités peuvent participer aux réunions du service permanent en plus, ou à la place, des délégués précédemment listés. ## 14. Président Du Service Permanent : Chair Of The Permanent Service: 14.1. La présidence du service permanent est assurée alternativement par le chef de chaque délégation. The chair of the permanent service shall be held by the head of each delegation alternately. 14.2. Le rôle du président est de s'assurer de l'efficacité et de l'équité des débats. The role of the chair will be to ensure that meetings are run efficiently and fairly. 14.3. Le président ne dispose pas d'une voix prépondérante. The chair shall not have a casting vote in relation to any decision making. 14.4. En l'absence du président, la présidence est assurée par un autre membre de sa délégation. Le responsable de l'autre délégation en est informé. In the absence of the chair, the chair shall be assumed by another member of his or her delegation, and the head of the other delegation shall be informed. 14.5. Le président est nommé le premier jour de l'année de fonctionnement et assure la présidence jusqu'au dernier jour de cette année de fonctionnement. The chair shall be appointed and take office on the first day of the relevant operational year and shall hold office until the end of the last day of that operational year. 15. Nomination des rapporteurs, experts et toute autre personne : Appointment of rapporteurs, experts, and any other person: To ensure that there is a clear distinction between investigative and decision making responsibilities within each Authority, the permanent service may arrange the appointment of rapporteurs, experts or any other person to carry out specific appeal and enforcement investigations. 15.1. Afin de garantir une distinction claire entre les responsabilités liées à l'instruction des procédures et celles relatives à la prise de décision au sein de chaque Autorité, le service permanent peut nommer des rapporteurs, des experts ou toute autre personne chargés de réaliser des missions spécifiques relatives aux différends ou à leur exécution. 15.2. Le service permanent peut effectuer ces nominations uniquement à la demande expresse des Autorités. The permanent service may only make such an appointment if the Authorities direct the permanent service to make such appointment. 15.3. Les personnes nommées peuvent être membres ou non membres du service permanent. Such appointment may be from within or outside the membership of the permanent service and may be of an existing member or employee of the Authorities. Without prejudice to any additional procurement rules within either Authority or any applicable EU or domestic law, regulation or custom, where the permanent service makes an appointment of a person who is neither a member nor an employee of either Authority it shall: 15.4. Sans préjudice de toutes autres règles relatives aux marchés publics existant au sein de l'une ou l'autre des Autorités au titre d'une législation, réglementation ou pratique nationale ou européenne, lorsque le service permanent nomme une personne qui n'est ni membre, ni agent employé par l'une ou l'autre Autorité : agree if a single Authority will lead the procurement process, or 15.4.1. Il décide si la procédure de passation est mise en œuvre par une seule des Autorités ou si elle fait l'objet d'un traitement conjoint ; if the appointment should be jointly procured; 15.4.2. Il détermine le coût des besoins et valide le dispositif de partage des coûts conformément à l'article 8.8 de l'Accord de coopération ; establish the likely cost of the requirements and agree the arrangements for sharing them in accordance with Article 8.8 of the Cooperation Agreement; 15.4.3. Il définit précisément les besoins, en indiquant : specify the requirements accurately setting out: 15.4.3.1. Le fondement des travaux nécessaire à la compréhension de leur contexte ; any background to the work necessary to understand its context; 15.4.3.2. Les objectifs des travaux ; the objectives of the work; 15.4.3.3. Les devoirs et/ou obligations du fournisseur ; the duties and/or obligations of the supplier; 15.4.3.4. Toutes les compétences ou l'expérience demandée au personnel du fournisseur ; any skills or experience required by the supplier's personnel; 15.4.3.5. Les détails de tous les résultats attendus ; details of any outcomes/outputs expected; 15.4.3.6. Les calendriers ; timelines; 15.4.3.7. Les critères d'évaluation liés à l'objet du marché ; et evaluation criteria relating to the subject matter of the procurement; and 15.4.3.8. Toute autre information pertinente ; any other relevant information; 15.4.4. Il précise les critères d'évaluation utilisés afin de faire un choix entre les fournisseurs ou, si une seule offre est déposée, précise les raisons justifiant de la retenir ; document what evaluation criteria are used to make a decision between suppliers, or if a single tender is made the justification for that single tender; 15.4.5. Il fournit la traçabilité complète et précise de l'appel d'offres et des décisions correspondantes ; et provide complete and accurate records of the tender and the decisions behind it; and 15.4.6. Le cas échéant, ou si nécessaire au titre d'une législation, if appropriate or required by any applicable EU or domestic law, regulation or custom, provide a debrief to all suppliers that submitted a proposal setting out the relative merits of their bid and the winning bid including their ranking. réglementation ou pratique nationale ou européenne, il fournit un résumé à l'ensemble des candidats à l'appel d'offres en soulignant les mérites relatifs de leurs offres et de l'offre ayant remporté le marché ainsi que leur classement. 15.5. Lorsque le service permanent nomme un rapporteur, un expert ou toute autre personne dans le but de remplir l'une de ses fonctions, toute règle relative au service permanent établie dans le présent règlement lui est opposable. Where the permanent service appoints a rapporteur, expert or any other person to carry out any of its functions, references in these rules of procedure to the permanent service shall be deemed to be a reference to that rapporteur, expert or any other person. ## 16. Instruction Réalisée Par Les Rapporteurs : Investigations By Rapporteurs: Where rapporteurs carry out specific appeal and enforcement investigations, they shall follow the procedure set out in this paragraph: 16.1. Lorsque les rapporteurs mènent une instruction dans le cadre d'un règlement de différend ou d'une procédure de sanction, ils suivent la procédure décrite au présent paragraphe : 16.1.1. Les rapporteurs tiennent compte des éléments de preuves obtenus au cours de l'instruction et préparent un avant-projet de rapport contenant leurs conclusions qu'ils soumettent aux chefs de délégation du service permanent ; rapporteurs shall consider the evidence relating to the investigation and shall prepare a draft report of their conclusions to be submitted to the heads of delegation of the permanent service; 16.1.2. Lorsque l'avant-projet de rapport démontre que les conclusions des rapporteurs sont convergentes, les chefs de délégation du service permanent autorisent les rapporteurs à finaliser le rapport et à l'envoyer aux collèges et aux parties ; where the draft report of the rapporteurs shows that their conclusions are aligned, the heads of delegation of the permanent service shall authorise the rapporteurs to finalise the report and shall arrange for the report to be submitted to the Boards and to the parties; 16.1.3. Lorsque l'avant-projet du rapport démontre que les conclusions des rapporteurs ne sont pas convergentes, les rapporteurs et les chefs de délégation du service permanent se réunissent afin d'examiner de nouveau les conclusions. Si where the draft report of the rapporteurs shows that their conclusions are not aligned, the rapporteurs and the heads of delegation of the permanent service shall meet to reconsider the conclusions. If after such meeting the rapporteurs are unable to align their conclusions, the heads of delegation shall instruct the rapporteurs to prepare a final report which includes a concise account of the areas of agreement and disagreement between the rapporteurs and shall arrange for the report to be submitted to the bi-national committee and to the parties. à la suite de cette réunion, les rapporteurs sont dans l'incapacité d'accorder leurs conclusions, les chefs de délégations demandent aux rapporteurs de préparer un rapport final incluant un descriptif concis des points d'accord et des points de désaccord et d'envoyer le rapport au comité binational et aux parties. 16.2. Le rapport final d'instruction est authentifié par la signature de chaque rapporteur. The final investigation report shall be authenticated by the signature of each rapporteur. ## 17. Réunions : Meetings: 17.1. Dès que possible après la date de signature de l'Accord de coopération, et au plus tard le 1er janvier de chaque année suivante, les chefs de délégation fixent un calendrier des réunions ordinaires (ci-après « les Réunions ordinaires ») du service permanent. As soon as possible after the date of the signature of the Cooperation Agreement, and by no later than 1 January of each subsequent year, the heads of delegation shall agree a schedule of regular meetings (Regular Meetings) of the permanent service. 17.2. Sauf accord contraire des responsables de délégation, les Réunions ordinaires sont organisées au moins une fois tous les deux mois calendaires suivant la signature de l'Accord de coopération. Unless the heads of delegation otherwise agree, Regular Meetings shall occur no further apart than every two calendar months following the date of the signature of the Cooperation Agreement. 17.3. S'ils l'estiment opportun, les chefs de délégation peuvent organiser une réunion supplémentaire avant la prochaine Réunion ordinaire (ciaprès « une Réunion urgente »). The heads of delegation may schedule a meeting to occur prior to the next Regular Meeting (an Urgent Meeting) if they agree that it is necessary or expedient to do so. 17.4. Les Réunions urgentes donnent lieu à un préavis minimum de cinq jours ouvrés, sauf cas de force majeure. There shall be at least five working days' notice of Urgent Meetings, except in emergencies. 17.5. Les Réunions ordinaires se tiennent de manière alternée en France et au Royaume-Uni, sauf si les chefs de délégation en décident autrement. Les Réunions urgentes se tiennent dans les lieux que les Regular Meetings shall normally be held alternately in the UK and in France, except if the heads of delegation agree otherwise. Urgent Meetings shall be held wherever the heads of delegation consider chefs de délégation jugent opportuns. appropriate. The agenda and relevant documents relating to any Regular Meeting or Urgent Meeting (together, Meetings) should wherever possible be provided to each delegation in advance. 17.6. L'ordre du jour et la documentation nécessaire relative à toute Réunion ordinaire ou Réunion urgente (ci-après, conjointement « les Réunions ») sont, dans la mesure du possible, communiqués à l'avance à chaque délégation. 17.7. Toute Réunion peut se tenir par conférence téléphonique ou à l'aide de tout équipement de communication similaire. Any Meeting may be held by conference telephone or similar communication equipment. 17.8. Sauf accord contraire entre les participants, toutes les Réunions se tiennent à la fois en anglais et en français. Unless otherwise agreed by all participants, all Meetings shall be held in both English and French. If more than six months have elapsed/will elapse between Meetings, the heads of delegation shall immediately inform the Authorities and explain why such a gap has occurred/will occur. 17.9. Dans le cas où plus de six mois se seraient écoulés ou pourraient s'écouler entre deux Réunions, les chefs de délégation en informent immédiatement les Autorités et justifient la raison d'un tel délai d'inactivité. 17.10. Lors de toute Réunion du service permanent, le quorum est fixé à deux membres de chaque délégation, y compris le responsable de chaque délégation nationale, ou la personne nommée pour assurer temporairement ce rôle. Chaque Autorité prend les mesures nécessaires pour que le quorum soit atteint. The quorum for any Meeting of the permanent service shall be two members of each delegation, including the head of each national delegation or the person nominated to act temporarily in his or her place. Each Authority shall take all reasonable steps to ensure participation of a quorate delegation at Meetings. 17.11. Sur accord des chefs de délégation, le service permanent peut auditionner toute personne de son choix. By agreement between the heads of delegation, the permanent service may hear from any person it may choose. ## 18. Prise De Décision Lors Des Réunions : Decision Making At Meetings: 18.1. Lors de l'instruction d'une affaire (ci-après « l'Affaire concernée »), le service permanent suit la procédure décrite au présent paragraphe : Where the permanent service is required to consider any matter (the Relevant Matter), it shall follow the procedure set out in this paragraph: 18.1.1. Dans la mesure du possible, le service permanent examine les éléments de preuves relatifs à l'Affaire concernée lors de la Réunion ordinaire suivante ; wherever possible, the permanent service shall examine the evidence relating to the Relevant Matter at the next Regular Meeting; where the Relevant Matter is urgent, the permanent service shall convene an Urgent Meeting or Meetings to expedite full and timely consideration of the Relevant Matter; 18.1.2. Lorsque le dossier en cause est urgent, le service permanent organise une Réunion urgente ou des Réunions afin de permettre de prendre pleinement et rapidement connaissance de l'Affaire concernée ; 18.1.3. Une fois que le service permanent a émis ses conclusions suite à l'examen de l'Affaire concernée, il prépare un rapport destiné soit au comité binational soit le cas échéant aux Collèges, détaillant ses recommandations ; et after the permanent service has concluded its consideration of the Relevant Matter, it shall prepare a report to the bi-national committee or the Boards (as applicable), setting out its recommendations; and if the permanent service is unable to reach complete agreement, it shall convene a further Urgent Meeting at which the heads of delegation shall reconsider the Relevant Matter. If after such Meeting the heads of delegation are unable to reach complete agreement, the final report shall include a concise account of the areas of agreement and disagreement between the delegations. 18.1.4. Si le service permanent est dans l'incapacité d'aboutir à un accord complet, il organise une autre Réunion urgente au cours de laquelle les chefs de délégation examinent de nouveau l'Affaire concernée. Dans le cas où, suite à cette Réunion, les chefs de délégation ne parviennent pas à un accord complet, le rapport final inclut un descriptif concis des points d'accord et des points de désaccord entre les délégations. 18.2. Tout acte ou décision du service permanent est authentifié par la signature de son président, ou par une personne désignée pour officier temporairement à sa place. Any decision or other act of the permanent service shall be authenticated by the signature of the chair of the permanent service, or a person nominated to act temporarily in his or her place. ## 19. Soumission Des Rapports : Submission Of Reports: Lorsque le service permanent doit soumettre un rapport, celui-ci Where the permanent service is required to submit a report, such report doit : shall: 19.1. Etre rédigé en anglais et en français ; be in writing in English and French; 19.2. Etre unique et refléter les opinions du service permanent dans son ensemble ; et be a single report reflecting the views of the permanent service as a whole; and 19.3. Présenter de manière concise tous les points d'accord et, le cas échéant, de désaccord entre les délégations. where applicable, concisely set out any areas of agreement and disagreement between the delegations. ## 20. Langues : Languages: 20.1. La langue de travail de la délégation de l'ORR est l'anglais. La langue de travail de la délégation de l'ARAFER est le français. The working language of the ORR delegation to the permanent service shall be English. The working language of the ARAFER delegation to the bi-national committee shall be French. 20.2. Les textes rédigés en anglais et en français font également foi. English and French texts shall be equally authoritative. ## 21. Autres Dispositions : Other Provisions: 21.1. Chaque année de fonctionnement du service permanent débute au 1er avril de l'année en cours et dure douze mois calendaires, pour se terminer au 31 mars de l'année suivante. Each operational year of the bi-national committee shall commence on 1 April of the relevant year and be for a period of twelve calendar months ending on 31 March of the following year. 21.2. L'un ou l'autre des chefs de délégation du comité binational peut proposer une modification de ces règles à tout moment. Si ladite modification est adoptée par le service permanent, elle est soumise au comité binational pour validation. Elle entre en vigueur dès sa validation par le comité binational. Amendment to these rules may be proposed at any time by the head of either delegation. If such an amendment is adopted by agreement of the permanent service, it shall be submitted to the bi-national committee for approval. It shall come into force when the approval of the bi-national committee has been notified to the permanent service.
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## Forest Park Glasdir Parc Coedwig **Coed Y Brenin** Forest Park Llwybr Copr **Glasdir** Copper Trail Llwybr Copr Glasdir Glasdir Copper Trail Uchafbwyntiau: Highlights: DISGRIFIAD: O'r maes parcio, croeswch y fordd i weirglodd a safle picnic Ty'n-y-buarth, a dilynwch y llwybr coch i lawr at Afon Babi lle, yn ôl traddodiad lleol, y cipiodd y tylwyth teg faban farmwr lleol a gadael un o'u babanod eu hunain yn ei le. DESCRIPTION: From the car park cross the road into Ty'n y Buarth meadow and picnic site and follow the red trail down to the Afon Babi - river of the baby - where local folklore says a fairy baby was exchanged for a local farmers child. Follow the waymarkers around the old copper workings rising, along a rough path with long flights of steps, to the upper tier where a viewpoint ofers a vista over the whole site and river valley below. Dilynwch y nodwyr llwybr o amgylch yr hen weithfeydd copr gan godi, ar hyd llwybr garw â rhes hir o risiau, i fyny i'r haen uwch a'r olygfan sy'n cynnig golygfa ar draws yr holl safle a chwm yr afon islaw. ## Mp3 to hear about the little mine with worldwide impact. ## Llwybr Hygyrch Glasdir Glasdir Accessible Trail Rydych Yma You Are Here Hygyrch Wheelchair-user access to the viewpoint is available from the disabled-only Pont Llam yr Ewig car park next to the upper bridge across the River Babi. The trail is built to 'Countryside for All' standards with an easy gradient (max 10% /1 in 10). Gall defnyddwyr cadeiriau olwyn gael mynediad at yr olygfan o faes parcio Pont Llam yr Ewig, sydd ar gyfer yr anabl yn unig. Mae hwn wedi'i leoli wrth ymyl y bont uchaf sy'n croesi Afon Babi. Mae'r llwybr wedi'i adeiladu'n ôl safonau 'Cefn Gwlad i Bawb' gyda graddiant rhwydd (10% / 1 mewn 10 ar y mwyaf). Please keep to the trail as mine workings are dangerous places with sheer drops. Cadwch at y llwybr hwn gan fod mwyngloddiau yn beryglus ac mae sawl dibyn yma. The forest park is a mixed-use site, please be aware that you may come across walkers, dogs, mountain bikes, horses or vehicles at any time. Mae'r parc coedwig yn safle o ddefnydd cymysg, byddwch yn ymwybodol fod yna bosibilrwydd y dewch ar draws cerddwyr, cw ˆ n, beiciau mynydd, cefylau neu gerbydau ar unrhyw adeg. Atgynhyrchir y map hwn o ddeunydd yr Arolwg Ordnans gyda chaniatâd Arolwg Ordnans ar ran Rheolwr Llyfrfa Ei Mawrhydi. © Hawlfraint y Goron a hawliau cronfa ddata 2015 Arolwg Ordnans 100019741. 2015 This map is based upon Ordnance Survey material with the permission of Ordnance Survey on behalf of the controller of Her Majesty's Stationary Ofce © Crown copyright and database rights 2015 Ordnance Survey 100019741. 2015 Croeso i Glasdir Croeso i Glasdir, neu'r 'tir glas'. Dilynwch ein harwyddion a chroeswch y fordd at ein safle picnic hyfryd ger y nant. Beth am ddilyn ein llwybr sydd wedi'i farcio a darganfod yr hen fwynglawdd copr? Rydym wedi creu mynediad pob gallu i'r olygfan o faes parcio Pont Llam yr Ewig ger y bont uchaf ar draws Afon Babi (gweler y map). Welcome to Glasdir Welcome to Glasdir, which means 'very green land'. Follow the waymarkers across the road to our lovely streamside picnic site. Why not follow our waymarked trail to discover the old copper mine? We have created all-ability access to the viewpoint from the Pont llam yr ewig car park next to the upper bridge across the Babi (see map). ## Download Our Free Apps For Android And Iphone Lawrlwythwch Ein Hapiau Di-Dâl Ar Gyfer Android Ac Iphone Cymru | Wales ® Placestogo I ganfod lleoedd eraill ardderchog CNC y gellir ymweld â hwy yng Nghymru. To find other great NRW places to visit in Wales. ## Accessible Cymru | Wales ® Placetales I ganfod nodweddion hynod ddifyr yng nghoedwigoedd CNC a Gwarchodfeydd Natur Cenedlaethol. To discover fascinating features in NRW forests and National Nature Reserves. Dilynwch y stori Follow the story
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## Miniscale User Guide Contents | | Section | Page no | |-------------------------------------------------------|------------|------------| | Preface | | 3 | | | | | | Contact details | 3 | | | | | | | Use of the product | | 3 | | | | | | Purpose and disclaimer | 3 | | | | | | | Copyright in this guide | 3 | | | | | | | Data copyright and other intellectual property rights | 4 | | | | | | | Trademarks | | 4 | | | | | | Back-up provision of the product | 4 | | | | | | | Using this guide | 4 | | | | | | | Chapter 1 | | | | | | | | Introduction | 5 | | | | | | | Applications | | 5 | | | | | | System requirements | 5 | | | | | | | Computer hardware | 5 | | | | | | | Computer software | | 6 | | | | | | Supply and formats | 6 | | | | | | | Chapter 2 | | | | | | | | High-level product overview | 8 | | | | | | | Scale | 8 | | | | | | | Coverage | | 8 | | | | | | Source of MiniScale | 8 | | | | | | | Features | 8 | | | | | | | Currency | | 9 | | | | | | Resolution | 9 | | | | | | | Georeferencing | 9 | | | | | | | Data compression | 10 | | | | | | | Image compression | | 10 | | | | | | Lossless compression | 10 | | | | | | | Lossy compression | 10 | | | | | | | TIFF | | 10 | | | | | | Revision | 10 | | | | | | | Annexe A | | | | | | | | Product and service performance report form | 11 | | | | | | ## Preface This user guide (hereafter referred to as the guide) is designed to provide an overview of MiniScale (hereafter referred to as the product) and it gives guidelines and advice on how a customer might derive the maximum benefit from the product. It assumes a general knowledge of geographic information. If you find an error or omission in this guide, or otherwise wish to make a comment or suggestion as to how we can improve it, please contact us at the address shown below or complete the product and service performance report form at annexe A and return it to us. ## Contact Details Our Customer Service Centre will be pleased to deal with your enquiries: Customer Service Centre Ordnance Survey Adanac Drive SOUTHAMPTON SO16 0AS General enquiries (calls charged at local rate): +44 (0)8456 05 05 05 Dedicated Welsh Language HelpLine: 08456 05 05 04 Textphone (deaf and hard of hearing users only please): +44 (0)23 8079 2906 customerservices@ordnancesurvey.co.uk www.ordnancesurvey.co.uk This document has been screened in accordance with Ordnance Survey's Equality scheme. If you have difficulty reading this information in its current format and would like to find out how to access it in a different format (Braille, large print, computer disk or in another language), please contact us on: +44 (0)8456 05 05 05. ## Use Of The Product The product is made available to you and your organisation on the terms of the OS OpenData Licence at www.ordnancesurvey.co.uk/opendata/licence. If there is any inconsistency between the terms of the licence and this guide, the terms of the licence prevail. ## Purpose And Disclaimer This guide is provided for guidance only and does not constitute any warranty, representation, undertaking, commitment or obligation (express or implied) about the product or its suitability for any particular purpose. It is your responsibility to ensure that this product is suitable for your intended purpose. Ordnance Survey does not accept any liability (whether for breach of contract, negligence or otherwise) for any loss or liability you or any third party may suffer in relying on this guide and any guidance, suggestion, advice or explanation provided in it. Ordnance Survey's liability to you in relation to the product is limited, as set out in the OS OpenData Licence. We may change the information in this guide at any time without notice. We do not accept responsibility for the content of any third party websites, referenced in, or accessed through, this guide or through the Ordnance Survey website. ## Copyright In This Guide This guide is © Crown copyright 2012. You may copy or distribute any part of this guide to support the use of OS OpenData, including for your personal use, use in your organisation or business, or for use with, or incorporation in, your product or application. ## Data Copyright And Other Intellectual Property Rights The Crown (or, where applicable, Ordnance Survey's suppliers) owns the intellectual property rights in the data contained in this product. You are free to use the product on the terms of the OS OpenData Licence, but must acknowledge the source of the data by including the following attribution statement: Contains Ordnance Survey data © Crown copyright and database right 2012. ## Trademarks Ordnance Survey, the OS Symbol and MiniScale are registered trademarks of Ordnance Survey, the national mapping agency of Great Britain. Adobe, Acrobat Reader, Adobe Illustrator and Adobe Photoshop are registered trademarks of Adobe Systems Incorporated. ArcInfo, ArcView and ESRI are registered trademarks of Environmental Systems Research Institute Inc. MapInfo is a registered trademark of MapInfo Corporation. Unisys is a registered trademark of Unisys Corporation. Intel is a registered trademark of Intel. ## Back-Up Provision Of The Product You are advised to copy the supplied data to a back-up medium. ## Using This Guide The documentation is supplied in portable document format (PDF) only. Free Adobe® Acrobat Reader® software, which displays the guide, incorporates search and zoom facilities and allows you to navigate within. Hyperlinks are used to navigate between associated parts of the guide and to relevant Internet resources by clicking on the blue hyperlinks and the table of contents. If you are unfamiliar with any words or terms used and require clarification please refer to the glossary at the end of the document. ## Chapter 1 Introduction Ordnance Survey's MiniScale is a small-scale product designed for use within desktop graphic applications, providing geographic context for the whole of Great Britain. MiniScale shows the major boundaries, lines of communication, settlements and physical features of Great Britain. MiniScale is a vector graphic created using desktop publishing software so it can be customised and converted into a wide variety of graphic formats. Alternatively, the raster version can also be used within a geographical information system (GIS) as a backdrop. MiniScale is aimed at any customer that requires a high-quality, visually appealing map for their documents and publications, whether a magazine, brochure or web pages. An extract of MiniScale, with default layers and styles, is shown below. ## Applications Typical ways in which MiniScale could be used include: - Location maps for websites or promotional material, showing head offices or distribution of assets across Great Britain. - High-level route planning along the major roads and railways. - As an overview or entry screen map within an Intranet or Internet web mapping service. - The smaller scale of MiniScale also lends itself to applications that need to show information at a regional or county/unitary level, where a larger-scale map would be too detailed or cluttered. ## System Requirements Computer Hardware This product may be used on a wide range of hardware platforms (provided sufficient memory and storage facilities are available), varying from desktop PCs using appropriate software or CAD to mainframe computers with specialised translators and applications. ## Computer Software MiniScale is supplied as inert data and does not include software for data manipulation. To exploit fully the potential of MiniScale, it is necessary to use appropriate application software. ## Supply And Formats The data is supplied on CD and is updated and released annually in January. It is supplied as the whole of Great Britain with Orkney and the Shetland Islands shown in their correct position. Some European coastline is supplied to give context. MiniScale is supplied in the following formats (file sizes are approximate). - Adobe Illustrator® CS3 or higher, file size 25 Mb - Editable Encapsulated Post Script (EPS), file size 70 Mb - Tiff LZW compression, file size 20–40 Mb The Illustrator file contains the layers and styles required to customise the product. This file also contains additional layers, such as sea depths, height colouring and other information that doesn't appear on the default style for MiniScale. Some of the ways that MiniScale can be customised is shown in the raster examples provided. The Illustrator file requires the font 'Source Sans Pro'. This is a free open source font created by Adobe. Available from Adobe and SourceForge; http://sourceforge.net/projects/sourcesans.adobe/ MiniScale with height layers see legend. MiniScale with shaded relief (tiff images available from supplementary file supplied). More information on formats is available in the technical specification. ## High-Level Product Overview Scale 1:1 000 000 (1 mm = 1 km) MiniScale is designed to be used at viewing scales between 1:700 000 and 1:2 000 000. ## Coverage Great Britain ## Source Of Miniscale MiniScale is derived from the 1:250 000 scale topographical digital database. ## Features Features Layer description Style and content notes Boundaries National names For example, England, Wales, Scotland County or unitary names For example, Dorset, Hampshire and so on National boundaries Dark grey line County or unitary boundaries Light grey line Settlements Urban primary names Primary destination towns with a large urban extent Other urban names Other towns with a large urban extent Primary town names Primary destination towns Other town names Selected towns and villages useful to MiniScale Urban area fill Depicts extent of large urban areas Alternative urban symbol Used to replace urban area fills if required Primary town symbol Large yellow dot Other town symbol Small yellow dot Communications Motorway numbers Numbered where space permits Primary A road numbers Numbered where space permits Other A road numbers Numbered where space permits Motorway junction numbers Access (full or limited) is distinguished by colour Service areas 24 hour services Motorways Solid blue line with white centreline Primary A roads Green line (dense urban areas may show only a selection) Primary dual-carriageway Significant lengths shown with yellow centre line Other A roads Pink line (dense urban areas may show only a selection) Roads under construction Only significant projects shown Airports Symbol (with or without customs). Named when different to associated town, for example, Heathrow Domestic ferry routes Time of crossing shown where space permits Railway lines Passenger routes only (main and other). Solid black line Features Layer description Style and content notes Physical Geographic feature names Selected names, for example, Land's End, Pennines, Isle of Skye Major mountain peaks Selected, for example, Ben Nevis Water feature names Selected names, for example, Bristol Channel, Loch Lomond Green fill and named, for example, Cotswolds, South Downs Scenic areas and Areas of Outstanding Natural Beauty (AONBs) Forest Parks and National Parks Green fill and named, for example, Dartmoor, New Forest Lakes and lochs Selection of major ones only Rivers Selection of major ones only: Thames, Severn, Trent, Dee and so on. Coastline High water mark only Background (land) tint Broken into shapes that match the boundaries Background (sea) tint Light blue fill Other National Grid 100 km grid and reference letters Longitude and latitude lines Great Britain Height tints 75, 200, 400, 600, 800 metres Extras Provided as separate files to fit MiniScale Sea depths 60,120,300,600 metres Legend and scale bar Inset box Shaded Relief 254 dpi, 1:1 000 000 scale NOTE: Some layer combinations may not be compatible. Relief tiles in separate file ## Currency MiniScale data is derived from the latest available version of Ordnance Survey's 1:250 000 database. The MiniScale dataset is refreshed annually. ## Resolution The master graphic (postscript) files are also provided as raster images at a resolution of ten (10) dots per mm (dpmm) - or 254 dots per inch (dpi) and a pixel is one hundred (100) metres on the ground. This resolution maintains the necessary clarity of text. ## Georeferencing To be able to view each tile in the correct geographic relation to the National Grid and to each other, the tiles must be georeferenced. GIS typically provide georeferencing as part of their functionality, but for each set of tiles it is necessary to provide the information on how the tiles should be ordered. Ordnance Survey provides this information in a set of georeferencing files, also known as world files. A complete set for MiniScale is available to download free of charge from the MiniScale product page on the Ordnance Survey website; these are also supplied with the product written to CD. There are several different types of world file. Prior to downloading one of the sets, customers are advised to check with their system suppliers to find out which type their system supports. The conventions behind the files' creation can be found in chapter 1 of the technical specification. By using the conventions outlined there, this means that other datasets using the same conventions can be imported into the same GIS to add value to the raster map. So, for example, overlaying a routing or logistics network over the map or displaying a customer's demographic information. The georeferencing files should be saved in the same directory as the files of the map tiles themselves. For this product a single TFW and TAB file is available to geographically position the data. ## Data Compression TIFF data volumes are influenced by the level of data compression. Approximate storage volumes: 16–80 Mb using LZW compression. ## Image Compression When an image is compressed, duplicated data that has no value is removed or saved in a shorter form, reducing a file's size. For example, if large areas of water are the same tone, only the value for one pixel needs to be saved, together with the locations of the other pixels with the same colour. When the image is edited or displayed, the compression process is reversed. When raster is compressed, not only are the data volumes reduced but the user can download, display, edit and transfer images more quickly. There are two forms of compression: *lossless* and *lossy*. ## Lossless Compression As its name suggests, lossless compression does not lose information within an image. A lossless compression retains the original quality of an image when it is uncompressed. This process doesn't provide much compression, so file sizes remain large. Lossless compression is used mainly where detail is important, such as when planning to make large prints. ## Lossy Compression This process degrades images to some degree, meaning that the decompressed image is not quite the same as the original. The more an image is compressed, the more degraded it becomes. In many situations, such as posting images on the Internet or printing small- to medium-sized prints, the image degradation is not so obvious. If a lossy compressed image is over enlarged the degradation will become apparent. ## Tiff TIFF is one of the most commonly used *lossless* image formats. TIFF is primarily designed for raster data interchange and is supported by numerous image-processing applications. This permits much more efficient access to very large files that have been compressed. ## Revision The MiniScale master dataset is updated and released annually in January. ## Introduction Purpose Of This Specification And Disclaimer This is the technical specification (hereafter referred to as the specification) applicable to the MiniScale (hereafter referred to as the product). We may change the information in this specification at any time. We do not accept responsibility for the content of any third party websites referenced in or accessed through this guide or through the Ordnance Survey website. ## Copyright In This Specification This guide is © Crown copyright 2010. You may copy or distribute any part of this specification to support the use of OS OpenData, including for your personal use, use in your organisation or business, or for use with, or incorporation in, your product or application. ## Chapter 1 Technical Software Requirements MiniScale requires Illustrator CS3 or higher running on a PC or Apple® Macintosh® platform. Other EPS-compatible software can also be used by importing the EPS files. Ordnance Survey does not specify hardware requirements as it is dependent on the software and applications within which the data will be used. Customers should contact their system or software supplier for advice. ## | Specification | MiniScale | |-----------------------------------------------------------------------------------------------|----------------------------| | Data source | | | MiniScale is a redrawn and simplified product designed to meet the needs of the desktop | | | graphics industry. Historically it is based on a variety of Ordnance Survey digital datasets; | | | however the graphic output is now updated from the 1:250 000 vector data base. | | | Availability | | | Great Britain | | | Scales | | | 1:1 000 000 (1 mm = 1 km) | | | MiniScale is designed to be used at viewing scales between 1:700 000 and 1:2 000 000 | | | Physical size | | | (at scale above) | | | Great Britain = 700 mm wide by 1 300 mm high (with Shetland Islands in position). Orkney | | | and Shetland can be inset to reduce the height to about 1 000 mm. | | | Resolution | | | Postscript = resolution of output device. Raster = 254 dots per inch | | | Supply media | | | Download or CD | | | Data type | | | Desktop vector graphic (Illustrator and EPS vectors), CMYK colour space | | | Colour | | | Raster LZW data is RGB colour | | | | | | Data structure and size | Postscript vector | | | Transfer format/s | | are approximate | | | Transfer format/s | Storage volumes | | are approximate | | | | | | Editable EPS | Editable 70 Mb | | TIFF LZW | | | compressed 254 dpi | | | | | | TIFF 20–40 Mb | | | (Choice of four | | | example styles) | | | | | | | | | Illustrator CS3 | Illustrator 25 Mb | | Layers and styles | | | Yes, see | features layers and styles | | | | | Update interval | | | Great Britain data revised annually | | | British National Grid (OSGB36) | | | Coordinate reference | | | system | | ## Fonts The Illustrator file requires the font 'Source Sans Pro'. This is a free open source font created by Adobe. Available from Adobe and SourceForge; http://sourceforge.net/projects/sourcesans.adobe/ ## Colours The default colours for MiniScale vectors are four-colour process (CMYK). MiniScale raster examples supplied as TIFF LZW (RGB). ## National Grid A 100 km grid is provided as a separate layer. This is set as an invisible layer by default. The 100 km grid is constructed from individual squares to enable them to be used easily for clipping and so on. A further non-printing layer holds the 100 km letter references to ease identification of the squares. For Illustrator users the rulers have been set to match the zero point for National Grid. When the file is used at 1:1 000 000 scale, and providing the rulers or page position has not been moved, the measurements can be used as National Grid coordinates (preferences must be set to millimetres). For example: the tip of Flamborough Head has an Illustrator coordinate of x = 525.85 mm and y = 470.51 mm, which corresponds to a National Grid reference of 5258 4705 (or TA 258 705). In Illustrator the y value will be a minus value. ## National Grid Coordinates For The Raster Versions The raster files have been provided for geographical information system (GIS) users who might otherwise be unable to use the Illustrator or EPS files. The origin (lower-left corner) of the GB file is 0, 0 km and it finishes at 700 km east and 1 300 km north of the National Grid origin. This equates, at 254 dpi, to 7 000 pixels wide by 13 000 pixels high (100 km = 1 000 pixels). ## Georeferencing File Georeferencing files allow tiles of map data to be located in their correct geographic position when loaded into a GIS. This is achieved by loading in files alongside the data files that contain the National Grid corner coordinates for each tile. This is especially useful if more than one tile of data is being loaded at once, as it allows for a true geographic depiction of the data. When raster data is supplied to customers, it is not georeferenced in any way. This means that tiles will not be set up in geographic relationship to each other when loaded into a GIS. Included on the CD is a TIFF World File (TFW), which can be used to georeference raster data in ESRI® ArcView® and ArcInfo®, together with a TAB file for use with MapInfo®. These Georeferencing files can also be downloaded from the MiniScale web pages in the technical pages. For this product a single TFW and TAB file is available to geographically position the data. ## Using Add-On Files/Merging Earlier Files The shaded relief tiles are provided in a second Illustrator file. The document size and position of this relief file matches that of the main MiniScale Illustrator file. Use the 'paste in front' command to copy the relief into the right position on the MiniScale map. Position the relief layer for desired effect. Use the 'multiply' setting to make detail underneath show through. If the document size and position have been changed then use the 100 km squares to fit the relief tiles to. ## Features, Layers And Styles | Features | Layer description | |------------------------------------------------------|------------------------------| | Boundaries | | | National names | | | For example, England, Wales, Scotland | | | | County or unitary names | | For example, Dorset, Hampshire and so on | | | | National boundaries | | Purple line | | | | County or unitary boundaries | | Light grey line | | | Settlements | | | Urban primary names | | | Primary destination towns with a large urban extent | | | | | | | Other urban names | | Other towns with a large urban extent | | | | Primary town names | | Primary destination towns | | | | Other town names | | Selected towns useful to MiniScale | | | | Urban area fill | | Depicts extent of large urban areas | | | | Alternative urban symbol | | Used to replace urban area fills if required | | | | Primary town symbol | | Large yellow dot | | | | Other town symbol | | Small yellow dot | | | Communications | | | Motorway numbers | | | Numbered where space permits | | | | Primary A road numbers | | Numbered where space permits | | | | Other A road numbers | | Numbered where space permits | | | | Motorway junction numbers | | Access (full or limited) is distinguished by colour | | | | Service areas | | 24 hour services on motorways and primary roads only | | ## | Features | Layer description | |----------------------------------------------------------|---------------------------------| | | Motorways | | Solid blue line with white centreline | | | | Primary A roads | | Green line (significant lengths of dual carriageway | | | shown with yellow centreline) | | | | | | | Other A roads | | Pink line | | | | Roads under construction | | Only significant projects shown | | | | | | | Airports | | Symbol (with or without customs). Some, for example, | | | Heathrow, are named | | | | | | | Domestic ferry routes | | Time of crossing shown where space permits | | | | | | | Railway lines | | Passenger routes only. Solid black line | | | Physical | | | Geographic feature names | | | Selected names, for example, Land's End, Pennines, | | | Isle of Skye | | | | | | | Water feature names | | Selected names, for example, Bristol Channel, Loch | | | Lomond | | | | | | Green fill and named, for example, Cotswolds, South | | | Downs | | | | | | | | | Scenic areas and Areas of | | | Outstanding Natural Beauty | | | (AONBs) | | | | Forest Parks and National Parks | | Green fill and named, for example, Tay, Dartmoor | | | | | | | Lakes and lochs | | Selection of major ones only | | | | | | | Rivers | | Selection of major ones only; Thames, Severn, Trent, | | | Dee and so on. | | | | Coastline | | High water mark only | | | | | | | Background (land) tint | | Broken into shapes that match the boundaries | | | | | | | Background (sea) tint | | Light blue fill | | | | | | Other | | | National Grid | | | 100 km grid and reference letters | | | | | | Longitude and latitude lines | | | Great Britain | | | | | | Layer tints | | | 75, 200, 400, 600, 800 metres | | | | | | Sea depths | | | 60,120,300,600 metres | | | Extras | | | | | | | | | Some layer combinations | | | may not be compatible | | | Legend and scale bar | | | Inset box | | | | | | Shaded relief | | | 254 dpi 1:1 000 000 scale (in separate Illustrator file) | | ## Chapter 2 Managing Miniscale Files MiniScale has been created as a vector data graphic map favourable for use within desktop graphic applications. MiniScale's use within GIS will be limited to backdrop mapping when using the TIFF only. MiniScale is supplied on one CD-ROM as a single data file in a variety of industry-standard formats. The data is held in layers, with styled objects for easy customisation of map images. These can be easily converted to web images using appropriate software (not supplied). ## File Formats MiniScale is maintained using Adobe Illustrator software. All the capabilities of editing and styling MiniScale may not be available in other applications. Raster versions are also provided at 254 dpi. The TIFFs are LZW compressed and in RGB colours. New raster files can be created, styled and layered as required by using the Illustrator data. ## Image File Directory (Tiff) The image file directory for TIFF will contain the following entries: ## Tag 254 (Newsubfiletype) An indication of the kind of data contained in this sub-file, for example, value = 0 ## Tag 256 (Imagewidth) The number of columns in the image, the number of pixels per row, for example, value = 7000 ## Tag 257 (Imagelength) The number of rows of pixels in the image, for example, value = 13000 ## Tag 258 (Bitspersample) Number of bits per component, for example, value = 8 ## Tag 259 (Compression) Compression scheme used on the image data, for example, value = 5 (LZW) ## Tag 262 (Photo.Interpretation) The colour space of the image data, for example, value = 2 (RGB Palette). ## Tag 273 (Stripoffsets) For each strip, the byte offset of that strip, for example, 1st 4 values = 28168 65970 103868 141504 ## Tag 274 (Orientation) value = 1 ## Tag 277 (Samplesperpixel) value = 3 ## Tag 278 (Rowsperstrip) The number of rows in each strip, for example, value = 12 Tag 279 (StripByteCounts) For each strip, the number of bytes in that strip after compression, for example, 1st 4 values = 37801 37898 37635 37702 ## Tag 282 (Xresolution) The number of pixels per resolution unit in the image width, for example, value = 254/1 ## Tag 283 (Yresolution) The number of pixels per resolution unit in the image length, for example, value = 254/1 ## Tag 284 (Planarconfiguration) value = 1 ## Tag 296 (Resolutionunit) Units used for resolution, for example, value = 2 (Inch) ## Tag 305 (Software) value = Adobe Photoshop CS5 Macintosh ## Tag 306 (Datetime) Date and time of image creation, for example, value = 2006:06:30 12:38:41 ## Tag 317 (Predictor) value = 2 ## Tag 700 (Unknown) 1st 4 values = 60 63 120 112 ## Tag 33723 (Unknown) 1st 4 values = 28 1 90 0 Tag 34377 (Unknown) 1st 4 values = 56 66 73 77 Tag 34665 (Unknown) value = 35853820 Tag 34675 (Unknown) 1st 4 values = 0 0 2 48 NOTE: The values given above are relevant to MiniScale data. ## Tiff Miniscale Colour Image Directory (Tiff) Tag number TIFF 8-bit LZW compressed File Byte Order : II (Little-endian) Magic Number : 42 Number of fields in IFD : 23 NewSubfileType 254 0 Image Width 256 7000 ImageLength 257 13000 BitsPerSample 258 8 ## | Compression | 259 | 5 (LZW) | |-------------------------------|------------------------------|----------------------------------| | Photo.Interpretation | 262 | 2 (RGB Palette) | | StripOffsets | 273 | 1st 4 values = 52406 53352 54298 | | 55246 | | | | Orientation | 274 | 1 | | SamplesPerPixel | 277 | 3 | | RowsPerStrip | 278 | 12 | | StripByteCounts | 279 | 1st 4 values = 945 945 947 947 | | XResolution | 282 | 254/1 | | YResolution | 283 | 254/1 | | PlanarConfiguration | 284 | 1 | | ResolutionUnit | 296 | 2 (Inch) | | Software | 305 | | | Adobe Photoshop CS5 Macintosh | | | | DateTime | 306 | 2008:09:20 11:20:04 | | Predictor | | | | 317 | 2 | | | Unknown | | | | 700 | 1st 4 values = 60 63 120 112 | | | Unknown | | | | 33723 | 1st 4 values = 28 1 90 0 | | | Unknown | | | | 34377 | 1st 4 values = 56 66 73 77 | | | Unknown | | | | 34665 | 35853820 | | | Unknown | | | | 34675 | 1st 4 values = 0 0 2 48 | | The tag values listed in the above table are a selection relevant to MiniScale Relief 1 Intel® TIFF LZW raster data. It should be noted that customers can access tag information from a raster file image by right clicking on a TIFF data image and looking at properties, and then left clicking on summary. ## Ireland And Channel Islands Parts of the French and Irish coastlines have been included to help give context to the position of Great Britain. Although reasonably accurate, they use different map projections to GB and fall outside the National Grid. Their position and scale are therefore approximate. This also applies to the Channel Islands. ## Boundaries National, county and unitary authority boundaries are shown. County and unitary boundaries are depicted by the same style. Boundaries within the London Authority area are shown on a separate optional extras layer. The boundaries are held as a 'grouped' object in Illustrator. This is to allow the whole boundary layer to overlay the map with transparency. ## Depiction Of Roads And Towns MiniScale shows three classes of roads: motorway, primary A road and other A road. The primary (green) roads are the recommended through routes that complement the motorway system. Where there are significant lengths of dual carriageway, they have been shown with a dual carriageway style. The primary roads link primary route destination towns, which appear on green road signs. In congested urban areas some roads have been omitted for clarity. MiniScale settlements are shown in three levels: those with large urban extent (with separate layers for primary and non-primary names), primary route destination towns (large dot), and other towns useful to the map (small dot). Urban names have been given a range of point sizes and weights to visually differentiate them. No statistical relevance, such as size or population, should be inferred from this. Primary route destination names are all the same regardless of their physical size: thus the hamlet of Scotch Corner appears the same as a major town like Andover. ## Welsh Spellings At the scale used for MiniScale it is impractical to show all the Welsh names with dual spellings (English and Welsh). However, the Illustrator file contains an extra layer of Welsh names that can be used to replace the English ones. This requires manual intervention, since the Welsh names are in the same position as the English names. ## Shaded Relief File Raster examples of MiniScale with shaded relief are provided to show what can be achieved with the Illustrator files. The relief file is embedded with individual 100 km shaded relief images fitted to the National Grid. These can be added to the main MiniScale map by using Illustrator's 'Paste in front' option. Use the 'multiply' setting to control the transparency and strength of the shaded relief. ## Annexe A Glossary accuracy The closeness of the results of observations, computations or estimates to the true values or the values accepted as being true. Accuracy relates to the exactness of the result, and is the exactness of the operation by which the result is obtained. boundary A boundary is the limit of a predefined and established area whose limit is determined by one or more lines, for example, county area boundary and DLUA boundary. byte A unit of computer storage of binary data usually comprising 8 bits, equivalent to a character. Hence megabyte (Mb) and gigabyte (Gb). ## Cad Computer-Aided Design Character A Distinctive Mark; An Inscribed Letter; One Of A Set Of Writing Symbols. Character Code The Binary Representation Of A Single Element Of A Character Set; For Example, Ebcdic, Ascii. compact disc-read only memory (CD-ROM) A data storage medium. A 12-cm disc similar to an audio CD. Ordnance Survey uses the writable CD, a WORM (write once, read many) device. The digital bits are encoded into a vegetable dye and, once written, cannot be erased by overwriting with subsequent data. A laser reads the disc. ## Coordinate Pair A Coordinate Pair Is An Easting And A Northing. coordinates Pairs of numbers expressing horizontal distances along original axis. Alternatively, that triplets of numbers measuring horizontal and vertical distances. Row and column numbers of pixels from raw imagery are not considered coordinates for the purpose of the standard. copyright Copyright is a legal property right that enables the creator of an original work to protect it from unauthorised use. Through the *Copyright, Designs and Patents Act 1988*, Crown copyright continues to subsist in all Ordnance Survey products until the end of the period of 50 years from the end of the year in which they were published, and in the case of data from the end of the year in which it was extracted from the Ordnance Survey database. Crown copyright is vested in The Controller of Her Majesty's Stationery Office, who has delegated powers to the Director General, Ordnance Survey for the administration of copyright in publications and data, including the determination of terms and conditions under which permission for their reproduction is given. ## Currency An Expression Of The Up-To-Dateness Of Data. customer An organisation or individual that makes use of Ordnance Survey's data supply facilities. This includes both direct sales customers of Ordnance Survey as well as customers of Licensed Partners. It does not include anyone, or any organisation, that has access to Ordnance Survey material without charge. data A representation of facts, concepts or instructions in a formalised manner suitable for communication, interpretation or processing. data capture The encoding of data. In the context of digital mapping, this includes map digitising, direct recording by electronic survey instruments and the encoding of text and attributes by whatever means. ## data format A specification that defines the order in which data is stored or a description of the way data is held in a file or record. data model An abstraction of the real world that incorporates only those properties thought to be relevant to the application or applications at hand. The data model would normally define specific groups of entities and their attributes and the relationship between these entities. A data model is independent of a computer system and its associated data structures. A map is one example of an analogue data model. database An organised, integrated collection of data stored so as to be capable of use in relevant applications, with the data being accessed by different logical paths. Theoretically, it is application-independent, but in reality it is rarely so. dataset An Ordnance Survey term for a named collection of logically related features arranged in a prescribed manner; for example, all water features. A dataset has more internal structure than a layer and is related to another dataset only by position. ## Digital Data That Is Expressed As Numbers (Digits) In Computer-Readable Form Is Said To Be Digital. digital map Any map sold by Ordnance Survey or its agents in any form; that is on computer-readable media or as hard copy on paper and/or film or microfilm - produced mainly, or wholly, using computerised means. digital map data The digital data required to represent a map. The data includes not only map detail but also features header data, map header data and management data. ## Digital Versatile Disk (Dvd) A high capacity disk for data storage; was called Digital Video Disc; Ordnance Survey use 4.23GB. data storage capacity discs. ## Dots Per Inch (Dpi) The Resolution, Or Fineness, Of A Raster Image. eastings See rectangular coordinates. extent of the realm (EOR) The external bounding lines of Land-Line® data is EOR. The *Territorial Waters Jurisdiction Act 1878* and the Territorial Waters Order in Council 1964 confirm that EOR of Great Britain as used by Ordnance Survey is properly shown to the limit of mean low water (mean low water springs in Scotland) for the time being (except where extended by Parliament). ## Feature An Item Of Detail Within A Map That Can Be A Point Or Symbol, A Line Or Text. feature code (FC) An alphanumeric attribute code used in digital map data to describe each feature in terms of the object surveyed, its representation on the map or both. file An organised collection of related records. The records on a file may be related by a specific purpose, format or data source - the records may or may not be arranged in sequence. A file may consist of records, fields, words, bytes, characters or bits. ## Font The Style Of Text Character Used By A Printer Or Plotter. format The specified arrangement of data. For example, the layout of a printed document, the arrangement of the parts of a computer instruction, the arrangement of data in a file. geographical information system (GIS) A system for capturing, storing, checking, integrating, analysing and displaying data that is spatially referenced to the Earth. This is normally considered to involve a spatially referenced computer database and appropriate applications software. ## Gigabyte (Gb) The Equivalent Of 1 073 741 824 Bytes; A Measure Of Data Storage Capacity. Grid The Planimetric Frame Of Reference; For Example, The National Grid. Hard Copy A Print Or Plot Of Output Data On Paper Or Some Other Tangible Medium. Kilobyte (Kb) The Equivalent Of 1 024 Bytes; A Measure Of Data Storage Capacity. map The representation on a flat surface of all or part of the Earth's surface, intended to be communicated for a purpose or purposes, transforming relevant geographic data into an end-product that is visual, digital or tactile. map generalisation A reduction in map detail, so that the information remains clear and uncluttered when map scale is reduced. May also involve resampling to larger spacing and/or a reduction in the number of points in a line. map header Data at the start of the digital map file describing that data. It may contain information on the source and history of the geometric data within the map and the coordinate system in use as well as holding information essential to the management of Ordnance Survey's digital mapping system. map scale The ratio between the extent of a feature on the map and its extent on the ground, normally expressed as a representative fraction, for example, 1:1250 or 1:50 000. ## Megabyte (Mb) The Equivalent Of 1 048 576 Bytes; A Measure Of Data Storage Capacity. National Grid A unique referencing system that can be applied to all Ordnance Survey maps of Great Britain (GB) at all scales. It is based on 100 km squares covering the whole of GB based on a Transverse Mercator projection. It is used by Ordnance Survey on all post-war mapping to provide an unambiguous spatial reference in GB for any place or entity whatever the map scale. northings See rectangular coordinates. pixel In the 1:10 000 scale product a **pixel** is a single point represented by a square. ## Raster Data Attribute Data Expressed As An Array Of Pixels, With Spatial Position Implicit In The Ordering Of The Pixels. rectangular coordinates Also known as X-Y coordinates and as eastings and northings. These are two-dimensional coordinates that measure the position of any point relative to an arbitrary origin on a plane surface, for example, a map projection, a digitising table or a VDU screen. ## resolution A measure of the ability to detect quantities. High resolution implies a high degree of discrimination but has no implication as to accuracy. For example, in a collection of data in which the coordinates are rounded to the nearest metre, resolution will be 1 m but the accuracy may be ±5 m or worse. source scale The scale of the source information from which the map was digitised; that is the scale of survey for a basic-scale map, or the scale of the source map for a derived map. spatial data Data that includes a reference to a two- or three-dimensional position in space as one of its attributes. It is used as a synonym for geometric data. stipple Used to produce light or dark shading (for example, building/water fill); this is dependent on spacing of the dots - the denser the dots, the darker the effect. structured data Data within which collections of features (of any type) form objects. Topographically structured data also contains topological information defining the relationships between features and objects. TIFF TIFF is a tagged image file format-based file format for storing and interchanging raster images with the most recent version (6.0) published in 1992. ## Topographic Database A Database Holding Data Relating To Physical Features And Boundaries On The Earth'S Surface. topography Topography is the study of the physical features of the Earth. A topographic map's principal purpose is to portray and identify the features of the Earth. transfer format The format used to transfer data between computer systems. In general usage, this can refer not only to the organisation of data but also to the associated information, such as attribute codes, which are required in order to successfully complete the transfer. transfer medium The physical medium on which digital data is transferred from one computer system to another, for example, CD-ROM. ## Update The Process Of Adding To And Revising Existing Digital Map Data To Take Account Of Change. Vector A Straight Line Joining Two Data Points. Vector Data Positional Data In The Form Of Coordinates Of The Ends Of Line Segments, Points, Text Positions And So On. Volume A Physical Unit Of The Transfer Medium; That Is A Single Disc.
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## The Office Of Rail And Road 158Th Board Meeting 26 March 2019, 09:00 - 15:00 One Kemble Street, London, WC2B 4AN Non-executive members: Declan Collier (Chair), Tracey Barlow, Stephen Glaister, Anne Heal, Bob Holland, Michael Luger, Justin McCracken, Graham Mather Executive members: John Larkinson (Chief Executive), Graham Richards (Director Railway Planning and Performance); Ian Prosser (Director Railway Safety). In attendance: Dan Brown (Director Strategy and Policy), Russell Grossman (Director of Communications), Juliet Lazarus (General Counsel), Tess Sanford (Board Secretary), Carl Hetherington (Deputy Director Railway Markets and Economics) Other ORR staff in attendance are shown in the text. Item 1 WELCOME AND APOLOGIES FOR ABSENCE 1. The chair welcomed everyone to the meeting. There were no apologies. Item 2 DECLARATIONS OF INTEREST 2. No new interests were declared. Item 3 APPROVAL OF PREVIOUS MINUTES AND MATTERS ARISING 3. The minutes needed some correction and clarification but were otherwise agreed. The chair would sign them once these changes had been made. 4. The Board noted the report on the action points which included: - clarification on a future agenda item on train service performance measurement [forward programme] - a reminder about the role of RENCO1 in supporting NED recruitment. Item 4: EXECUTIVE DIRECTORS' HEADLINES AND REGULAR REPORTS 5. Ian Prosser introduced the new format of monthly report to the Board. The board welcomed the move to a shorter and more focused report and asked for trends to be shown. The board also asked the quality of reproduction and size of the text to be taken into account when circulating papers. [Action - secretariat] Ian reported on: challenges resulting from new rolling stock - both particular types and the overall scale of change; IGC's work on the Eleclink project; industry workshops on alertness devices for drivers; toilet effluent discharge. The board asked about increasing rolling contact fatigue reports: because the risk is mitigated by speed restrictions, this had implications for performance as well as safety risk. HSRC2 had discussed the unimproved performance on track worker safety with Chris Gibb (NR's non exec chair of their SHE committee) the day before. 6. Graham Richards reported on preparations for the start of CP6 including internal recruitment. The board discussed risk identification around the May 2019 timetable change and related access arrangements, which staff expected to resolve in good time. TOCs had written to the Secretary of State about their own readiness. The board took some assurance from the publication of timetables for May, but were concerned that contingency arrangements should also have been considered by NR. The board asked JLk to write to NR seeking assurance on this issue. [Action: John Larkinson] Overall the executive felt that May '19 timetable was 'on track' but would continue to be vigilant in monitoring progress to launch day. 7. Carl Hetherington reported on potential issues with the introduction of the ombudsman condition to the TOC licences and asked the Board to note that the Scotland grant letter had not yet been finalised between Transport Scotland and NR. 8. Dan Brown reported on good progress towards arrangements for the continuation of services post-Brexit, particularly a 9 month extension on driver licence validity issued by the EU. The remaining risks were outside the control of ORR/DfT including customs arrangements and passport clearance at St Pancras. Graham Richards added that plans were in place and tested for highways disruption in Kent and other ports. He had discussed with Highways England the importance of their role in getting good information to customers during any disruption and particularly in responding dynamically to any emerging issue - drawing on the recent investigation into PIDD failures on rail. 9. John Larkinson reported on progress on the London office move, staff engagement through leadership roadshows, the announcement of the PIDD investigation outcome, feedback on the Manchester stakeholder dinner and other external engagement. Item 5: 2019-20 BUDGET ALLOCATIONS AND STRATEGIC OBJECTIVES Freya Guinness called in for this item 10. Freya Guinness introduced the item. Since their February meeting the board had been consulted on how to treat an increase in employer contributions to pensions, which would add nearly £1m to the overall budget. This would be passed on to the rail industry through the levy and sought from DfT for roads. 11. The board continued to be content with the changes proposed to the strategic objectives to better align the language to current priorities. 12. The board noted the service standards and suggested that each should also be reported on a quarterly basis. 13. The board approved the budget allocations and the revised strategic objectives. Item 6: SAFETY REGULATION OF THE CHANNEL TUNNEL FOLLOWING A NO DEAL BREXIT AND PROPOSED MOU WITH EPSF Martin Jones joined the meeting for this item 14. Martin Jones explained the changes made to the draft MOU since the papers had been circulated, none of which were substantive. The board noted the report and delegated the agreement and signing of the MOU to the Director of Railway Safety [action list]. Items 7, 8 and 9 all related to NR but were slightly rearranged to reflect a more logical progression Item 7 NR'S DELIVERY OF PERFORMANCE: COMPLIANCE WITH ORR'S PROVISIONAL ORDER Dominic Bulcock joined the meeting for this item on the phone. 15. Graham Richards reported that the response from NR to the provisional order had been encouraging and the monitoring framework would now hold them to account to the plan offered. Close monitoring of Wessex, LNE and Scotland would continue and NR would produce a six month report (in September) on progress [forward programme]. 16. The board was concerned about the quality of the plan to deliver improvements in performance and wished to see early evidence that changes were delivering improvement, given the lead times in some of the plans - so the September report should include concrete examples, however small. The board discussed the importance of identifying leading indicators that would show how passenger experience was changing, recognising the challenge this posed and the work already under way by NTF. While the adoption of a maturity model was encouraging, the timescales for change were disappointing. The board noted that well-made plans were only the starting point and delivery against the plan was more important. 17. The board agreed that NR had complied with the provisional order and asked for quarterly reports to demonstrate ongoing evidence of improvement in line with the plan. JLk would write to NR [Action] Item 9 NR'S CP6 PREPAREDNESS: EFFICIENCY PLANNING Gordon Cole joined the meeting for this item 18. The board had concerns about NR's efficiency plans for CP6 and welcomed the paper which showed that the quality of underlying evidence from NR was insufficient to demonstrate their ability to deliver efficiently in CP6. Following ORR's intervention, NR had now understood ORR's real concerns. The board discussed the importance of fiscal accountability through route management. The executive were considering what evidence might lead to consideration of a licence breach in this regard. 19. John Larkinson would write to NR setting out the board's concerns and seeking assurance that they would outline concrete evidence of efficiency measures in place that could be assessed by ORR and that the roll out of the restructuring under the NR100 day plan will demonstrate that real improvements to financial management would be made. [Action] Item 10 HS1 LTD - 5 YEAR ASSET MANAGEMENT STATEMENT AND PR19 Feras Alshaker joined the meeting for this item and the next. Keith Ludeman (Chair) and Dyan Crowther (CEO) of HS1 joined the meeting 20. The chair welcomed the guests to this meeting. 21. The guests tabled a presentation which covered the 5YAMS (5 year asset management statement), NRHS (Network Rail High Speed), engagement, the renewals annuity and next steps. 22. The board and visitors discussed the reasons underlying the projected increase in charges including: quicker than expected track deterioration, treatment of signalling, cost of the annuity, and operating costs for NRHS. HS1 set out the work it had done to manage its overall costs including NRHS's contract. 23. HS1 was working with its passenger and freight customers and stakeholders (including DfT and ORR) to explain the issues and seek solutions that were sustainable: it recognised the potential shock to customers of the projected charge increases. Ultimately it sought an affordable approach consistent with the Concession Agreement but this was proving difficult in spite of positive engagement by DfT and support from ORR's exec team. 24. The board thanked HS1 for their open discussion of the issues. Lunch Item 11 PERIODIC REVIEW OF HS1 LTD (PR19) Chris Warburton and Debbie Daniels joined the meeting for this item 25. Feras Alshaker described the outcome of ORR's public consultation on Eurostar International Limited's (EIL) request for a suspension of the PR19 process because of the demands of Brexit on its business. The board reflected on the pressures on EIL and the possible delay before Brexit was resolved. 26. The paper set out four options including two which required a variation to the process set out in the Concession Agreement and therefore could not be implemented without HS1 and DfT agreement. HS1 had said they would not consent to the delay requested by EIL. 27. The board recognised the real issues presented by Brexit for EIL and the preference of HS1 for no change to the Concession Agreement process. However, the board agreed that option 1 offered a fair and pragmatic change which would not compromise the legitimacy of the process. 28. The board understood that it did not have powers to unilaterally change the process set out in the Concession Agreement as requested by EIL and therefore would allow EIL to make additional representations by mid-June and to allow HS1 to comment on those views. This would not vary the Periodic Review process set out in the Concession Agreement and could be implemented unilaterally by ORR. 29. GR would write to all the parties. All relevant correspondence with HS1, DfT and EIL would be put in the public domain. [Action: GR] Item 8 NR'S 100 DAY REVIEW AND CP6 DELIVERY PLAN Carl Hetherington and Pedro Abrantes joined the meeting for this item 30. DfT was due to publish NR's Delivery Plan for CP6 imminently. John Larkinson emphasised the need for the plan to be clearly reconcilable to the Final Determination before it was adjusted or changed by the 100 day review. The link was not yet sufficiently clear in all areas. The Board noted that the enhancement delivery plan would be published late because the DfT needed more time to consider it. 31. Further details of the 100 day plan were now emerging including some additional costs. 32. The board discussed risks arising from the 100 day plan or increasing as a result of management distraction, blurring of accountability, insufficiently detailed plans, doubts about efficient cost management, and poor line of sight to the CP6 commitments. 33. The board had already expressed general support for the 100 day plan as long as it did not undermine the overall settlement and now discussed when it was likely to issue an opinion under the change management licence condition. ORR executive should make clear what it would expect to see and by when - allowing for the delay which arose while senior staffing questions were resolved. ITEM 12 WILLIAMS REVIEW Robert Cook joined the meeting for this item 34. Dan Brown updated the board on work with the Williams Review team since the last board meeting and plans for a board policy discussion on the issues that the Review had sought advice on as well as the wider issues it was considering. The board was content with the process outlined by DB and looked forward to a more detailed discussion at the proposed April Board workshop.[Action: secretariat] ITEM 13 COMMITTEE REPORTS 35. Stephen Glaister reported on the Highways Committee the day before which had discussed: performance in RIS1 and preparations for RIS2, the SBP and efficiency review, and preparations for Brexit. 36. Justin McCracken reported on HSRC which (as already mentioned) had heard from Chris Gibb of NR, and also discussed how ORR should meet its duty to promote safety research, a strategic chapter on tram safety and CTSA as well as noting an updated version of ORR's RM3 safety management tool. ITEM 15 ANY OTHER BUSINESS 37. The board noted the items circulated below the line including the forward programme. Meeting closed at 2.55pm
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## An Introduction To Peer Challenge And Support In The Culture And Sport Sector: A Guide For Councils What Is Peer Support And Challenge? Peer challenge and support are managed and delivered by the sector for the sector. Peers, members and officers, are at the heart of the process providing councils with an external practitioner perspective and 'critical friend' challenge so helping them with their improvement and learning. The use of peers helps build capacity, confidence and sustainability in local government by sharing knowledge and experience, and enables the transfer of learning between councils and across the sector. They help recognise and confirm good practice and also provide challenge to inappropriate processes and behaviours so championing change and improvement. The LGA has been providing peer-based challenge and support for many years. Currently this ranges from a corporate peer challenge available to every council at no direct cost to service specific peer challenge including children's safeguarding, adult social care, planning, housing, safer communities and equalities. Some of these peer challenges have a cost associated. You can find out more about the LGA's peer challenge offer from the website: ## Lga'S Peer Challenge Offer Since 2004, almost 70 per cent of councils have had a peer challenge and in the last year we have received a clear message from the sector that peer challenge is a valuable part of a council's drive to improve its performance in tough times. In the past, peer challenge programmes have been provided for libraries alongside external validated self-assessments carried out using the Culture and Sport Improvement Toolkit. We are now able to offer, at no direct cost, a limited number of peer challenge and support activities for libraries, museums and sport services. Over time, other peer based activity may be added to the portfolio. These limited offers are currently funded by grants made by our partners Sport England and the Arts Council and are accessed by application through the LGA. Councils will be informed by LGA when funding is available. Funding is limited and will normally provide access to up to two days of peer challenge and support. Councils can if they wish expand the grant aided activity by providing additional funding themselves or approach the LGA about self-funded peer challenge and support. ## How Does It Work? The process will be tailored to meet your specific needs but normally consists of the following stages:  A scoping discussion with you to clarify and define exactly what is required from the peer challenge and support. This will result in a clear written brief setting out the purpose and anticipated outputs or outcomes.  A self-assessment by the council of the current position of the service including recent and current performance, the challenges being faced and proposals being considered all captured in a short 'position statement'.  Identification of a small number of key documents that the peer team need to read beforehand to understand the local context.  An onsite visit principally to interview and discuss with key individuals and groups of stakeholders the issues and challenges being faced. These discussions also enable good practice and ideas to be shared, developed and tested with the peers. This onsite phase can take up to two days and depends on the council organising a programme of meetings and discussions for them.  At the end of the onsite work the peer team will briefly feed back their key findings and practical suggestions for improvements.  Finally a brief written report with recommendations is sent to the council about three weeks after the team leave confirming the feedback. In summary, here is what happens: Before LGA Council  Application process  Seek endorsement from your chief  Scoping meeting executive and portfolio holder  Assemble peer team  Scoping meeting  Logistics  Prepare position statement identifying  Briefings for peer team on current performance and priority authority specifics and issues, challenges being faced and challenges proposals being considered  Agree date and setup interview timetable and onsite arrangements ## Onsite (Up To 2 Days)  Interviews with senior officers, councillors, partners and frontline staff.  Presentation of feedback including findings and recommendations.  Report circulated within three weeks. Councils value the flexible nature of the process and the fact that it is tailored to their own issues and requirements. They value that they can within reason determine the timing of visits to make sure they take place at the most appropriate point in their improvement journeys and planning processes. Because the process is not rules based (there is no template or scoring system), it relies on the judgment and experience of the peer teams. Councils value the rigorous nature of the process, how well prepared the teams are and how quickly they get to grips with the issues they are asked to focus on. Visits are always conducted in a professional manner with peers seeking to be knowledgeable yet empathetic. We try to pick a peer team who clearly understand what it takes to manage complex organisations and change processes to help facilitate honest and open dialogue and agree with you beforehand the peers. How could you use peer support and challenge? Councils use peer challenge and support in different ways depending on what issues and challenges they are facing but some of the more common uses of the process include:  To provide an independent check and challenge to an existing or proposed change process.  To provide an external review of past and current performance to help identify areas for improvement and how these could be delivered.  To help identify and consider different ways of providing the service to improve efficiency and effectiveness.  To provide professional and technical support to specific service delivery or development challenges.  To help broker sensitive or difficult political or professional tensions in the service, across the council or across partners. Recently councils have used the peer challenge and support process to provide an independent review of change processes taking place round their library and museum services. ## Preparing For Peer Support And Challenge? Preparation is all important. The scoping meeting and other discussions with the LGA that take place prior to the visit by the peer team are crucial in getting the focus, scope and timing right. Getting the scope right is key to putting together the right peer team with the right mix of skills and experience. An example scoping document can be made available to you. Most councils request member peers from the same political party (or parties) as the controlling group (or groups) and an officer peer from a similar type and size of council normally from outside the region. Peers are agreed with you beforehand. It is import to prepare beforehand a short position statement which tells your story. You are encouraged to carry out a short self-assessment of the service its performance, current challenges and issues and possible future direction. Think of it as "telling your story", where has the service come from, where it is now and where do you want to take it in the future. You can use this as a brief introduction at the start of the onsite visit to help the peer team understand clearly your context. Include comparator data and key policy or strategy documents for the service and the council. Wherever possible, use existing documents to minimise the burdens the process places on staff. If you can provide the peer team with links to these key documents or summary versions it will assist their preparation time. Think about the key people the peer team need to meet. The right elected members, senior officers from across the council, service managers, staff, partners and other stakeholders. In some circumstances meeting customers might be helpful but given time will be short not a priority. Similarly, visits to facilities may help the peer team but given time will be short, organised tours of facilities will add little value to the process. Make sure the people you identify will be available when the peer team visit and put together a draft programme to ensure there will be adequate time to meet everyone. An example schedule can be made available to you. The peer team usually arrives the night before. Where you have received a grant you will be required to book appropriate accommodation near to the council to ensure the peer team can function efficiently and pay all appropriate expenses direct to the peers. You will also need to provide the peer team with a base room to work in for the duration of their visit. It is good to start the first day with an introductory meeting of key people to enable the peer team to clarify anything in the position statement, clarify the programme for the two days and confirm who they will be meeting. It is also useful to have an identified lead officer from the service to liaise with the peer team beforehand and throughout the visit. At the end of the first day, the team will confirm any additions or changes they may want to make to the programme for the next day. They may wish to see specific individuals or look at specific information or re-meet people they met on day one. By lunchtime on day two they will want to start drawing together their feedback and will need time to do this on their own. Time will need to be left in the programme to ensure they can adequately prepare. ## What Feedback Do You Get? Feedback onsite is usually verbal and will include the main strengths the peers have seen and the areas for improvement they feel need to be addressed along with some recommendations. These should not be a surprise to you given the discussions that will have taken place up to that point. Most councils report that the feedback at the end of visits has been challenging but balanced and fair. Peers are often able to say things that those inside the council knew but were unwilling or unable to voice, and the process often highlights new issues or priorities or leads to the re-evaluation of existing approaches and strategies. It is not normal practice to enter into a lengthy discussion at this stage unless things need to be clarified. After giving their feedback the peer team will leave. Within three weeks you will receive a concise written report reflecting the feedback you received on the day. You will have an opportunity to comment on this but the final document remains the views of the peer team. Once you have commented the LGA will issue the final report. Who are the peer team? We take a flexible approach to the composition of the peer team but you can tell us what peers would best meet your needs. A standard peer team is usually made up of three people:  the team will be led by an LGA officer or associate, and  a serving senior officer with experience and knowledge of the service being challenged and supported  in addition, there will be an elected member with experience of the service as w as wider corporate experience in terms of political leadership. In some instances, if there is a need, the team may be supplemented by other specialist peers or an LGA associate with more general management experience. I n some circumstances, where appropriate, an NDPB officer (for example Sport England or Arts Council) with relevant experience may be involved. ## What To Do If You Want A Peer Challenge Or Support If you want to discuss arranging a peer challenge or support for your council, please email: cts@local.gov.uk or telephone: 0207 664 3094
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# Proven Reoffending Statistics: Definitions And Measurement Published October 2016 ## Contents Contents ................................................................................................ 2 Introduction .......................................................................................... 3 Measurement ........................................................................................ 4 Definitions for the measurement of proven reoffending ...................... 5 Definitions for the measurement of interim proven reoffending for Community Rehabilitation Companies and the National Probation Service ............................................................................................................ 9 Data quality ......................................................................................... 14 Police National Computer data ......................................................... 14 Prison data ........................................................................................ 15 Probation data .................................................................................. 17 Young offenders in secure accommodation ...................................... 17 Data processing and analysis ........................................................... 18 Matching offender records ................................................................ 18 Counting rules ................................................................................... 19 The extraction of the criminal histories .............................................. 19 Level of subjectivity ........................................................................... 20 Maturity and stability of the data system ........................................... 20 Expertise of those who operate the system ...................................... 20 Data on historical trends ................................................................... 21 Appendix A: Glossary of terms ......................................................... 23 Explanatory notes .............................................................................. 30 Contact details .................................................................................... 31 ## Introduction This document supplements the quarterly Proven Reoffending Statistics bulletin by providing a comprehensive guide to the statistics. This document focuses on concepts and definitions published in Ministry of Justice statistics and the counting procedures used to produce them. It also provides explanations of data sources and quality. This bulletin is published alongside two inter-related bulletins: Offender Management Statistics Quarterly: provides key statistics relating to offenders who are in prison or under Probation Service supervision. Safety in Custody Statistics Quarterly: provides statistics on death, selfharm and assault incidents whilst in prison custody. The publication in its current form is a result of a statistical consultation on improvements to the transparency and accessibility of our information launched in 2010 and a response to the consultation was published in March 2011. One aspect of the consultation was the measurement of proven reoffending. Responses supported the proposals to move to a single framework for measuring reoffending where adult and youth data can be provided at national and local levels on a consistent basis. From 30 July 2015 to 30 October 2015, a more recent consultation on changes to the proven reoffending statistical publication was launched. The key change that was proposed was to align the existing reoffending measure with those measures necessary for assessing progress against the rehabilitation reforms. This consultation outcome summarises the responses received to that consultation. Having considered the responses to the consultation, details of the post consultation position are:  Proven reoffending measures will be published using the proposed 3 month cohorts;  The new publication will contain a chapter on Community Rehabilitation Companies (CRC) Payment by Results and National Probation Service (NPS) division proven reoffending performance measure;  For assessing the likelihood of reoffending OGRS4/G will be used for adult cohorts and for juvenile cohorts the Youth Offender Group Reconviction Scale (YOGRS) will be used;  From October 2016 we will provide interim Payment by Results. The existing adult and juvenile reoffending statistics will continue in their current form until the reoffending outcomes for the first Payment by Results cohort become available in October 2017. ## Measurement The underlying principle of measuring reoffending (or recidivism, which is the most commonly used term internationally) is that someone who has received some form of criminal justice sanction (such as a conviction or a caution) goes on to commit another offence within a set time period. Measuring true reoffending is difficult. Official records are taken from either the police or courts, but they will underestimate the true level of reoffending because only a proportion of crime is detected and sanctioned and not all crimes and sanctions are recorded on one central system. Other methods of measuring reoffending, such as self report studies, are likely to also underestimate the rate. Following the Ministry of Justice Consultation on Improvements to Ministry of Justice Statistics, a **proven reoffence** is defined as any offence committed in a one year follow-up period that resulted in a court conviction, caution, reprimand or warning in the one year follow-up or a further six month waiting period (to allow time for cases to progress through the courts). The data source is the extract of the Police National Computer (PNC) held by the Ministry of Justice. ## Definitions For The Measurement Of Proven Reoffending Cohort This is the group of offenders for whom reoffending is measured. For the Proven Reoffending Statistics Quarterly Bulletin, this is defined as all offenders in any one year who received a caution, a final warning or reprimand (for juveniles prior to April 2013), a non-custodial conviction or who were released from custody. Offenders who were released from custody or secure accommodation (juveniles only) or commenced a court order are matched to the PNC database. A proportion of cases are lost in this process because they cannot be matched (see the section below titled "Matching offender records" for further details). Additionally, offenders who appear multiple times in the cohort are only included once (see the section below titled "Multiple offender entries" for further details). The group of offenders whose offending behaviour is proven is likely to be a sub-group of all active offenders. The Offending, Crime and Justice Survey (2003)1 estimated that around one in ten people in England and Wales aged between ten and 65 had committed an offence in the previous 12 months, which translates into approximately 3.8 million people. This compares to around 632,000 offenders in the 2002 cohort used to measure proven reoffending, underlining that the offenders whose proven reoffending behaviour is presented in the Proven Reoffending Statistics Quarterly Bulletin are a small and probably unrepresentative sample of the population of all active offenders. Index disposal (sentence type) The index disposal of the offender is the type of sentence the offender received for their index offence. For the Proven Reoffending Statistics Quarterly Bulletin, this is defined as custody, court order, other disposal resulting from a conviction at court, such as a fine or discharge, caution, reprimand or final warning (young offenders). Index offence The index offence is the proven offence that leads to an offender being included in the cohort. An offence is only counted as an index offence if it is:  recordable (see below);  committed in England and Wales;  prosecuted by the police; and  not a breach offence. Start point (index date) This is the set point in time from when proven reoffences are measured. For the *Proven Reoffending Statistics Quarterly Bulletin*, this is defined as the date of prison release, the date of court conviction for non-custodial sentences, or the date of receipt for a caution, reprimand or final warning. Follow-up period This is the length of time over which proven reoffending is measured. For the *Proven Reoffending Statistics Quarterly Bulletin*, this is defined as 12 months from the start point. Waiting period This is the additional time beyond the follow-up period to allow for offences which are committed towards the end of the follow-up period to be proven by a court, resulting in a conviction, caution, reprimand or final warning. For the *Proven Reoffending Statistics Quarterly Bulletin*, this is six months. Figure 1 below illustrates why different offences for an example offender are included or excluded in the proven reoffending measure. Events A to D all occur in the one year follow-up period, but events E and F are outside this period, so would not be counted. Events A to C are all counted because they were all proven within the one year follow-up period or the further six month waiting period. Event F, even though the offence took place in the 6 month waiting period, it would not be counted, as the event took place outside of the one year follow up period and conviction did not occur within either the one year follow-up period, or the further six month waiting period. The offender has, therefore, committed six proven offences during the one year follow-up period (two for event A, one for event B, three for event C). Proven reoffence Offences are counted as proven reoffences if they meet all of the following criteria:  They are recordable. Not all offences are on the PNC and more recordable offences are entered than non-recordable offences. Analysis comparing offences proven at court with offences recorded on the PNC suggests the most cost common offences that are not recorded relates to motor vehicles, e.g. using a motor vehicle whilst uninsured against third party risks, speeding offences, keeping a vehicle on the highway without a driving licence or television licence evasion.  They were committed in England or Wales.  They are offences that were prosecuted by the police. PNC data are collected and input by the police and offences prosecuted by the police are likely to be recorded more comprehensively on the PNC than offences that are prosecuted by other organisations. For example, benefit fraud is prosecuted by the Department for Work and Pensions. Therefore, benefit fraud offences may be poorly represented on the PNC.  Offences are only counted if they are proven through caution, reprimands or final warnings (for juveniles) and court convictions. Offences that are not proven, or which meet with other responses from the Criminal Justice System, are not counted. The Offending, Crime and Justice Survey (2003) estimated that 6% of all offences resulted in any contact with the Criminal Justice System.  The offence is not a breach offence, i.e. breach of a court order, since we are only interested in new offences. ## Measures Of Proven Reoffending Proven Reoffending Data Are Presented In The Following Ways:  The number of offenders.  The proportion of offenders who are proven reoffenders.  The average number of proven reoffences among **reoffenders**.  The proportion of proven offenders who committed a proven indictable reoffence. Multiple offender entries Each offender is tracked over a fixed period of time and any proven offence committed in this period is counted as a proven reoffence. A multiple offender entry refers to an offender who, after entering the cohort in a given year, commits a reoffence and is either cautioned, discharged from prison or gets a non-custodial conviction in the same cohort year. This reoffence could also be included as a second entry for this offender into the cohort. Re-offence 2 Re-offence 2 Re-offence 3 Re-offence 3 Offender Cautioned Re-offence 1 Offender starts a community sentence Offender Cautioned Offender Cautioned Re-offence 1 Offender starts a community sentence Offender sentenced to 3mnths in prison then released Offender sentenced to 3mnths in prison then released Offender sentenced to 3mnths in prison then released 1 year cohort period 1 year cohort period To date, publications have avoided the double counting of these multiple offender entries (MOE) by only counting an individual once based on their first proven offence in the relevant time period. In the illustration above, the caution would be counted as the index disposal and the further two proven offences would be counted as reoffences. This avoids double counting of proven reoffences. In this publication the main tables (tables A1 to A6 and B1 to B4) in the report have been produced on the basis of the 'first proven offence in the relevant time period', which led to an offender being included. This provides a picture of proven reoffending which is consistent with previous publications and tracks an offender, irrespective of the disposal they receive, to when they commit a proven reoffence. The measure of proven reoffending now covers all offenders in any one year instead of the first quarter of a calendar year as in previous proven reoffending publications. The result is many more offenders with multiple entries. In addition, including cautions to identify a proven offence means many offenders' first offence will be associated with a caution since cautions account for around a third of adult offenders in one year. Table 1 shows the number of offenders in each cohort period by their number of entries. 2000, 2002 to 2012 cohorts2 Multiple Offender Entries 2000 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 1 512,551 522,376 544,031 549,545 580,709 615,775 630,748 602,251 572,068 528,466 498,364 459,250 2x 75,311 77,813 81,651 78,827 80,968 86,866 90,870 87,427 83,235 78,430 74,314 66,028 3x 19,565 21,208 22,073 20,840 20,908 21,823 23,590 23,499 22,005 21,332 20,479 17,892 4x 6,195 6,689 7,074 6,833 6,720 6,768 7,605 7,882 7,319 7,396 7,115 6,289 5x 1,998 2,314 2,392 2,355 2,355 2,411 2,774 2,894 2,927 2,902 2,963 2,592 6 to 10x 1,240 1,510 1,689 1,641 1,505 1,509 1,964 2,332 2,303 2,361 2,500 2,292 Greater than 10x 164 155 129 131 119 115 114 160 202 193 190 178 Total MOEs 104,473 109,689 115,008 110,627 112,575 119,492 126,917 124,194 117,991 112,614 107,561 95,271 % of total cohort 16.9% 17.4% 17.5% 16.8% 16.2% 16.3% 16.8% 17.1% 17.1% 17.6% 17.8% 17.2% Cohort 617,024 632,065 659,039 660,172 693,284 735,267 757,665 726,445 690,059 641,080 605,925 554,521 The number of offenders with multiple entries has remained fairly constant over time - the proportion of the total that had multiple offender entries has remained at about 16 to 18% between 2000 and 2012. Proven reoffending by index disposal, probation trust and prison In order to measure proven reoffending on a consistent and representative basis by offender management groups, it is necessary to distinguish between the disposal (sentence) types that led to an offender being included. Doing this allows the cohort to be defined according to the relative start point of an offender's interaction with the prison (released from custody) or probation services (court order commencement). Tables C1-C3 provide reoffending data by disposal (sentence) types. These are produced on the basis of an individual's first disposal (sentence) in that category. In figure 2 above, the individual would appear once in the caution category, once in the community order category and once in the custody category. These tables will include an overall prison and probation proven reoffending rate which will be the figures we quote publicly. However, these figures should not be used when comparing proven reoffending rates across different disposals to compare effectiveness of sentences. Instead the Compendium of Reoffending Statistics and Analysis 2013 publication should be referred to as this analysis controls for offender characteristics in order to give a more reliable estimate of the relative effectiveness of different disposals. The prison/youth secure accommodation/probation trust data tool provide reoffending rates by individual prison and former probation trust, and National Probation Service Division (NPS). These are produced on the basis of an individual's first disposal from each specified prison or probation trust. If the individual offender is discharged from two different prisons in the year they will appear in both of the prison's reoffending rates. The same applies for offenders commencing court orders in more than one probation trust within the year. This is to allow prisons and probation services to track their caseload of offenders. Definitions for the measurement of interim proven reoffending for Community Rehabilitation Companies and the National Probation Service The Transforming Rehabilitation reforms included opening up the probation service to a diverse range of rehabilitation providers from the private, voluntary and social sectors through 21 Community Rehabilitation Companies (CRCs) and creating a new public sector National Probation Service (NPS), to manage high risk offenders. A Payment by Results (PbR) approach was adopted for the 21 CRCs to develop and implement effective ways of rehabilitating offenders and rewarding providers that devise and deliver the most effective rehabilitation programmes. Final reoffending results for the CRC PbR offender cohorts will be based on a **one year proven reoffending measure**. One year proven reoffending statistics for PbR will be published in October 2017. To address this interim gap in knowledge, the Ministry of Justice will publish interim reoffending results from October 2016. The interim reoffending results are based on a reoffending-to-date measure. This will allow CRCs' progress to be assessed at the earliest opportunity. Equivalent interim figures for the NPS divisions will also be produced. These estimates will only give an indication of progress and, therefore, care should be taken when interpreting them. Cohort This is the group of offenders for whom reoffending is measured. For the Interim Proven Reoffending Statistics for CRCs and NPS Quarterly Bulletin this is defined as all adult offenders in any one quarter (January to March, April to June, July to September, October to December) who begin a community order, a suspended sentence order or who were released from custody. For CRC proven reoffending, this group represents the eligible cohort. Offenders who were released from custody or commenced a court order are matched to the PNC database. A proportion of cases are lost in this process because they cannot be matched. The process uses automated matching routines that look at offenders' surnames, initials, dates of birth and gender, using direct name matching along with a variety of 'sounds like' algorithms. The matching algorithm also searches through PNC held information on alias names and dates of birth for offenders. Additionally, offenders who appear multiple times in the cohort are only included once (see the section below titled "Multiple offender entries" for further details). For CRC proven reoffending, **eligible** offenders that can be matched to the PNC database represent the **measurable cohort**. This is the group for whom reoffending can be measured. Offenders are only included in a CRC's PbR cohort the first time they commence an eligible sentence (see below for exclusions) in the three month period. The same methodology will be used for each NPS division's proven reoffending performance measure. - released from a custodial sentence; - who begin a community order; - who begin a suspended sentence order; - Aged 18 or over Start point (index date) This is the set point in time from when proven reoffences are measured. For the Interim Proven Reoffending Statistics for CRCs and NPS Quarterly Bulletin this is defined as the date of prison release or the date of sentence for court orders. Follow-up period This is the length of time over which proven reoffending is measured. For the Interim Proven Reoffending Statistics for CRCs and NPS Quarterly Bulletin instead of measuring reoffending with a defined follow-up and waiting period, this interim estimate would count any proven reoffending to date as recorded on the MoJ's PNC data extract (see diagram below). Some offenders in the three month cohort will have a longer follow-up period in which to reoffend. An offender enters the cohort if they are released from custody or are sentenced to a community order or a suspended sentence order in the period October to December 2015. ## Proven Reoffence The Same As For The Headline Proven Re-Offending Figures Presented In The Proven Re-Offending Statistics Quarterly Bulletin. Measures Of Interim Proven Reoffending Interim Proven Reoffending Data Are Presented In The Following Ways:  The number of eligible offenders.  The number of measurable offenders.  The proportion of measurable offenders who are proven reoffenders.  The average number of proven reoffences among **reoffenders**.  The offender group reconviction scale average score. Multiple offender entries Each individual offender is allocated to a quarterly cohort only once, based on their first eligible entry in a given quarter. For the final results, annual cohorts will be formed by combining the four quarterly cohorts of the relevant year. An individual offender can, therefore, appear up to four times within a single annual cohort (one from each quarter). Interim proven reoffending by CRCs and NPS divisions An offender can move within the three month cohort period and supervision can be transferred to another CRC provider. An offender can also be transferred from being supervised by a CRC to being supervised by an NPS division if a high risk offence is committed within the three months. If an offender is managed by more than one different CRC or NPS division within the same three month cohort period, reoffending is measured against the first CRC or NPS division the offender is allocated to. Offender Group Reconviction Scale For the final reoffending results, CRCs' performance in reducing reoffending will be assessed against the baseline year of 2011. As proven reoffending is related to the characteristics of offenders, the actual rate of proven reoffending will depend, in part, on the characteristics of offenders coming into the system. This actual rate provides users with sufficient information on what the level of reoffending is and how it is changing over time. In addition to the actual rate, the Offender Group Reconviction Scale version 4/G3 is used to control for some differences in offender characteristics across different offender groups. OGRS4/G is based on a well-established, peer-reviewed methodology for assessing and representing reoffending risk. OGRS4/G uses age, gender and criminal history to assess the reoffending risk of a given group of offenders by producing a score between 0 and 1. These scores can be used to compare the relative likelihood of reoffending either over time or between different groups of offenders, with a higher rate meaning a group of offenders who are more likely to reoffend. For the final reoffending results, the reoffending rate for each CRC will be adjusted by using OGRS4/G, to take account of the influence that differences in offender mix can have on binary rates. OGRS4/G adjusted rates will be used to determine final PbR outcomes. The frequency rate will not be adjusted. The OGRS4/G adjusted reoffending rate for a given CRC cohort will be calculated as the observed reoffending rate for that cohort plus any difference between the OGRS4/G score in that cohort and the 2011 CRC baseline cohort. This calculation standardises the mix of offenders in each cohort of a given CRC to the 2011 mix for that same CRC. It will not be possible to adjust the reoffending rate for interim results because OGRS4/G only offers a one and two year prediction of reoffending and interim results are based upon a reoffending-to-date measure. ## Data Quality The data required for measuring proven reoffending are based on a range of data sources (prison data, probation data, young offenders in secure accommodation, and criminal records from the Police National Computer) from a range of agencies (the National Offender Management Service, the Youth Justice Board, local authorities and the National Police Improvement Agency). These figures have been derived from administrative IT systems which, as with any large scale recording system, are subject to possible errors with data entry and processing. Police National Computer data Information regarding the proven reoffending behaviour of offenders has been compiled using the Ministry of Justice's extract from the Police National Computer (PNC). The process involves matching offender details from the prison and probation data to the personal details recorded on the PNC. A proportion of cases cannot be matched and the figures presented in Table 2 below and are expressed as a percentage of the offenders that are matched. Like any large scale recording system, the PNC is subject to errors with data entry and recording. The PNC is regularly updated so that further analysis at a later date will generate revised figures. The quality of the information recorded on the PNC is generally assumed to be relatively high as it is an operational system on which the police depend, but analysis can reveal errors that are typical when handling administrative datasets of this scale. The extent of error or omitted records on the PNC is difficult to estimate because it is a unique data source. As a result, there is not always an obvious source of data to provide a baseline from which to assess data quality. For some types of results, however, comparisons can be made. For example, the trend in receptions into prison in each month is very similar using the PNC and prisons data (see below for details). Although the number of receptions recorded on the PNC is consistently slightly lower because prisons data include cases on remand whereas the PNC does not. Another example is the number of cases that are given a custodial sentence, broken down by offence type, which is similar using the PNC and the Court Proceedings Database with a match rate of 97%. A number of improvements are routinely carried out:  Updates to the coding and classification of offences and court disposals, including the reduction of uncoded offences, the reduction in the use of miscellaneous offence codes and the clarification of the coding of breach offences;  Updates to the methods used to identify the primary offence, where several offences are dealt with on the same occasion, and the methods used to identify the primary disposal, where an offence attracts more than one court disposal; and  Removal of some duplication of records within the database resulting in improvements to the efficiency and reliability of the matching process. ## Prison Data Prison establishments record details for individual inmates on the prison IT system (Prison-NOMIS or LIDS). The information recorded includes details such as date of birth, gender, religion, nationality, ethnic origin, custody type, offence, reception and discharge dates and, for sentenced prisoners, sentence length. The data from individual prison establishments then feeds through to a central computer database, called the Inmate Information System (IIS). In May 2009, the National Offender Management Service (NOMS) began the roll-out of a new case management system for prisons (Prison-NOMIS). During the phased roll-out, data collection issues emerged that affected the supply of data for statistical purposes from July 2009 to February 2010. Specifically, statistical information on sentence length and offence group is not available on any of our prison datasets for this period. In order to ensure the fullest possible set of data from July 2009 to February 2010, sentence lengths were estimated for those prisoners received or discharged before the problems were resolved. At the point when the problems were resolved, a small number of prison establishments were still using the old LIDS case management system; data for prisoners received or discharged from these prisons was assumed to be unaffected. For those prisoners received or discharged from prisons operating Prison- NOMIS, efforts were made to populate their record with the correct sentence length using other data extracts. For example, many prisoners discharged in January 2010 were originally received into prison prior to July 2009, so their sentence length was taken from unaffected datasets before the problems began. Similarly, the majority of those received in early 2010 were still in prison in March 2010 when the problems were resolved, so the sentence length from the corrected prison population data was used. Where it was not possible to populate a sentence length using other datasets, prisoners were allocated a sentence length band based on the number of days they spent in custody (taking account of early release schemes where relevant). As a check on the methodology, an alternative estimation process was designed and the number of discharges in each sentence length band for the second half of 2009 was compared using the two methods. A number of estimation methods were considered and tested on the 2008 data (prior to the data problems) to see which yielded estimates closest to the actual 2008 data. This identified the following method: 1. Calculate data for the first half of the year as a proportion of the full calendar year, for each year from 2001 to 2008; separately for each sentence length band or offence group (the two key breakdowns to be estimated). 2. Apply the average of these proportions to the January to June 2009 data to estimate the 2009 annual totals; separately for each sentence length band or offence group. 3. Scale the estimated numbers in each sentence length band or offence group to sum to the annual total recorded in the raw data (where the totals are known to be correct). The maximum difference between the two approaches was 2.6% in the band '12 months to less than 4 years'; for all other bands the difference was less than 1%. Indeterminate sentence prisoners In addition to the above, data on the discharge of prisoners on indeterminate sentences, i.e. prisoners given a life sentence or an Indeterminate sentence for Public Protection (IPP), is provided from the Public Protection Unit Database (PPUD). This holds data jointly owned by the Offender Management and Public Protection Group (OMPPG) in NOMS and the Parole Board. PPUD records details of all indeterminate sentence prisoners at the point of conviction, those engaged in the Generic Parole Process and prisoners (determinate and indeterminate) who have been recalled from licence. It also covers those who have received a restricted hospital order/direction from a Crown Court, and those remand and convicted prisoners who have been transferred from prison/detention centres to psychiatric hospital under the relevant sections of mental health legislation. All decisions taken by the NOMS casework sections and the Parole Board are recorded on the system. Personal information recorded includes (but is not limited to) name, date of birth, gender, identifying numbers, ethnicity, last known address, probation area and sentencing information. OMPPG and the Parole Board run monthly and ad hoc reports to cleanse data that are not otherwise identified by data validation routines built into the system. For the interim proven reoffending statistics, prison discharge data are sourced from the nDelius case management system (for further information about nDelius, please see the section on probation data below). ## Probation Data Since 2005, detailed information on the supervision of offenders (at the individual offender level) had been submitted by probation trusts on a monthly basis. These monthly 'probation listings' included information on offenders starting probation supervision. Between 2002 and 2005, this information was submitted quarterly, and prior to 2002 a different data collection system was in place, which meant that information on caseload had to be calculated based on the number of people starting supervision and the number of terminations. From June 2014, the Transforming Rehabilitation programme was launched, which changed the way offenders are managed in the community. Management of offenders serving their sentence in the community has been split into two groups, one consisting of high risk offenders who are managed by the National Probation Service (NPS) and another group consisting of low to medium risk offenders who are now managed by Community Rehabilitation Companies (CRCs). The quality of the information recorded on the probation data is generally assumed to be relatively high as it is a direct extract from an operational system upon which the probation service depends for managing offenders locally. The extract consists of a small number of key fields for which completion is mandatory. Data is received centrally via the nDelius case management system and is subject to another set of data validation processes. Trends from the data are consistent with comparable time series from the Courts Proceeding Database. Any large scale recording systems are subject to possible errors with data entry and processing, but there are no known issues regarding the probation commencements data. Young offenders in secure accommodation Information about secure training centres (STCs) and secure children's homes (SCHs) comes from the Youth Justice Board's (YJB) eAsset database. Information about young people aged 17 and under and held in YOIs is supplied by the Prison Service and private YOIs. The YJB monthly custody report has traditionally used data from the Secure Accommodation Clearing House System (SACHS), this was the system used by the YJB to book young people into custody. To meet information management challenges of a growing department and whilst improving our processes, the YJB has migrated to the use of the new eAsset system since March 2012. As part of the work to implement the new system both SACHS and eAsset were run in parallel from 5th March to 1st July 2012. The YJB now has the ability to produce some reports from eAsset and has done work to quality assure the outputs against SACHS. While this work is ongoing and further reports are being developed we now believe the quality of data from this system is of a suitable level to publish as management information. The quality of the information recorded on the eAsset database is generally assumed to be relatively high as it is a direct extract from an operational system which is used to place young people in custody. The extract uses a number of key fields for which completion is mandatory when booking a young person into custody. Data processing and analysis The data underpinning the results are considered by Ministry of Justice to be broadly robust. Considerable work has been carried out ensuring data quality, and the data have been used for research publications. Scrutiny of the data source continues in order to ensure the data remains reliable. The National Audit Office (NAO) identified risk factors in its review of the reporting of PSA targets (NAO, 2005). The remainder of this section addresses these. Matching offender records This process involves matching data on prison discharges and court order commencements to the PNC database. The process uses automated matching routines that look at offenders' surnames, initials, and dates of birth, using direct name matching along with a variety of 'sounds like' algorithms. The matching algorithm also searches through PNC held information on alias names and dates of birth for offenders. However, not all offenders are matched and a thorough analysis of bias in the matching system has yet to be undertaken. Table 2 below shows that the overall matching rates between 2000 and 2012 have remained high. Table 2: Matching rates for the different data sources for 2000, 2002 to 2012 cohorts1 2000 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Prison Prison discharges 87,083 87,338 85,920 86,970 84,897 83,725 87,340 95,824 94,114 93,137 89,773 91,009 Automatically matched to the PNC 80,572 81,211 80,121 81,125 79,398 78,285 81,874 90,021 88,745 87,845 84,950 86,333 Matched to an index date 73,810 75,121 73,327 73,390 71,246 68,185 69,741 76,668 74,189 65,278 67,512 71,059 Percentage matched to the PNC 92.5% 93.0% 93.3% 93.3% 93.5% 93.5% 93.7% 93.9% 94.3% 94.3% 94.6% 94.9% Percentage matched to the PNC and index 84.8% 86.0% 85.3% 84.4% 83.9% 81.4% 79.9% 80.0% 78.8% 70.1% 75.2% 78.1% offences (not breach etc.) Court Orders Court order starts 136,023 154,621 158,750 164,831 163,681 176,346 187,386 189,643 191,784 186,417 179,206 165,959 Automatically matched to the PNC 123,540 142,838 148,257 154,075 158,416 172,906 184,740 187,253 190,128 185,112 178,026 164,937 Matched to an index date 105,685 115,108 119,446 122,927 130,307 148,072 159,279 163,519 167,378 164,579 159,533 147,681 Percentage matched to the PNC 90.8% 92.4% 93.4% 93.5% 96.8% 98.0% 98.6% 98.7% 99.1% 99.3% 99.3% 99.4% Percentage matched to the PNC and index 77.7% 74.4% 75.2% 74.6% 79.6% 84.0% 85.0% 86.2% 87.3% 88.3% 89.0% 89.0% offences (not breach etc.) YJB2 YJB discharges - 1,337 1,612 1,521 1,551 1,564 1,553 1,647 1,626 1,770 891 836 Automatically matched to the PNC - 1,226 1,502 1,425 1,448 1,464 1,463 1,537 1,564 1,682 852 801 Matched to an index date - 680 818 785 800 769 780 845 817 916 647 607 Percentage matched to the PNC - 91.7% 93.2% 93.7% 93.4% 93.6% 94.2% 93.3% 96.2% 95.0% 95.6% 95.8% Percentage matched to the PNC and index - 50.9% 50.7% 51.6% 51.6% 49.2% 50.2% 51.3% 50.2% 51.8% 72.6% 72.6% offences (not breach etc.) 1. Data are not available for 2001 due to a problem with archived data on Court Orders. 2. A new data collection method began in March 2012. The total number of offenders matched to the PNC is substantially higher than the final figure for the cohorts - for example, in 2012 there were 252,071 matched offenders, but a final cohort size of 219,347. The main reasons for these discrepancies are:  Conviction dates for the beginning of the community, suspended or custodial sentence do not match the conviction date within seven days of the criminal records from the PNC database;  The index offence was not dealt with by a Home Office police force - this ensures that only offences in England and Wales are counted;  Exclusion of all offenders where the index offence is a breach, since we are only interested in new offences; and  Exclusion of multiple offender entries (see section above titled "Multiple offender entries" for further details). ## Counting Rules The counting rules for choosing which prison discharges to include offer a variety of choices. For instance, it makes little sense to include offenders deported on release or who have died. These counting rules were enumerated and discussed to ensure a more accurate and consistent count and are reviewed on an annual basis to ensure a consistent approach. Note that an offender is counted more than once when the offender was initially in the juvenile cohort, then in the adult cohort in the same cohort period. Complexity of data processing and analysis The data processing involved for measuring reoffending is complex. To analyse reoffending behaviour by previous offending or disposal history requires the extraction of criminal histories that can span a number of decades, and the subsequent matching of these histories against the probation caseload files and prison discharges in order to generate a dataset. The extraction of the criminal histories To quality assure the extraction of criminal histories, a small set of random samples of offenders was taken after the analysis to check, via a basic validation, that outputs of the SQL (Structured Query Language) program were accurate. The Ministry of Justice is confident that this process has been successful. ## Level Of Subjectivity There is relatively little subjectivity in the system. Occasional judgements are required (e.g. where to classify an offence), but these will not significantly influence the results. ## Maturity And Stability Of The Data System The system is well established having been used a number of times to produce reoffending statistics for publication. Nonetheless, vigilance continues to be exercised to ensure the validity of the results. Expertise of those who operate the system Prison and court order data-feeds are continually monitored and improvement work is regularly undertaken to improve the reliability and the accuracy of datasets. The internal processing of the results within the Ministry of Justice has been subject to dip sampling of criminal histories and the statistical model has been extensively tested. Interpreting trends in the proportion of offenders who commit a serious reoffence against the person Care should be taken when interpreting the severity rate for the following reasons:  **Time through the Criminal Justice System** - more serious offences are likely to take a longer time to progress through the Criminal Justice System than less serious offences. The proven reoffending statistics track proven reoffending behaviour for a year upon offenders entering the cohort, plus an additional six months for convictions to be updated on the system. There is a risk that this time scale is not long enough to capture the most serious offences. However, analysis suggests that the number of serious proven reoffences picked up by the measure remains comparatively stable year on year, ensuring performance is comparable over time.  **Reporting variation** - variation in reporting time between police force areas and courts may also have an impact on how many serious offences are captured during the one year follow-up period. ## Data On Historical Trends The data used to measure proven reoffending is from the PNC. Police forces started to enter criminal records locally in 1995. In order to allow time for good practice among police forces in entering data onto the PNC to become embedded, PNC data was used to measure proven reoffending for the first time in 2000. Prior to the 2012, headline bulletin results were compared to 2000 to highlight long-term trends. From 2012, results are compared to 2002, and in the future the year of comparison will move forward by one year for each calendar year publication. Results prior to 2000 cannot be compared to results from 2000 onwards for two main reasons:  Change in data source - reoffences are measured using data from the PNC (which covers recordable offences), whereas data from years before 2000 were measured using the offenders index (which covered a narrower range of offences).  Change in measurement - the concept being measured from 2000 onwards in these reports is that of using the offence date to measure reoffences (a period of time is allowed for offences to be committed, and a further period allowed for these offences to be proved by caution, reprimand, final warning or court conviction), whereas the concept being measured prior to 2000 was that of using the conviction date to measure reconvictions (any conviction occurring in a set period of time, whether or not the offence occurred in that time period). However, the *Compendium of Reoffending Statistics and Analysis 2010*, published in November 2010, provides the most consistent statistical series possible between 1971 and 2006, adjusting for known methodological changes. For more information, please refer to Chapter 4.4 at the following link. Results for 2001 cannot be calculated for offenders on court orders because of a problem with archived data on court orders. Local breakdowns of the headline proven reoffending rates are available from 2005 onwards. Proven reoffending data are broken down by locality using the address and post-code information of the offender. Where this information is missing, the location of the processing police force is used instead. This is not a completely reliable indicator of the offender's home address as offenders may offend in a different locality than where they reside. The completeness of this information has improved over time. In 2000, this information was omitted for 29% of cases, which was considered too high to produce reliable results. By 2005, this was reduced to 16.5%, and there has been a continuing downward trend since then. Confidentiality This statement sets out the arrangements in place for protecting persons' confidential data when statistics are published or otherwise released into the public domain. Principle 5 of the Code of Practice for Official Statistics states that: Private information about individual persons (including bodies corporate) compiled in the production of official statistics is confidential and should be used for statistical purposes only. It also states that arrangements for confidentiality protection should be: sufficient to protect the privacy of individual information, but not so restrictive as to limit unduly the practical utility of official statistics. To comply with this and with the Data Protection Act of 1998, and to maintain the trust and co-operation of those who use reoffending statistics, the following provisions have been put in place. Private information collected by the Ministry of Justice (MoJ) is stored in line with MoJ data security policies. Electronic data are held on password protected networks. All new staff undergo MoJ security vetting before receiving access to data systems, and all staff undertake mandatory training on information responsibility annually. Three types of disclosure risk are considered in relation to reoffending statistics: general attribution, identification (including self-identification) and residual through combination of sources. Assessment of the risk of disclosure considers the following:  Level of aggregation (including geographic level) of the data  Size of the population  The likelihood of an attempt to identify  Consequences of disclosure As a result number of offenders, reoffenders, reoffences and previous offences based on five or fewer offenders are suppressed for individual prisons, probation areas and the following geographical areas; County, Upper Tier Local Authority, Lower Tier Local Authority and Youth Offending Team. This is to prevent the disclosure of individual information. ## Appendix A: Glossary Of Terms Reoffending terms Cohort - this is the group of individuals whose reoffending is measured. Index offence - the index offence is the proven offence that leads to an offender being included in the cohort. Index disposal - the index disposal of the offender is the type of sentence the offender received for their index offence. Start point (index date) - this is the set point in time from when reoffences are measured. Follow-up period - this is the length of time proven reoffending is measured over. Waiting period - this is the additional time beyond the follow-up period to allow for offences committed towards the end of the follow-up period to be proved by a court conviction, caution, reprimand or final warning. Reconviction - where an offender is convicted at court for an offence committed within a set follow-up period and convicted within either the follow-up period or waiting period. Proven reoffence - where an offender is convicted at court or receives some other form of criminal justice sanction for an offence committed within a set follow-up period and disposed of within either the follow-up period or waiting period. Cohort definition used in the Proven Reoffending Statistics Quarterly Bulletin - the proven reoffending cohort consists of all offenders discharged from custody, otherwise sanctioned at court, receiving a caution, reprimand or warning in each year. This cohort's criminal history is collated and criminal behaviour is tracked over the following one year. Any offence committed in this one year period which is proven by a court conviction or out-of-court disposal (either in the one year period, or in a further six months waiting period) counts as a proven reoffence. Cohort definition used in the Interim Proven Reoffending Statistics for CRCs and NPS Quarterly Bulletin - the payment by results proven reoffending cohort consists of all adult offenders in any one quarter (January to March, April to June, July to September, October to December) who begin a community order, a suspended sentence order or who were released from custody. This cohort's criminal behaviour to date is tracked and collated. Any offence committed in this period which is proven by a court conviction or out-of-court disposal counts as a proven reoffence. Cohort definition used in the Local Adult Reoffending Quarterly Bulletin - the local adult reoffending measure takes a snapshot of all offenders, aged 18 or over, who are under probation supervision at the end of a quarter, and combines four such snapshots together. This cohort's criminal history is collated and criminal behaviour is tracked over the following three months. Any offence committed in this three month period which is proven by a court conviction or out-of-court disposal (either in the three month period, or in a further three months waiting period) counts as a proven reoffence. The latest available publication is available at this link. Disposal (sentence type) Fine - a financial penalty imposed following conviction. Court orders - court orders include community sentences, community orders and suspended sentence orders supervised by the Probation Service. They do not include any pre or post release supervision. Criminal Justice Act 2003 (CJA03) - for offences committed on or after 4 April 2005, the new community order replaced all existing community sentences for adults. The Act also introduced a new suspended sentence order for offences which pass the custody threshold. It also changed the release arrangements for prisoners. See Appendix A of Offender Management Caseload Statistics 2009 for more information. Community order - for offences committed on or after 4 April 2005, the new community order introduced under the CJA 2003 replaced all existing community sentences for those aged 18 years and over. This term refers to all court orders except suspended sentence orders and deferred sentences which may have a custodial component to the sentence. The court must add at least one, but could potentially add all 12 requirements depending on the offences and the offender. The requirements are:  unpaid work (formerly community service/community punishment) - a requirement to complete between 40 and 300 hours' unpaid work;  activity - for example, to attend basic skills classes;  programme - there are several designed to reduce the prospects of reoffending;  prohibited activity - a requirement not do so something that is likely to lead to further offence or nuisance;  curfew - which is electronically monitored;  exclusion - this is not used frequently as there is no reliable electronic monitoring yet available;  residence - requirement to reside only where approved by probation officer;  mental health treatment (requires offender's consent);  drug rehabilitation (requires offender's consent);  alcohol treatment (requires offender's consent);  supervision - meetings with probation officer to address needs/offending behaviour; and  attendance centre - between a minimum of 12 hours and a maximum of 36 in total which includes three hours of activity. Typically, the more serious the offence and the more extensive the offender's needs, the more requirements there will be. Most orders will comprise of one or two requirements, but there are packages of several requirements available where required. The court tailors the order as appropriate and is guided by the Probation Service through a pre-sentence report. Suspended sentence order **(SSO)** - the CJA 2003 introduced a new suspended sentence order which is made up of the same requirements as a community order and, in the absence of breach is served wholly in the community supervised by the Probation Service. It consists of an 'operational period' (the time for which the custodial sentence is suspended) and a 'supervision period' (the time during which any requirements take effect). Both may be between six months and two years and the 'supervision period' cannot be longer than the 'operational period', although it may be shorter. Failure to comply with the requirements of the order or commission of another offence will almost certainly result in a custodial sentence. Pre CJA03 Court Orders - Community sentences Community punishment order **(CPO)** - the offender is required to undertake unpaid community work. Community rehabilitation order **(CRO)** - a community sentence which may have additional requirements such as residence, probation centre attendance or treatment for drug, alcohol or mental health problems. Community punishment and rehabilitation order **(CPRO)** - a community sentence consisting of probation supervision alongside community punishment, with additional conditions like those of a community rehabilitation order. Custody - the offender is awarded a sentence to be served in prison or a Young Offenders Institute (YOI). If the offender is given a sentence of 12 months or over, or is aged under 22 on release, the offender is supervised by the Probation Service on release. It is important to note that the sentence lengths and youth disposals awarded will be longer than the time served in custody. For more information please refer to Appendix A of Offender Management Caseload Statistics 2009. Short sentences (under 12 months) - those sentenced to under 12 months (made under the Criminal Justice Act 1991) spend the first half of their sentence in prison and are then released and considered 'at risk' for the remaining period. This means they are under no positive obligations and do not report to the Probation Service, but if they commit a further imprisonable offence during the 'at risk' period, they can be made to serve the remainder of the sentence in addition to the punishment for the new offence. The exception to this is those aged 18 to 20 who have a minimum of three month's supervision on release. Sentences of 12 months or over - the CJA03 created a distinction between standard determinate sentences and public protection sentences. Offenders sentenced to a standard determinate sentence serve the first half in prison and the second half in the community on licence. Youth disposal (sentence type) Reprimand or warning - a reprimand is a formal verbal warning given by a police officer to a juvenile offender who admits they are guilty for a minor first offence. A final warning is similar to a reprimand, but can be used for either the first or second offence, and includes an assessment of the juvenile to determine the causes of their offending behaviour and a programme of activities is designed to address them. Reprimands and warnings for youths were abolished under Legal Aid Sentencing and Punishment of Offenders Act 2012 with effect from 8 April 2013 and replaced with youth cautions. Youth cautions - are a formal out-of-court disposal that can be used as an alternative to prosecution for young offenders (aged 10 to 17) in certain circumstances. A Youth Caution may be given for any offence where the young offender admits an offence, there is sufficient evidence for a realistic prospect of conviction but it is not in the public interest to prosecute. First-tier penalties Discharge - a juvenile offender is given an absolute discharge when they admit guilt, or are found guilty, with no further action taken. An offender given a conditional discharge also receives no immediate punishment, but is given a set period during which, if they commit a further offence, they can be brought back to court and re-sentenced.  **Fine** - the size of the fine depends on the offence committed and the offender's financial circumstances. In the case of juveniles under 16, the fine is the responsibility of the offender's parent or carer.  **Referral order** - this is given to juveniles pleading guilty and for whom it is their first time at court (unless the offence is so serious it merits a custodial sentence or it is of a relatively minor nature). The offender is required to attend a Youth Offender Panel to agree a contract, aimed to repair the harm caused by the offence and address the causes of the offending behaviour.  **Reparation order** - the offender is required to repair the harm caused by their offence either directly to the victim or indirectly to the community. Youth Rehabilitation Order - a community sentence for juvenile offenders, which came into effect on 30 November 2009 as part of the Criminal Justice and Immigration Act 2008. It combines a number of sentences into one generic sentence and is the standard community sentence used for the majority of children and young people who offend. The following requirements can be attached to a Youth Rehabilitation Order (YRO):  activity requirement  curfew requirement  exclusion requirement  local authority residence requirement  education requirement  mental health treatment requirement  unpaid work requirement  drug testing requirement  intoxicating substance misuse requirement  supervision requirement  electronic monitoring requirement  prohibited activity requirement  drug treatment requirement  residence requirement  programme requirement  attendance centre requirement  intensive supervision and surveillance  intensive fostering The following community sentences are replaced by the YRO, but will continue to exist for those that committed an offence before 30 November 2009. The YRO is only available for those that committed an offence on or after the 30 November 2009.  action plan order  curfew order  supervision order  supervision order and conditions  community punishment order  community punishment and rehabilitation order  attendance centre order  drug treatment and testing order  exclusion order  community rehabilitation order Prison categories Category B and category C **prisons** hold sentenced prisoners of their respective categories, including life sentenced prisoners. The regime focuses on programmes that address offending behaviour and provide education, vocational training and purposeful work for prisoners who will normally spend several years in one prison. High security prisons hold category A and B prisoners. Category A prisoners are managed by a process of dispersal, and these prisons also hold a proportion of category B prisoners for whom they provide a similar regime to a category B prison. The category B prisoners held in a High Security Prison are not necessarily any more dangerous or difficult to manage than those in category B prisons. Female prisons, as the name implies, hold female prisoners. Because of the smaller numbers, they are not divided into the same number of categories although there are variations in security levels. Local prisons serve the courts in the area. Historically their main function was to hold un-convicted and un-sentenced prisoners and, once a prisoner had been sentenced, to allocate them on to a category B, C or D prison as appropriate to serve their sentence. However, pressure on places means that many shorter term prisoners serve their entire sentence in a local prison, while longer term prisoners also complete some offending behaviour and training programmes there before moving on to lower security conditions. All local prisons operate to category B security standards. Open prisons have much lower levels of physical security and only hold category D prisoners. Many prisoners in open prisons will be allowed to go out of the prison on a daily basis to take part in voluntary or paid work in the community in preparation for their approaching release. Miscellaneous terms National Probation Service - the National Probation Service generally deals with those aged 18 years and over. (Those under 18 are mostly dealt with by Youth Offending Teams, answering to the Youth Justice Board.) They are responsible for supervising offenders who are given community sentences and suspended sentence orders by the courts, as well as offenders given custodial sentences, both pre and post their release. Police National Computer - the Police National Computer (PNC) is the police's administrative IT system used by all police forces in England and Wales and managed by the National Policing Improvement Agency. As with any large scale recording system the PNC is subject to possible errors with data entry and processing. The Ministry of Justice maintains a database based on weekly extracts of selected data from the PNC in order to compile statistics and conduct research on reoffending and criminal histories. The PNC largely covers recordable offences - these are all indictable and triable-either-way offences plus many of the more serious summary offences. All figures derived from the Ministry of Justice's PNC database, and in particular those for the most recent months, are likely to be revised as more information is recorded by the police. Recordable offences - recordable offences are those that the police are required to record on the PNC. They include all offences for which a custodial sentence can be given plus a range of other offences defined as recordable in legislation. They exclude a range of less serious summary offences, for example television licence evasion, driving without insurance, speeding and vehicle tax offences. Offence group (based on new ONS crime classifications) - offences classified into 13 separate offence categories using the new Office for National Statistics (ONS) crime classifications. Indictable and summary offences - Proven reoffending statistics quarterly (published 28 July 2016) included a table (B1.1) on serious sexual/violent proven reoffences and serious acquisitive proven reoffences. Another way to classify the seriousness of an offence is to classify the offence as 'summary', 'triable-either-way' or 'indictable-only'. Indictable-only offences cover the most serious offences that must be tried at the Crown Court; these 'indictable-only' offences include murder, manslaughter, rape and robbery. These are reported in table B1. Note that summary offences are triable only by a magistrates' court. This group includes motoring offences, common assault and criminal damage up to £5,000. Triableeither-way offences are more serious offences; these can be tried either at the Crown Court or at a magistrates' court, and include criminal damage where the value is £5,000 or greater, theft and burglary. Summary and triable-either-way are not reported. Youth Offending Teams (YOTs) YOTs work with young people that get into trouble with the law and each one cover a certain number of local authorities. The YOTs have been updated in the proven reoffending publication published on the 28th July 2016. ## Explanatory Notes The United Kingdom Statistics Authority has designated these statistics as National Statistics, in accordance with the Statistics and Registration Service Act 2007 and signifying compliance with the Code of Practice for Official Statistics. Designation can be broadly interpreted to mean that the statistics:  meet identified user needs;  are well explained and readily accessible;  are produced according to sound methods; and  are managed impartially and objectively in the public interest. Once statistics have been designated as National Statistics it is a statutory requirement that the Code of Practice shall continue to be observed. ## Symbols Used | .. | Not available | |--------|--------------------------------------------------------| | 0 | Nil or less than half the final digit shown | | - | Not applicable | | * | One or both of the comparison figures are less than 30 | | (p) | Provisional data | ## Contact Details For queries, comments or further information, please contact: Nick Mavron Ministry of Justice Justice Statistics Analytical Services 7th floor 102 Petty France London SW1H 9AJ Email: statistics.enquiries@justice.gsi.gov.uk Alternative formats are available on request from statistics.enquiries@justice.gsi.gov.uk. ## © Crown Copyright 2015 This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk. ##
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CREATED FOUND DETECTED EXPLORE YOUR ARCHIVE CAMPAIGN TOOLKIT 01 GETTING INVOLVED EXPLORED UNEARTHED LEARNT DISCOVERED CELEBRATED CONNECTED IMAGINED REVEALED ## Levels Of Involvement Easy level We know that many of you don't have much resource and time, so here are different ways that you can get involved. Explore Your Archive is an ongoing, annual campaign. It is owned by the sector, giving you freedom to use the campaign in support of any event that you may be planning at any time of the year. | - | |------------------------------------| | channels to let people know | | about the campaign e.g. include | | something on your website, in | | a newsletter or on social media | | about the Explore Your Archive | | campaign in the run up to the week | Archives and record offices experienced in public outreach, advocacy and event promotion may not need much of the advice or accessories in this toolkit. But, as with everyone else, you have absolute flexibility to use the logos, branding and other items in this toolkit in support of your plans. - You could use key messages and template press release to draft a press release to issue to your local/specialist media to let them know about the Explore Your Archive campaign For those new to campaigning or with limited capacity to organise events, you may find it useful to aim for an activity in launch week, and the following menu of options helpful in choosing your ideal level of participation. Many archives and record offices have said that they like to have an identified campaign launch week each year to help them sell ideas internally and plan activities as far in advance as possible. To date, launch week has taken place around the middle of November each year, and now over two consecutive weekends. Extensive efforts to find an 'ideal' week in the calendar that works for everyone have so far failed, so we have tended to stick to November. For those of you who choose this option, we focus the lion's share of our annual publicfacing campaign promotional activity (conventional media, social media, wider marketing, etc.) in the four weeks or so preceding launch week. Each region/nation of the UK and Ireland tends to have its own designated 'launch event' or series of events. Highest level Medium level - You could create a 'Story Box' - more on this on the following pages - and spread the word about this through your existing channels and through local/specialist media - You could create a 'Story Box' - more on this on the following pages - and spread the word about this through your existing channels and through local/specialist media - You could use your existing channels to let people know about the campaign e.g. include something on your website, in a newsletter or on social media about the Explore Your Archive campaign in the run up to the week - You could use your existing channels to let people know about the campaign e.g. include something on your website, in a newsletter or on social media about the Explore Your Archive campaign in the run up to the week - You could use key messages and template press release to draft a press release to issue to your local/specialist media to let them know about the Explore Your Archive campaign - You could use key messages and template press release to draft a press release to issue to your local/specialist media to let them know about the Explore Your Archive campaign - You could engage with local groups, organisations and charities asking them to let people know about the campaign through their newsletters, groups etc and potentially taking your 'Story Box' to one of their gatherings if possible - You could hold an event about your 'Story Box' ## Campaign Timeline Standard timelines for events being planned for campaign launch week: Month Potential Activity June - Early September - Get internal buy in from other staff members and relevant teams The other sections of this toolkit explain more about how you can do each of these, what we mean by 'story boxes' and guidance on how to go about some of the things we have suggested. | - | For those with medium to high level involvement, you may want | |-------------------------------------------------------------------|-------------------------------------------------------------------| | to start pulling together materials for your 'Story Box' (more on | | | this later) and engaging with local/specialist ambassadors | | | August | | | - September | | | - | Draft a press release/liaise with press team to get this written | | and approved | | We've also created some handy downloadable resources to help you, including a template press release, ready-to-use posters, campaign logos in a variety of sizes and files to suit your digital, printing and poster needs, and a suggested timeline. | - | |-------------------------------------------------------------------| | specialist groups, organisations and charities about the campaign | | and what you're doing | You can download resources for your campaign from the Explore Your Archive web pages. October - November - Issue your press release to local/specialist media - Create/print posters or leaflets and use existing channels to raise awareness of the campaign and, if you are doing one, your event - Hold an event around mid November
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## Licensing Authority Statistics April 2014 To March 2019 Contents | Headline findings | 3 | |---------------------------------------------|-----| | Executive summary | 4 | | Preface | 5 | | The Gambling Commission | 5 | | Licensing authorities | 5 | | Licensing authority returns | 5 | | Permits and notifications | 6 | | Licensed premises | 6 | | Notices | 8 | | Occasional use notices | 8 | | Temporary use notices | 8 | | Permits, notifications and notices combined | 8 | | Inspections and visits | 9 | | Overview | 9 | | Pre-planned inspections | 10 | | Follow up inspections | 10 | | Inspections following a complaint | 11 | | Test purchasing visits | 11 | | Inspections/Premises percentage map | 12 | | Local Authority Compliance Events (LACE) | 13 | | Appendix A: Terminology | 14 | | Appendix B: Data collection methodology | 15 | | Appendix C: Further Information | 15 | ## Headline Findings The headline findings in this report indicate areas of interest resulting from data provided by all 380 licensing authorities for the year ending 31 March 2019. 51,541 Permits/Notifications for gambling activity currently active. (-1.4% from March 2018) 2,838 Permits/Notifications for gambling activity issued this year. (-37% from March 2018) 5,098 Inspections/visits of premises where gambling activity takes place conducted by licensing authorities. (+1% from March 2018) 13 Average number of inspections/visits of premises where gambling activity took place per licensing authority. (No change from March 2018) 105 Total number of licensing authorities which did not conduct any inspections/visits of premises. (-13% from March 2018) 140 Total test purchasing visits conducted by all licensing authorities. (+77% from March 2018) ## Executive Summary This report provides statistics by licensing authorities (LAs) in respect of their duties under the Gambling Act 2005 for the regulation of gambling in Great Britain. This edition reports on the periods between April 2014 and March 2019. For reference, the accompanying Excel file contains comparative data dating back to April 2009. As of March 2019, there are 51,541 permits and notifications in force for gambling-related activity in alcohol-licensed premises, clubs and unlicensed family entertainment centres across Great Britain. This represents a 1% decrease on last year, and a 7% decline over the last 5 years. LAs reported that a total of 2,838 permits were issued or notifications received. Over a 5-year period, this figure has fallen by 1,729 (38%). The average quantity of permits issued/notifications received per LA was 7. In addition, LAs have received 465 Occasional Use Notices (OUNs), allowing betting operators licensed by the Gambling Commission (the Commission) to take bets on tracks. A total of 9 Temporary Use Notices (TUNs) were submitted to LAs, permitting the holder of a nonremote casino operating licence (licensed by the Commission) to offer gambling activities at a temporary venue for a limited period of time. The report also presents the quantity of LA conducted pre-planned inspections, follow-up inspections, inspections following a complaint, and test purchasing visits for age verification. During this reporting period (as part of their regulatory responsibility for gambling) LAs inspected or visited 5,098 premises, of which 3,290 were at locations where the operator is licensed by the Commission (for example, arcades, bookmakers, bingo halls, casinos and race tracks). Overall, this is an increase of 1% compared to last year. However, this is due entirely to visits to premises where the operator is not licensed by the Commission (Other). There have been decreases in all remaining areas. Over a 5-year period there is an overall decrease of 20% in the total quantity of inspections and visits conducted by LAs. There is a decrease in inspections following a complaint and follow-up inspections, and an increase in preplanned inspections and test purchasing visits. Compared to the previous reporting period, test purchasing visits rose by 77% and pre-planned inspections increased by 1%. Inspections following complaints fell by 12% while follow up inspections reduced by 21%. There is a wide variation in the performance of LAs with respect to conducting inspections and visits. Of the 380 LA's, 6 (2%) conducted more than 100 inspections or visits in the year ending 31 March 2019. A majority of 253 (67%) conducted fewer than 10 inspections or visits during the year (including 105 LAs which conducted none). The average quantity of premises inspected or visited by each LA during this period was 13. To make the system of shared regulation as effective and efficient as possible, the Commission notifies LAs of complaints and intelligence received regarding noncompliance and illegality in their geographical area which is primarily of a localised nature. These are referred to as Local Authority Compliance Events (LACE) referrals. During this reporting period, 85 referrals were made in the year ending March 2019, compared with 74 in the previous year (a 15% increase). ## Preface The Gambling Commission The Gambling Commission regulates commercial gambling in Great Britain, including arcades (excluding unlicensed Family Entertainment Centres), betting, bingo, casinos, gaming machine manufacturers and suppliers, gambling software providers, lottery operators and external lottery managers (excluding small society lotteries), remote gambling and the National Lottery. The Commission does not regulate spread betting - this is the responsibility of the Financial Conduct Authority. ## Licensing Authorities The Gambling Act 2005 established a system of shared regulation in gambling. It created one national regulator - the Commission - and many local regulators, the licensing authorities. The Act provides LAs with wide ranging powers to manage gambling provision locally, and with the ability to set fees in England and Wales (they are centrally set in Scotland) that cover the costs of discharging their responsibilities. The Commission and LAs work in partnership to ensure that businesses which provide gambling do so in a way that; keeps crime out of gambling, keeps it fair and open for consumers, and protects children and other vulnerable people. Although the Commission and LAs work in partnership, LAs tend to focus on the impact of gambling provision on local communities while the Commission's attention is more often focused at a national and regional level. Within that overall framework, LAs have a range of specific responsibilities, including1: • licensing and regulating premises for gambling activities • considering notices given for the temporary use of premises for gambling • granting permits for gaming and gaming machines in clubs and miners' welfare institutes • regulating gaming and gaming machines in alcohol licensed premises • granting permits to unlicensed family entertainment centres for the use of certain lower stake gaming machines • granting permits for prize gaming • considering occasional use notice for betting at tracks • registering small society lotteries ## Licensing Authority Returns LAs have a statutory duty to provide specific information to the Commission about aspects of gambling regulation - for example, the grant of premises licences and the annual return dataset. The Commission collates and analyses the LA returns to help it, LAs and the Government understand the local and national landscape of gambling regulation. The annual return is included in the Single Data List2 that the Ministry of Housing, Communities and Local Government has issued. ## Permits And Notifications This section reports information on the different types of gambling permits and notifications3. The total number in force as at 31 March 2019 was 51,541, a decrease of 726 (1.4%) on last year's figure. Over a 5-year period, the total has decreased by 3,961 permits and notifications (7.1%). ## Licensed Premises In addition to the 51,541 permits and notifications currently in force, there are 10,866 premises in Great Britain where a licence has been granted by the LA. A premises licence, rather than a permit, is required when an operator is using a premises for a gambling business licensed by the Commission4. 4 Gambling Sector At 31 Mar 2015 At 31 Mar 2016 At 31 Mar 2017 At 31 Mar 2018 At 30 Sept 2018 Betting 8,995 8,915 8,802 8,557 8,425 5 6 Adult Gaming Centre (AGC) 1,610 1,549 1,546 1,511 1,436 Bingo 674 654 635 657 650 331 345 319 219 203 Family Entertainment Centre6 (FEC) Casino 148 152 149 151 152 Total 11,758 11,615 11,451 11,095 10,866 The total number of permits that LAs issued and notifications that LAs received was 2,838 for the year ending 31 March 2019. This is a decrease of 1,672 (37%) from the year prior. Over 5 years, the total cumulative number of permits and notifications has fallen by 3,961 (7%). Notifications received for Alcohol Licensed Premises - Automatic Entitlement accounted for 74.4% of all permits issued and notifications received during the year ending 31 March 2019. Alcohol Licensed Premises - Gaming Machine Permit accounted for 14.0%, Club Machine Permit 5.7%, Unlicensed FEC 4.5% and Club Gaming Permit 1.4%. Over the last 5 years, the number of Unlicensed FEC permits issued increased by 15% from 111 year ending March 2014 to 128 year ending March 2019. Alcohol Licensed Premises - Gaming Machine Permits, Club Machine Permits, Club Gaming Permits and Alcohol Licensed Premises - Automatic Entitlement notifications issued have all decreased over the same period by 50%, 48%, 38% and 36% respectively. Many LAs reported that they had changed data recording systems during 2018-2019 which had identified previous reporting duplications, which they have addressed in this year's returns. A number of Club Machine Permits and Unlicensed FEC Permits had not been renewed when their 10 year permit expired. ## Notices Occasional Use Notices There were 465 Occasional Use Notices (OUNs) received by 85 LAs between April 2018 and March 2019. This represents a decrease of 3% of OUNs received over the previous 5 years. The number of days (465) which OUNs allowed betting operators licensed by the Commission to take bets on tracks has decreased by 17% over the same 5 year period. 295 LAs did not receive OUNs during the year ending 31 March 2019. ## Temporary Use Notices There were 9 Temporary Use Notices (TUNs) received by 8 LAs between April 2017 and March 2018. This represents an increase of 29% of TUNs received over the previous 5 years. The number of days covered by the TUNs (permitting the holder of a non-remote casino operating licence, licensed by the Commission, to offer gambling activities at a temporary venue for a limited period of time), has decreased by 21% to 33 days over the last 5 years. 371 LAs did not receive TUNs during the year ending 31 March 2019. ## Permits, Notifications And Notices Combined Apr 2014 Mar 2015 Apr 2015 Mar 2016 Apr 2016 Mar 2017 Apr 2017 Mar 2018 Apr 2018 Mar 2019 Total Permits / Notifications & Notices Issued 4,458 4,011 3,727 4,913 3,312 1,343 1,518 1,405 1,498 1,201 Total Permits / Notifications & Notices Issued excluding Alcohol Licensed Premises - Automatic Entitlement ## Inspections And Visits Overview The types of inspections reported as being undertaken by LAs are as follows: • Pre-planned inspections • Follow-up inspections • Inspections following a complaint • Test purchasing visits During the period April 2018 to March 2019, as part of their regulatory responsibility for gambling, LAs inspected or visited 5,098 premises, of which 3,290 were at locations where the operator is licensed by the Commission (for example, arcades, bookmakers, bingo halls, casinos and race tracks). The remaining 1,808 inspections were to 'Other' premises. These are mainly premises where no requirement to hold a gambling operating licence exists, such as pubs and clubs. 'Other' premises and betting premises comprise 82% of the inspections/visits conducted. AGC, betting, bingo, casino, and FECs saw a decrease of premises inspected or visited; with 'Other' visits and inspections increasing by 377. (Figure 5). Primarily, visits rather than inspections take place when test purchasing. Over the last 5 years, the total quantity of inspections and visits conducted by LAs has decreased by 23% (from 6,367 conducted over the period April 2013 to March 2014) (Figures 5 & 6). ## Pre-Planned Inspections Pre-planned inspections account for 91% of all inspection types. Betting and 'Other' accounted for 82% of all pre-planned inspections during the period April 2018 to March 2019. ## Follow-Up Inspections Betting accounted for 48% (77) of all follow-up inspections for the period April 2018 to March 2019, an increase of 12 (18%) compared to the previous 12 months. ## Inspections Following A Complaint 'Other' accounted for 46% of all inspections following a complaint during the period April 2018 to March 2019. Betting accounted for 21% and AGCs accounted for 15% over the same period. ## Test Purchase Visits (For Age Verification) LAs conducted 140 age verification related test purchasing visits in the year to March 2019. Although this is an increase of 61 (77%) over the previous year, it is 55 (28%) less than the number of test purchasing visits made 5 years ago. This increase was due to a focus on checking the age verification controls on over 18 (Category C) gaming machines in pubs. Over the last year 76% of all test purchasing visits were to 'Other' premises, 14% were to betting. There were no visits to casino premises. The figures reported relate to the number of test purchasing visits carried out, rather than the number of premises tested. The same premises may have been tested more than once. These figures include the underage gambling test purchasing conducted by local authorities in partnership with the Commission. More detailed information on test purchasing can be found on our website. Pre-planned inspections are the only type of visits included in this mapping data. Map 1 illustrates the number of preplanned inspections as a percentage of the total premises per licensing authority. A total of 7 LAs conducted either follow-up inspections or inspections following a complaint, but did not undertake any pre-planned inspections. The Commission has published an advice note (The role of authorised persons in Scotland) to assist licensing authorities in Scotland in carrying out their functions under the Act. The premises figures used to calculate the percentages in the map were obtained from the premises register, as of May 2019. We maintain a national register of premises licences for gambling, but we are reliant on data provided to us by licensing authorities and gambling businesses to populate this register. Consequently, whilst we make every effort to assure the data, it may contain errors, duplications or there may be omissions. ## Local Authority Compliance Events To make the system of shared regulation as effective and efficient as possible, the Commission notifies LAs of complaints and intelligence received regarding non-compliance and illegality in their geographical area which is primarily of a localised nature. These are referred to as Local Authority Compliance Events (LACE). The responsibility for the LACE referral is then discharged from the Commission to the LA. The complaints that instigate the LACE referrals come from a variety of sources, including licensed operators and members of the public. A number of them are received anonymously via the Commission's confidential intelligence phone line. There were 85 LACE referrals to 66 LAs during the reporting period April 2018 to March 2019, a 15% increase compared to last year. Referrals can range from reports of illegal gaming in areas such as pubs and clubs, illegally sited machines in areas such as restaurants, pubs, taxi offices & take away retailers and could also relate to underage gambling. Apr 2014 Mar 2015 Apr 2015 Mar 2016 Apr 2016 Mar 2017 Apr 2017 Mar 2018 Apr 2018 Mar 2019 Arcades 3 5 21 9 4 Betting 36 36 24 33 28 Bingo 7 8 8 4 12 Casino 1 1 1 1 0 Lotteries 10 7 7 2 7 Machines 52 55 27 11 13 Poker 39 44 20 13 19 Unallocated 0 3 1 1 2 Total 148 159 109 74 85 More detailed information can be found on the Excel version of this document. ## Appendix A: Terminology Adult Gaming Centre (AGC) - an arcade licensed by the Gambling Commission comprising a limited number of B3 and B4 machines and an unlimited number of category C and D machines. No one under the age of 18 is allowed to enter. Alcohol Licensed Premises - Automatic Entitlement - Pubs and other alcohol licensed premises are automatically entitled to two category C or D gaming machines upon notification to the licensing authority of their intention to make gaming machines available for use. Alcohol Licensed Premises - Gaming Machine Permits - Licensing authorities can issue gaming machine permits which allow additional category C and D gaming machines to be provided. Where a gaming machine permit authorises the making available of a specified number of gaming machines in particular premises, this will effectively replace, and not be in addition to, any automatic entitlement to two machines. Club Machine Permit - Club Machine Permits allow the holder to have no more than three gaming machines in total. Members' clubs may site up to three machines from categories B3A, B4, C or D but only one B3A machine can be sited, by agreement, as part of this entitlement. Commercial clubs may site up to three machines from categories B4, C or D (not B3A machines). This permit also allows the holder to offer equal chance gaming such as poker or bingo with limits placed on stakes and prizes for both types of game. Club Gaming Permit - Club Gaming Permits allow the holder to have no more than three gaming machines in total of categories B3A, B4, C or D, but only one machine of category B3A. This permit also allows the holder to offer equal chance gaming such as poker (with no limit on stakes and prizes) or bingo (with limits placed on stakes and prizes) and games of chance (pontoon and chemin de fer only). Family Entertainment Centre (FEC) - an arcade licensed by the Gambling Commission comprising unlimited category C and D machines. Under 18s are allowed in FECs but not into the area offering category C machines. Occasional Use Notice - This notice permits betting operators, licensed by the Gambling Commission, to use tracks for short periods of betting at events which are temporary or infrequent. The notice must specify the day on which it has effect. Notices may be given in relation to consecutive days, up to an overall limit of eight days in a calendar year. Temporary Use Notice - This notice permits the holder of a casino operating licence, licensed by the Gambling Commission, to offer gambling activities at a temporary venue for a limited period of time. Test Purchasing - Test purchasing exercises are a method by which Local Authorities may measure the compliance of licensed premises with aspects of the Gambling Act 2005 and to assess whether effective controls are in place to prevent underage gambling. Unlicensed Family Entertainment Centre (UFEC) Gaming Permits - Unlicensed FECs can offer only category D machines. Any number of category D machines can be made available with such a permit subject to other considerations, such as fire regulations and health and safety. Permits cannot be issued in respect of vessels or vehicles. ## Appendix B: Data Collection Methodology Data within this document has been collated by the Gambling Commission and is drawn from returns submitted by LAs and additional information provided through complaints and intelligence received by the Commission. All LAs in England, Scotland and Wales were required to submit a return. The data submitted is quality checked and where anomalies appear they are followed up with the appropriate LA and amendments are agreed where applicable. The Commission is committed to working with LAs to increase the efficiency of the data collection process and explore methods to increase the value of this work to stakeholders. Totals and percentages are calculated from unrounded figures. The information contained in this document covers LAs in England, Scotland and Wales only. The quality checks can sometimes require historical data to be amended. Consequently, the data provided in this report may differ from those provided previously. The methodology for producing this report is consistent with Official Statistics guidelines. At 31 March 2019, there were 380 LAs, of which 380 (100%) submitted a return to the Commission. ## Appendix C: Further Information Supporting data tables for the report's charts can be found in the Licensing authority statistics - MS Excel document. An up-to-date list of the notifications of grant for premises licences received from each LA can be found on the premises register section of our website. Further statistics and information relating to the Gambling Commission and gambling in Great Britain are available from our website. Guidance to Licensing Authorities (GLA) on the Gambling Commission website. making gambling fairer and safer Responsible statisticians: Andrew Dixon Senior Data Analyst Matthew Webster Head of Profession for Statistics For further information or to register your interest in the Commission please visit our website at: www.gamblingcommission.gov.uk Copies of this document are available in alternative formats on request. Gambling Commission Victoria Square House Victoria Square Birmingham B2 4BP T 0121 230 6666 F 0121 230 6720 E info@gamblingcommission.gov.uk Gambling Commission Published September 2019
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## Licence Exemption 1. The Office of Rail Regulation (ORR) exempts under section 7(3) of the Railways Act 1993: ## [Full Company Name] Registered In **[England And Wales/Scotland]** With Number **[Xyz]** from the requirement to be authorised by licence to operate the railway assets described in paragraph 2 below. 2. This exemption applies to: (a) any light maintenance depot (LMD) which has been notified to ORR and in respect of which ORR has not objected within 30 days of being notified; (b) any train being used on the network within the depot. A list of the LMDs to which this exemption applies is at Schedule 1. 3. This exemption is valid from [Day Month Year]. 4. ORR may revoke the whole or any part of this exemption: (a) if the exemption holder is granted another licence or exemption for the operation of all or some of the railway assets to which this exemption applies; or (b) if ORR suspects on reasonable grounds that the exemption holder has operated a railway asset without a necessary licence or exemption; or (c) if all or some of the railway assets to which this exemption applies are not used for at least one year; or (d) if the exemption holder ceases to be the operator of all or some of the assets to which this exemption applies; or (e) by agreement in writing with the exemption holder. Signed by authority of ORR [Day Month Year] Reference number: ## Schedule 1 The LMDs to which this exemption applies are: | LMD | Date | |--------|---------| | 1. | | | 2. | | | 3. | | | 4. | | | | |
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FOI Response released on 04 February 2019 relating to Corporate Manslaughter charges ## Freedom Of Information Act 2000 Request Request Could You Please Provide Me With: 1. The number of charges brought for corporate manslaughter each year since the introduction of the Act. 2. The names of all organisations charged with corporate manslaughter. 3. Whether charges were also brought under Health and Safety legislation against any of the organisations. If charges were initially brought and then dropped, please confirm this if possible. 4. Whether charges were also brought against Directors or employees of the organisation under either health and safety legislation or gross negligence manslaughter. If charges were initially brought and then dropped, please confirm this if possible. 5. The outcome of the cases (and the year of the outcome). 6. The sentences in the successful prosecutions. Response The offence of corporate manslaughter (and in Scotland, corporate homicide) was introduced by the Corporate Manslaughter and Corporate Homicide Act 2007. By definition, a charge of corporate manslaughter can only be brought against an organisation (which includes government departments and crown bodies). The 2007 Act effectively absolved organisations of liability for the offence of common law manslaughter; however, individual employees can still be charged with gross negligence manslaughter. Individual employees (and organisations) can similarly be charged over the same underlying incidents leading to the death under the Health and Safety at Work Act 1974. Floor 8, 102 Petty France, London SW1H 9EA United Kingdom You have asked for "The number of charges brought for corporate manslaughter each year since the introduction of the Act". That information can be summarised as follows: | Year | Cases | |---------|----------| | 2008 | 0 | | 2009 | 1 | | 2010 | 0 | | 2011 | 1 | | 2012 | 1 | | 2013 | 5 | | 2014 | 6 | | 2015 | 5 | | 2016 | 5 | | 2017 | 1 | | 2018 | 2 | The information you have requested in questions 2-6 can be found in the table on the following page. Please note that information regarding the charges brought in each case has been taken from the formal indictment submitted by the prosecution at the start of each trial. Case outcomes refer to the corporate manslaughter offence only. In some cases, the figures given in the final column (sentences) represent the cumulative total of fines given in connection to all charges for which the organisation was found guilty. Name of organisation Sentence in successful outcome Outcome of the case and year of outcome H&S charges brought against the organisation? (Y/N) Charges brought against brought against Directors or employees of the organisation under either health and safety (H&S) legislation or for common law manslaughter (GNM) Y GNM and H&S. Guilty - 2011 Fined £385,000 Cotswold Geotechnical Holdings Ltd Fined £480,000 Lion Steel Equipment Ltd N GNM and H&S Guilty plea - 2012 Y H&S Guilty plea - 2013 Fined £134,579.79 Princes Sporting Club Ltd Fined £183,000 Y GNM and H&S Guilty plea - 2014 Mobile Sweepers (Reading) Ltd | | PS & JE Ward | Y | | Not guilty - | |------------------|-----------------|---------------|------------------|------------------| | 2014 | | | | | | | MNS Mining | | | | | Ltd (Fyfields) | | | | | | N | GNM | Not guilty - | | | | 2014 | | | | | | N | H&S | Guilty - 2014 | Fined £500,000 | Sterecycle | | (Rotheram) Ltd | | | | | | Y | | Guilty - 2014 | Fined £150,000 | Cavendish | | Masonry Ltd | | | | | | Fined £220,000 | Peter Mawson | | | | | Ltd | | | | | | Y | GNM and H&S | Guilty plea - | | | | 2015 | | | | | | Y | H&S | Guilty - 2015 | Fined £200,000 | Pyranha | | Mouldings | | | | | | fined £150,000 | Huntley Mount | | | | | Engineering Ltd | | | | | | Y | GNM | Guilty plea - | | | | 2015 | | | | | | Y | | Guilty - 2015 | Fined £600,000 | CAV Aerospace | | Ltd | | | | | | Fined £200,000 | Y | GNM and H&S | Guilty plea - | | | 2015 | | | | | | Linley | | | | | | Developments | | | | | | Ltd | | | | | | N | | Guilty - 2015 | Fined £300,000 | Kings | | Scaffolding Ltd | | | | | | Baldwin's | | | | | | Crane Hire Ltd | | | | | | Y | | Guilty - 2015 | Fined - £700,000 | | | | | | | | | Fined - £50,000 | N | GNM | Guilty plea - | | | 2015 | | | | | | Cheshire Gate | | | | | | and | | | | | | Automation Ltd | | | | | | | N | GNM | Judge directed | | | acquittal - | | | | | | 2016 | | | | | | Maidstone and | | | | | | Tunbridge | | | | | | Wells NHS | | | | | | Trust | | | | | | Fined - £300,000 | Sherwood Rise | Y | GNM and H&S | Guilty plea - | | 2016 | | | | | | N | GNM and H&S | Guilty - 2016 | Fined - £600,000 | Bilston Skips | | Ltd | | | | | | Fined - £550,120 | Y | H&S | Guilty plea - | | | 2016 | | | | | | Monavan | | | | | | Construction | | | | | | Ltd | | | | | | Ozdil | | | | | | Investments | | | | | | Y | H&S | Guilty - 2017 | Ozdil - fined | | | £660,000 | | | | | | Koseoglu - fined | | | | | | £400,000 | | | | | | Y | GNM and H&S | Guilty - 2017 | Fined - £300,000 | SR and RJ | | Brown | | | | | | JTF Wholesale | Y | H&S | |-------------------|-------------|----------------| | | | | | | | | | Y | H&S | Guilty - 2017 | | Construction | | | | Products Ltd | | | | Martinisation | | | | Ltd | | | | | | | | Y | H&S | Guilty - 2017 | | | | | | | | | | Y | GNM and H&S | Awaiting trial | | Consultants Ltd | | | | No | H&S | Awaiting trial | | Haulage Ltd | | | Information Management Unit 020 3357 0899 IMU@cps.gov.uk | | |-----| | |
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